SUMMARY

• The European Commission has published a second edition of its Frequently Asked Questions on the Packaging and Packaging Waste Regulation (PPWR), ahead of the Regulation’s general application from 12 August 2026. Members can find the updated FAQs here: https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1/language-en‍
• The new edition includes a significant number of clarifications. Of particular relevance to FESI members, the Commission has now addressed the treatment of packaging and packaged products already held in stock before 12 August 2026, an issue raised repeatedly by members.
• The Commission confirms that packaging already produced or held in stock before 12 August, but not yet placed on the market, does not need to be destroyed, remanufactured or physically relabelled. For such existing stock, the identification and manufacturer information required under Article 15 may instead be provided through an accompanying document when the packaging is subsequently placed on the market.
• The Commission also encourages national authorities to begin with warnings and allow companies a reasonable opportunity to take corrective action before considering prohibition, recall or withdrawal.
• The FAQs also provide further clarification on batch-level identification, technical documentation, transport packaging, supplier responsibilities and enforcement.

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MORE INFORMATION

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Existing and carry-over stock

The most important clarification concerns existing stock, including carry-over products such as shoeboxes, polybags and other packaging already held in warehouses.

The Commission distinguishes between:

• Packaging already placed on the market before 12 August 2026, which may remain on the market without having to comply retroactively with the new PPWR requirements; and
• Packaging already produced or held in stock before that date but not yet placed on the market.
  

For the second category, the Commission confirms that the packaging does not have to be destroyed, remanufactured or relabelled. The information required under:

Article 15(5) — type, batch, serial number or another identification element; and

Article 15(6) — manufacturer name, postal address and relevant contact details,

may be provided through accompanying documentation.

This should provide welcome operational flexibility for brands and retailers selling existing warehouse stock after 12 August. However, it should not be understood as a complete exemption from all substantive PPWR obligations applicable when the packaging is placed on the market.

For packaging produced after 12 August 2026, direct marking remains the general rule. Accompanying documentation may normally be used only where the size or nature of the packaging does not allow the information to be affixed directly.

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Identification and traceability

The Commission confirms that Article 15 does not require an individual identification number for every packaging unit. Identification may be organised at the level of the packaging type, model, production batch or another equivalent element linked to the technical documentation and Declaration of Conformity.

For standard packaging items such as tape, bags or desiccants, batch-level traceability may therefore be sufficient.

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Technical documentation

Laboratories, consultants and authorised representatives may support conformity assessment and documentation processes. However, the legal responsibility for drawing up and maintaining the technical documentation remains with the manufacturer and cannot be transferred by contract.

Suppliers must provide manufacturers with the information and documentation needed to demonstrate conformity.

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Substances of concern and heavy metals

The Commission confirms that the obligation to minimise substances of concern applies from 12 August 2026. Pending an updated standard, manufacturers may use Annex C of EN 13428:2004 as an assessment method, although it does not provide a full presumption of conformity.

For the existing combined limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium, the Commission recommends CEN report CR 13695-1/2000.

For food-contact packaging, the PFAS limits also apply from 12 August, but a fully harmonised EU testing methodology is still under development. Companies should therefore rely on appropriate supplier evidence, risk assessment and testing where relevant.

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Transport packaging

The FAQs also clarify that:

• A flat cardboard box may already be considered finished packaging;
• Stretch wrap sold on a roll is already packaging before use;
• A logistics sticker does not by itself make the company applying it the manufacturer; and
• For unbranded custom-made packaging, the company determining the design specifications may be considered the manufacturer.

Enforcement

The Commission encourages national authorities to begin with warnings and allow companies a reasonable opportunity to take corrective action before considering prohibition, recall or withdrawal.

However, this guidance is not legally binding, and enforcement remains the responsibility of national authorities. Companies should therefore ensure that technical documentation and Declarations of Conformity can be produced promptly.

Key Dates

Key PPWR dates and actions (based on external assessments):

By 12 August 2026 – Confirm responsibility: determine who acts as the PPWR manufacturer, importer and EPR producer for each packaging flow.

By 12 August 2026 – Map packaging: identify packaging types, components, suppliers, materials, weights and relevant markets.

By 12 August 2026 – Review existing stock: identify relevant packaging and packaged products produced or held in stock before 12 August 2026 and determine whether an accompanying-document solution is needed.

By 12 August 2026 – Prepare compliance files: ensure appropriate supplier evidence, technical documentation and an EU Declaration of Conformity are available for packaging placed on the EU market. Documentation should be retained for the required period (generally five years).

By 12 August 2026 – Verify restricted substances: confirm compliance with the heavy-metal limit for all packaging and the specific PFAS limits for food-contact packaging.

By 12 August 2026 – Review packaging design: document how packaging weight and volume have been minimised and how recyclability has been assessed.

By 12 August 2026 – Check identification requirements: establish appropriate batch-level identification and review requirements relating to packaging identification, company name, address and contact information.

Immediate and ongoing – Verify national EPR compliance: check registrations, reporting, fees and authorised-representative requirements in each relevant Member State. A list of National Competent Authorities is available here, along with a list of European National Registers for Packaging.

Not yet due in August 2026: harmonised EU sorting labels, detailed recyclability grades, recycled-content targets, the 50% empty-space limit and most reuse targets apply at later dates.

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