Focus on… PPWR

Commission publishes guidance on interpretation
European Commission adopts first Delegated Act

Commission publishes guidance on interpretation

The European Commission has published guidance to support the interpretation and implementation of selected provisions of the EU Packaging and Packaging Waste Regulation (PPWR), as well as an accompanying FAQ document, designed as a “living document” that will be updated as further implementation questions arise.

Together, these documents aim to clarify key aspects of the Regulation and facilitate a more harmonised application across Member States.

The guidance addresses a range of practical issues raised by stakeholders. It provides clarifications on key definitions such as ‘packaging’, ‘manufacturer’ and ‘producer’, the treatment of borderline cases, and exemptions for certain packaging formats. It also elaborates on design-for-recycling requirements, confirming that all packaging placed on the EU market must be recyclable by August 2026, while further harmonised criteria will be specified through secondary legislation.

Further clarifications concern reuse obligations, in particular the scope of reuse targets for transport and sales packaging. The guidance confirms that large-scale reusable formats such as beverage kegs used in hotels, restaurants and cafés are not counted towards reuse targets where they are not made available to consumers, while smaller reusable sales packaging is included.

It also clarifies that reuse requirements depend on the function and feasibility of the packaging, and that responsibility for compliance may fall on manufacturers, importers or distributors depending on the use case.

In addition, the document provides guidance on deposit return systems (DRS), including conditions for exemptions and minimum requirements, as well as on packaging minimisation, empty space ratios, compostability and labelling obligations. It also confirms exemptions from certain requirements, for instance for contact-sensitive packaging or specific material types.

Importantly, the guidance addresses the relationship between the PPWR and the Single-Use Plastics Directive (SUPD), particularly regarding packaging bans. It confirms that certain restrictions on single-use plastic packaging and product-specific obligations under the SUPD continue to apply alongside the PPWR framework.

According to the document, the PPWR establishes harmonised restrictions for specific packaging formats listed in Annex V that prevail over the SUPD in these cases. This means that, for those formats, Member States can no longer rely on SUPD provisions to introduce less stringent national measures. At the same time, the SUPD remains applicable to single-use plastic products not covered by Annex V.

The guidance also highlights that composite packaging must be assessed under both regimes, as the PPWR’s 5% plastic threshold does not exempt such packaging from SUPD requirements. At the same time, the Commission indicates that this dual framework may not be permanent, as a review of the SUPD is planned for 2027.

From a compliance perspective, further clarity on the interaction remains particularly relevant for producers, as overlapping obligations and differing national implementation approaches continue to create complexity.

In this context, European Recycling Platform, a Landbell Group company, has advocated for a clearer delineation between the two frameworks and, in the longer term, for addressing single-use plastic packaging requirements primarily under the PPWR to improve coherence and reduce administrative burden.

The guidance document will be formally adopted once all language versions are available, with the Commission stressing that it will continue to support and monitor the implementation of the PPWR.

Commission adopts first Delegated Act

On 25 February 2026, the European Commission adopted its first Delegated Act under the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40.

This exempts pallet wrapping films and strapping used to secure goods during transport from the 100% reuse obligation set out in Article 29(2) and 29(3) for intra-company and intra-group transport within the Union, as well as for transport between companies within the same Member State.

The Decision is based on the 15 December 25 Commission’s feasibility assessment and will enter into force on the 20^th day following its publication in the Official Journal of the European Union (OJEU), provided that neither the European Parliament nor the Council objects within the objection period ending by 25 April 2026.

Under the PPWR, economic operators using transport packaging or sales packaging used for transporting products, including pallet wrapping films and strapping, are in principle required to ensure the packaging is fully reusable within a reuse system.

The Commission’s feasibility assessment concluded that reuse systems for flexible load-securing materials are not yet sufficiently scalable or economically viable, and that mandating full reuse would require significant investments in still underdeveloped automated reuse solutions, imposing disproportionate costs and operational burdens for economic operators, with limited additional environmental benefit.

Despite this exemption, pallet wrapping films and strapping remain subject to the broader PPWR reuse framework, and economic operators must still comply with the overall target, ensuring at least 40% of transport and sales packaging is reusable by 1 January 30.