The European Commission has published a guidance document providing further clarity around the requirements of the Packaging and Packaging Waste Regulation, including exempted packaging formats, compostable packaging guidelines, rules around empty space and minimization, and much more.
The guidance document clarifies that, as per Article 6(1), all packaging placed on the EU market must be recyclable by 12th August 2026. In line with Article 6(2), the Commission must adopt a delegated act to fully harmonize design-for-recycling requirements and the relevant assessment methodology by 1st January 2028. Manufacturers will have 24 months to comply.
It goes on to confirm that contact-sensitive packaging and plastic parts representing less than 5% of a pack’s total weight are exempt from recycled content requirements, as per Article 7(5). Further exemptions will be assessed, and existing measures revisited, from 1st January 2028.
Regarding Article 29(6)’s reuse targets for beverages in the HORECA sector, drinks sold in beer kegs and other large reusable containers will not contribute, as they are not available to consumers. On the other hand, smaller sales packaging like reusable bottles will be considered.
The reusability of sales packaging depends on the product it is carrying, the document continues. Containers carrying pesticides, paints, plasters or adhesives could be impossible, expensive, or inefficient to reuse, with the guidance asserting that only sales packaging with an evident transport function is covered by the reuse targets.
Transport packaging imported from third countries will be subject to the Regulation’s reuse targets from the moment of import, with all required import procedures typically taking place in the first EU warehouse the packaging reaches. The targets will apply to the products after they are placed on the EU market.
The user of transport packaging, or the user of sales packaging used for transport, will be responsible for its reuse targets. This may be a manufacturer, importer or distributor.
Deposit return schemes must be fully operational by 1st January 2029, unless a Member State has requested an exemption by 1st January 2028. This will require the Member State to separately collect 80% of its single-use plastic bottles and metal containers made available in 2026, which must be reported to the Commission by 1st July 2028 at the latest.
The exemption will no longer apply if the Member State does not separately collect 90% of its single-use beverage packaging for three consecutive years. It will then be required to establish a deposit return scheme by the second subsequent calendar year.
By 1st January 2029, Member States are expected to ensure that their deposit return schemes for single-use plastic and metal beverage containers meet the minimum requirements listed in Annex X of the Regulation. These will not apply to schemes established before the entry into force of PPWR, and which achieve the 90% separate collection targets set out in Article 50(1) by 1st January 2029.
However, Member States should review their deposit return schemes before 1st January 2029. If the separate collection rate of 90% is not likely to be achieved, existing single-use DRS must comply with the minimum requirements in Annex X by 1st January 2035 at the latest.
Until 12th August 2026, Member States are permitted to decide whether the packaging formats listed in Article 9(1) and Article 9(2)(a) should be compostable. They are allowed to mandate that certain packaging formats are home compostable, depending on the local infrastructure; this may be done before the adoption of, or even in the absence of, a set of harmonized standards.
In any case, specific lists should be compiled and distributed among economic operators, the general public, and the Commission itself. Furthermore, the Commission has requested that European standardization bodies create EU-wide standards for home compostables with a deadline of 12th February 2026.
Notably, packaging exempted from design for recycling criteria in Article 48(1) – including lightweight wood, cork, textile, rubber, ceramic, porcelain and wax, alongside medical devices and transport packaging for dangerous goods – is also considered exempt from the ban on incineration and landfilling. Any packaging that is designed for recycling may not be incinerated or landfilled.
To clarify the Regulation’s packaging minimization requirements, the Commission must request that CEN update existing standards with a new methodology assessment, plus the maximum adequate weight and volume for common packaging types, by 12th February 2027. These will be effective from 1st January 2030, until which point the existing standards will remain effective.
The document explains that Article 24’s empty space ratio applies to grouped, transport, and e-commerce packaging, and that the natural or legal person using or filling such packaging must comply. The Commission will establish a methodology for calculating the empty space ratio in an implementing act, which will be adopted before 12 February 2028.
Empty space requirements for sales packaging are not linked to any predefined threshold, the Commission explains. Therefore, manufacturers must assess these requirements based on the existing EN 13428:2004 standard, which applies until 1 January 2030. This will be updated in line with the updated performance criteria provided for in Part A of Annex IV and the requirements set out in Article 10.
Reusable packaging placed on the market prior to the application of Article 11’s requirements on 12th August 2025 does not need to be brought into compliance retroactively. Any such packaging placed on the EU market after that date must be compliant, but the competent authorities will only be able to check its compliance after 12 August 2026.
The scope of harmonized packaging labelling under Article 12(1) is considered in relation to deposit return schemes. The document concludes that Member States will not be allowed to keep their national labels next to EU harmonised labels after 12 August 2028, or 24 months from the date of entry into force of the implementing act specifying the labelling rules and pictograms.
The Commission Decision 97/129 of 28th January 1997, which sets out an identification system for packaging materials based on numbering and abbreviations to help waste managers identify the material composition of a pack, will continue to apply until 18th August 2028, but will no longer be permitted after that point. This is set to harmonize labelling across the Single Market and account for technological advances in waste separation, and the resultant lack of necessity for such markings.
Article 12(1)’s labelling requirements to improve the sorting of packaging waste by consumers will not apply to human or veterinary medicinal products, medical devices or in vitro diagnostic medical devices – i.e. products only intended for use by specialists, not consumers at large.
To ensure the derogation is correctly applied for those products, the document advises that ‘immediate packaging’ refers to any packaging that touches the device directly, while the outer packaging refers to the device’s sales packaging.
All transport packaging, except for e-commerce packaging, and packaging that is subject to a deposit and return system will also be exempt from these labelling requirements.
Labelling for reusable packaging under Article 12(2) may not display Member States’ national labels beside harmonized EU labels after 12th February 2029, or 30 months from the date of entry into force of the implementing act specifying the related labelling rules.
Labels for recycled content and bio-based content under Article 12(4) will be fully harmonized from 12 August 2028, or 24 months after the entry into force of the related implementing act. However, the use of these labels is voluntary.
Member States may also require that labels covered by mandatory deposit return systems, as per Article 50(1), may be marked with a harmonized colour label; they are not required to use the EU-harmonized deposit return label, but they may not prevent the affixing of DRS labels on their market packaged products carrying DRS labels affixed in other Member States.
Reusable packaging placed on the market after 11 February 2025, but before the date of application of the implementing act on labelling for reusable packaging (currently scheduled for 12 February 2029), must comply with the labelling requirements at the latest by February 2032.
The Commission also plans to review the Single-Use Plastics Directive in 2027, including its coherence and consistency with the Packaging and Packaging Waste Regulation.
Reacting to the document, Europen comments: “The long-awaited Guidance Notice from the European Commission still falls short of providing the legal certainty and operational clarity businesses urgently require. As a result, investment decisions remain on hold, compliance planning is constrained, and supply chains across the Single Market face growing disruptions.
“Without clear, harmonized, and implementable rules, companies cannot be expected to comply effectively. The risks are no longer theoretical: this uncertainty is already eroding Europe’s industrial competitiveness at a time when investment and innovation should be accelerating.
“The packaging value chain remains fully committed to delivering on the PPWR’s ambitions. But commitment cannot replace clarity. Industry must be put in a position to act, which requires practical, coherent legal guidance and critical secondary legislation delivered in time for implementation.
“The European Council’s focus on better regulation and industrial competitiveness must now translate into concrete progress. We call on a swift, high-level dialogue between institutions and packaging industry leaders to close critical implementation gaps. If the remaining time is not used to deliver clear guidance and close critical implementation gaps, there is a real risk that the PPWR obligations will be challenging on their practical feasibility and hampering the industry’s competitiveness and growth.”
This report does not constitute legal advice or official regulatory guidance. Click here to read the full guidance document.
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