Two weeks before the general date of application of the Packaging and Packaging Waste Regulation (PPWR) on 12 August 2026, the European Commission’s Directorate-General for Environment (DG ENV) published the second edition of its PPWR FAQ document. It replaces the first version from March 2026 and adds more than thirty new or revised answers across various chapters. Conveniently, all changes in the document are marked “NEW” or “UPDATED” — so those familiar with the first edition can jump directly to the relevant sections.
The FAQ document is not a legal act and is therefore not binding. It supplements the Commission Notice containing the actual guidance and addresses practical implementation questions submitted to DG ENV since the Regulation was adopted. The FAQs provide important interpretative guidance — and several of the new answers close precisely the gaps where our clients have encountered difficulties in recent months.
Below, I highlight five points that are particularly relevant for importing companies.
1. Existing stock: no destruction, no relabelling
One of the most pressing practical questions shortly before the application date was what happens to packaging stock that has already been produced. The Commission’s answer: packaging produced before 12 August 2026 that is still in stock does not have to be destroyed, modified or relabelled.
The labelling requirements under Article 15(5) and 15(6) — unique identification as well as the manufacturer’s name and address — can be fulfilled for such stock through an accompanying document. For packaging manufactured after 12 August, however, an accompanying document is no longer the standard route and is only permitted where affixing the information directly to the packaging itself is not possible.
And: packaging that was already placed on the market before the date of application may remain on the market — even if it does not comply with the PPWR requirements.
2. Importers: the verification obligation has become concrete
Article 18 has received a new dedicated answer. From 12 August, anyone importing packaging or packaged goods from a third country must ensure that:
- the manufacturer outside the EU has carried out the conformity assessment procedure under Article 38 and drawn up the declaration of conformity,
- the requirements of Article 15(5) and 15(6) are met, and
- the required documents accompany the packaging.
The additional clarification regarding generic, unprinted imported goods is particularly noteworthy — paper sheets, for example. The fact that there is no information on the packaging does not remove the obligation to provide evidence. Anyone placing such goods on the market must ensure that the relevant documentation and information are available. The Commission expressly identifies contractual arrangements with suppliers in third countries as one way of doing this and, for generic imported packaging, the shipping document as the carrier of the information required under Article 18(2)(d).
Anyone who has so far assumed that this could simply be dealt with as part of the existing procurement process should read this passage twice.
3. Who is the “manufacturer” of transport packaging?
Here, the Commission has included several new answers — and they dispel a common misconception.
The manufacturer is determined at the stage at which the empty packaging reaches its final form. “Final” means that it can be used as transport packaging without any further components being added. A folding carton delivered flat is therefore considered to be in its final form, even if it still needs to be folded.
This leads to a conclusion that may surprise many: a single shipment can contain packaging from several manufacturers — cardboard, adhesive tape, stretch film, pallet — and each of these manufacturers must retain the technical documentation supporting their declaration of conformity. The fact that several packaging materials are used together does not make the user the manufacturer.
If the packaging does not bear a name or brand, the key question is who commissioned it and who defined the design specifications. For standardised, unbranded goods, this is generally the physical producer. A shipping label does not expressly qualify as branding.
The situation is reversed for customised products: anyone ordering customised transport packaging without a brand is themselves the manufacturer within the meaning of the PPWR — because the specification is determined by the customer and the decision-making power therefore lies with the purchaser.
4. Traceability: no mandatory marking of every individual item
Article 15(5) has caused considerable uncertainty — does every individual packaging unit have to be marked for traceability purposes? No. The purpose of the provision is to enable the packaging to be assigned to a type, model or production batch so that market surveillance authorities can link it to the technical documentation and declaration of conformity.
Not every component has to be marked: for a yoghurt cup consisting of a cup, lid and sleeve, an indication on one component is sufficient. And for standardised purchased items such as adhesive tapes, generic bags or desiccant bags, batch-level traceability is the normal approach.
5. Suppliers cannot refuse to provide the documentation
One sentence has significant practical implications: under Article 16(1), suppliers must provide manufacturers with all information and documentation they need to demonstrate conformity — and the Commission makes clear in its updated answer that suppliers cannot refuse to provide it.
Responsibility for demonstrating conformity remains with the manufacturer. The manufacturer may engage external service providers for this purpose, but the required information and documentation must be available and incorporated into the technical documentation.
Two further clarifications should also put an end to certain debates: envelopes containing invoices, bank statements or other correspondence are not packaging because correspondence is not a product within the meaning of the definition. Envelopes containing a catalogue or magazine, however, are packaging. And goods that merely transit through the EU and are not released for free circulation under customs law are not subject to the PPWR.
What this means operationally
The second edition of the FAQ makes one thing particularly clear: in practice, PPWR compliance depends not only on the packaging itself, but also on whether responsibilities, supporting documentation and supplier information are properly organised. If supplier information is not systematically available, a manufacturer cannot prepare a robust declaration of conformity — even if the packaging meets the PPWR’s substantive requirements.
For importers, this means three things:
- Engage with suppliers now, not after the first request from an authority. The right to obtain the documentation is legally established — it simply needs to be exercised.
- Capture packaging data where it can be reused. Most companies have significantly fewer packaging variants than products. Recording data by supply chain rather than by individual product can save a substantial amount of work.
- Plan for retention periods. Five years for single-use packaging and ten years for reusable packaging — for documents that may still be sitting in email attachments today.
That is exactly why we built the PPWR module in supplycanvas: to structure packaging attributes, attach supplier documentation to them, and generate declarations of conformity from the collected data. Collect the information once, use it multiple times.
Source: European Commission, DG Environment, “Packaging and Packaging Waste Regulation (PPWR) — Frequently Asked Questions”, 2nd edition, August 2026.