New PPWR FAQs provide clarity on enforcement and labelling guidance

On 31 July, the European Commission uploaded a new version of the Packaging and Packaging Waste Regulation (PPWR) Frequently Asked Questions (FAQs) document.

Several new questions were included, providing greater clarity on responsibilities and timeframes. 

Enforcement 

A new section was included on enforcement (XVI on page 56).

It was confirmed that products will not be banned from the EU market if its packaging is non-compliant with the rules that apply as of 12 August 2026. It was clarified that in line with Article 62 of the PPWR, if a Member State becomes aware of any instance on non-compliance, it must first require the relevant economic operator to put an end to that non-compliance. Essentially, the economic operator would receive a warning and an opportunity to take corrective action before any other action is taken by the Member State. This will be a welcomed confirmation for industry.

The Commission and Member States have yet to publish the timelines for corrective action, but we will continue to share additional detail and clarity when this becomes available.

Article 15 

Also included was greater clarification on 12 August 2026 labelling requirements under Article 15. This includes the requirement of unique identifiers and contact details of the manufacturer to be included on-pack. If the size or nature of the packaging does not allow for this to be included on-pack, the information can be provided in a document accompanying the packaging. 

Guidance also indicates that the Article 15 (5) labelling requirement is not necessary on every single component of a packaging unit to be individually marked for traceability purposes. It will be sufficient if the required information is displayed on only one component of the sales packaging.

Read the full FAQs here. Look for NEW! And UPDATED! within the text to see what’s changed between this version of the document and the March publication.

How we can help

We are here to help you navigate the continually evolving PPWR regulatory landscape.

Ecosurety members can access our PPWR guidance articles to help you understand the timeline of implementation, how to register and report, and the areas of evolving legislation that will impact your business.

Not an Ecosurety member? Please contact our team to discuss your PPWR needs.