The European Commission has clarified how stocks of packaging are to be treated when the Packaging and Packaging Waste Regulation (PPWR) enters into application on 12 August 2026. Packaging that is already with a retailer at this point in time is consequently deemed to have been placed on the market. The PPWR does not provide for a sell-off period.
The clarification was made in a written answer from the European Commission of 21 August 2026 in response to an enquiry by MEP Angelika Niebler (EPP). The background was uncertainty, particularly among small and medium-sized enterprises, regarding how to handle packaging that had been produced or supplied to retailers before the PPWR began to apply.
According to the Commission, packaging is placed on the EU market when it is first made available on the market by a manufacturer or importer. If a manufacturer or importer sells packaging or a packaged product to a distributor, this transaction is already considered as placing on the market. Therefore, if packaging is in a distributor's warehouse, it has already been placed on the market.
No clearance sale period for stock inventories
According to the Commission, only packaging that has not yet been placed on the market by 12 August 2026 must comply with the PPWR requirements applicable from that date. The new requirements will therefore not apply retroactively to stock that has already been supplied to a wholesaler or retailer beforehand.
According to the Commission, the PPWR does not contain a time limit for the sale of corresponding stock. Packaging already placed on the market before the start of application can therefore continue to be sold even after 12 August 2026.
Accompanying document may contain labelling information
The Commission also comments on packaging that was already produced before the deadline but has not yet been placed on the market. This packaging also does not need to be destroyed, remanufactured or relabelled. For the labelling requirements applicable as from the date of application, the required unique identification and the name and address of the manufacturer can be provided via an accompanying document.
The Commission does not state in its opinion which specific documents are sufficient as proof of existing stock for market surveillance authorities. However, the clarifications are to be included in an updated version of the FAQ on the PPWR, the publication of which has been announced.
Source: EU Commission
