Shortly before the start of the EU Packaging Regulation (PPWR) on 12 August, the European Commission published a revised version of its Frequently Asked Questions (FAQ). It is aimed at manufacturers, importers, distributors, authorities and other economic operators, and answers questions that have been put to the European Commission since the PPWR entered into force. The aim is to ensure a uniform interpretation of the regulation within the European Union and to facilitate the implementation of the new requirements.
A topic in the updated FAQs concerns the allocation of roles for dispatch packaging. The European Commission clarifies that in the case of neutral standard dispatch boxes, the party who determines the design specifications is deemed to be the producer. As a rule, this is the company that physically manufactures the packaging. For retailers, this means that simply unfolding a box does not make them producers. This clarification is particularly important as there was previously uncertainty in the sector.
Another important topic is the affixing of shipping labels. The FAQ emphasises that a standard shipping label is not considered branding. Retailers who merely attach a shipping label to a box do not thereby become the producer of the box. This statement by the European Commission brings clarity to a previously disputed issue and provides companies with greater certainty in their daily business operations.
Stretch wrap is considered packaging even while still on the roll
Stretch film is considered packaging as soon as it is placed on the market as a roll, even if it is only cut to the required length later and used to secure pallets. In the case of unprinted stretch film, the physical manufacturer of the film is fundamentally the manufacturer within the meaning of the PPWR and not the company that uses the film to secure its goods. Exceptions may occur if the film is printed with a company's name or brand or is manufactured according to specific requirements. In such cases, the specific criteria for determining the producer must be applied.
Stretch film generally belongs to transport packaging. Transport packaging serves to protect and handle goods during storage and transport, and thus differs from sales or group packaging. Several packaging elements (e.g. pallet, cardboard box, adhesive tape and stretch film) each remain separate packaging items. The fact that they are used together does not make them a single packaging product.
Recyclability and substances of concern
A central element of the regulation is the recyclability of packaging. The FAQs explain the concept of the packaging unit and distinguish between integrated and separate packaging components. For the assessment of recyclability, the entire packaging including its components will be considered in future. Non-recyclable components can worsen the classification of the entire packaging. In principle, all packaging must be recyclable from 2030 onwards. Only a few materials or areas of application are exempt from this obligation.
A significant amount of space is taken up by the chapter on so-called „Substances of Concern“ (SoC). The PPWR obliges manufacturers to minimise the presence and concentration of substances of concern in packaging as far as possible. The definition is aligned with the Ecodesign Regulation (ESPR) and includes substances with hazardous properties or substances that can hinder recycling. The FAQs explain that there is no exhaustive list of substances for this and that the European Commission, together with the European Chemicals Agency (ECHA), is carrying out relevant investigations.
Source: EU Commission
