On 30 March 2026, the European Commission published a guidance document and an accompanying set of Frequently Asked Questions (FAQs) on the implementation of the Packaging and Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40). These documents aim to facilitate the uniform application of the new packaging rules across the EU and to simplify compliance for economic operators and Member States.
Background
The PPWR entered into force on 11 February 2025 and will generally apply from 12 August 2026, although certain provisions have later application dates. The Regulation replaces the former Packaging and Packaging Waste Directive (94/62/EC) and introduces harmonised requirements covering the full lifecycle of packaging, with the objective of reducing the environmental impact of packaging waste and strengthening the Single Market through harmonized rules.
Purpose of the guidance
The Commission’s guidance document clarifies a number of provisions where the PPWR requires further clarification and where stakeholders have requested assistance. Among other topics, it addresses:
- Definitions of key terms, including the distinct roles of manufacturer (responsible for EU-wide PPWR sustainability requirements) and producer (responsible for EPR obligations market by market),
- Scope of what constitutes packaging, including the primacy of the functional test over Annex I listing (e.g., products in their own right like cups and bags do not constitute “packaging”)
- Enforcement of the PFAS restriction in food-contact packaging via a three-step testing protocol, and the absence of a transitional period during which non-compliant packaging could be placed on the market until stock exhaustion,
- Application of re-use targets to different types of packaging and actors, including HORECA beverage obligations, custom-designed transport packaging, and transport packaging of imported goods,
- Flexibilities and exemptions from targets and mandates, including Member State derogations from re-use targets and recycled content exemptions for contact-sensitive packaging.
The accompanying FAQ document responds to a wide range of practical questions raised by stakeholders since the adoption of the PPWR. The EU Commission has indicated that the FAQ will be updated regularly.
It is important to note that, while providing more clarity on key provisions, neither the guidance document nor the FAQs replace, add to, or amend the provisions of the PPWR. The binding interpretation of EU legislation remains the exclusive competence of the Court of Justice of the European Union.
Next steps
The Commission guidance document will be translated into all EU official languages before being formally adopted. In the meanwhile, several delegated and implementing acts are also being prepared, covering topics such as harmonised registration and reporting formats for EPR, labelling for waste sorting, recycled content in plastic packaging and recyclability criteria.
How can PwC support?
The PPWR introduces wide-ranging obligations for economic operators across virtually every sector and value chain — from packaging design and labelling to recyclability, reuse targets, EPR and deposit-return systems. Companies that act early can turn regulatory pressure into a competitive edge, while those that delay face rising costs, margin erosion, and operational complexity across markets.
At PwC, we support companies in building a structured PPWR readiness strategy, including:
- Regulatory impact assessment: analysing how the PPWR affects your product portfolio and packaging formats, identifying applicable obligations across markets, and determining where your company qualifies as the legal producer under EPR rules.
- Compliance and operating model design: defining the most appropriate compliance approach for sustainability, labelling, recyclability and EPR requirements, and establishing clear ownership and cross-functional governance.
- Packaging data management and reporting: mapping packaging flows across supply chains, establishing structured data collection, and integrating packaging data into ERP and reporting systems to meet both EPR reporting obligations and broader PPWR needs.
A well-structured strategy not only ensures compliance but also supports operational excellence, cost reduction, stronger sustainability positioning, and full supply chain transparency.
For further insights on the PPWR or any assistance in this matter, please contact Tom Wallyn, Helena Caluwe, Lorenzo Costa or your regular PwC contact.
