Decide whether an item falls under Regulation (EU) 2025/40, then classify the packaging format before assigning PPWR work.
This guide focuses on Article 2 scope, Article 3 definitions, and the evidence a team should keep for borderline packaging decisions.
Structured answer sets in this page tree.
Cited legal and guidance references.
PPWR scope analysis starts with the item and its function. Article 2 applies the Regulation to all packaging, regardless of material, and to all packaging waste from industry, manufacturing, retail or distribution, offices, services, or households. Article 3 then defines what counts as packaging and separates the main packaging formats that route later work on recyclability, minimisation, labelling, reuse, extended producer responsibility (EPR), and documentation.
Article 2 is deliberately broad. If an item is under Article 3, PPWR scope does not turn on whether the material is paper, plastic, glass, metal, wood, textile, ceramic, composite, or another material. It also does not turn on whether the packaging waste originates from a household or a business setting.
Record the commercial flow and waste flow separately. A component may be placed on the Union market empty, supplied with a product, used in industrial distribution, delivered through services, or later become packaging waste; each fact can change the responsible actor or next PPWR workflow. Product-specific safety, quality, health, hygiene, medicinal-product, transport, and dangerous-goods rules continue to apply alongside PPWR.
Article 3 defines by function. The item must be intended for containment, protection, handling, delivery, or presentation of products to another economic operator or to an end user, and it can be differentiated by function, material, and design.
The definition also captures integrated components, ancillary elements attached to products, point-of-sale filling items, disposable point-of-sale items, and permeable tea, coffee, or other beverage bags and soft single-serve units that are intended to be used and disposed of together with the product. Non-permeable tea, coffee, or beverage-system units that are disposed of after use also fall within the stated criteria. Apply the exact Article 3 wording to the unit rather than treating every single-serve product as .
Once an item passes the -function test, classify the format. PPWR separates sales packaging, grouped packaging, transport packaging, e-commerce packaging, take-away packaging, service packaging, and primary production packaging because later obligations often attach to a format, activity, or operator role rather than to the product category alone.
Do not collapse all secondary or logistics material into a single internal label. A retail multipack, a shelf-restocking unit, a pallet wrap, a parcel shipper, and a take-away cup may all support the same product line but require different PPWR evidence and follow-up checks.
Annex I gives an indicative list of items that are or are not in scope of the definition. It is useful for edge cases, but it does not supersede the Article 3 function test. The same apparent item can change classification when the intended use changes.
The Commission's June 2026 guidance applies that test to borderline items. An empty beverage cup sold to a consumer for private use is not , while the same type of cup filled with coffee at a refill station is service packaging. A process film that only enables manufacturing and remains on an intermediate product until later transformation is not packaging. A dust bag supplied with shoes or garments can be packaging when it contains or protects the product during supply, but not when it is integral to the product or supplied outside a commercial packaging use.
For plant pots and seed trays, classify the actual function rather than repeating Annex I in isolation. Pots used only during a grower's production cycle are not ; a pot used for the final cultivation stage and supplied with the plant to the end user can be packaging because it also performs the sale and transport function. The Commission also treats pre-filled intravenous bags and syringes as delivery devices integral to the medicinal or medical product, not packaging.
A defensible scope record should show the item, the intended use, the Article 3 function, the format, the Union-market or Member State flow, and the source quote used for the decision. It should also identify the next workflow: product conformity, technical documentation, minimisation, recyclability, labelling, reuse, format restriction, EPR registration, or packaging-waste reporting.
The common error is to publish a broad answer such as out of scope, , transport pack, or service pack without preserving the facts that made the answer true. Narrow the public copy when the source only supports a narrow claim.
This PPWR guide helps classify packaging units, capture cited scope evidence, and route follow-up work before product, supplier, or public guidance changes.
"Packaging & Packaging Waste Regulation"
"An indicative list of items falling within the definition of packaging"