PPWR Frequently Asked Questions: Packaging Components and Labelling Explained

This FAQ answers common questions about the EU Packaging and Packaging Waste Regulation (PPWR), including whether protective films are considered packaging, how labelling applies to multi-component packaging and what businesses should expect from the upcoming EU-wide labelling requirements. At Artem, we help companies understand evolving packaging compliance obligations and prepare for future regulatory changes.
The PPWR introduces harmonised rules for packaging across the European Union, covering packaging design, recyclability, labelling and producer responsibilities. While the PPWR establishes a comprehensive legal framework, many businesses still have practical questions about how it applies to everyday packaging scenarios.

This FAQ answers some common implementation questions based on the current text of the PPWR. As the European Commission continues developing implementing acts companies should continue monitoring regulatory updates to ensure compliance.

Official resources

• European Commission - Packaging and Packaging Waste Regulation
• European Commission - Packaging Waste
• Official PPWR legal text (EUR-Lex)

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Are protective films on parts of a product (e.g. on the seat of a car) considered packaging?

Short answer: Yes.

In most cases, protective films applied solely to protect a product during handling and transport are considered transport packaging under the PPWR.

The PPWR defines packaging as:

…an item, irrespective of the materials from which it is made, that is intended to be used by an economic operator for the containment, protection, handling, delivery or presentation of products to another economic operator or to an end user…

The Regulation further defines transport packaging as:

…packaging conceived so as to facilitate the handling and transport of one or more sales units or a grouping of sales units, in order to prevent damage to the product from handling and transport…

The official legal definitions can be found in the PPWR legal text (EUR-Lex).

Protective films or covers placed on vehicle seats during the transport of new cars are intended to protect the seats from scuffs, dirt, dust, UV exposure, moisture and other damage while the vehicles are moved from manufacturing facilities or warehouses to dealerships.

These protective films are not intended to remain with the product throughout its lifetime and are not an integral part of the vehicle itself. Instead, their sole purpose is to protect the product during handling and delivery.

Based on the PPWR definitions, protective films used on car seats would generally be considered packaging, and more specifically transport packaging.

Key takeaways

• The protective film protects the product during transport and handling.
• It is typically removed before the vehicle reaches the end user.
• Under the PPWR, it would generally qualify as transport packaging.

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If a product is made of several parts, does each part require a label?

Short answer: No.

A packaging unit may consist of multiple packaging components, but the PPWR does not require every individual component to carry its own separate label.

Packaging often consists of more than one component. The Recyclability Assessment, pursuant to CEN 13430, defines a component as a part of packaging that can be separated by hand or by using simple physical means.

The PPWR further distinguishes between different types of packaging components.

Integrated components

The PPWR defines an integrated component as:

“a packaging component… that is integral to the packaging unit and its functioning, that does not need to be separated from the main body of the packaging unit… and that is typically discarded at the same time as the main body of the packaging unit…”

Separate components

A separate component is defined as:

a packaging component… that needs to be disassembled completely and permanently from the main body of the packaging unit and that is typically discarded prior to and separately from the main body of the packaging unit…

Unit of packaging

The Regulation also defines a unit of packaging as:

a unit, including any integrated or separate components, which as a whole serves a packaging function…

These definitions make clear that multiple components can together constitute a single packaging unit.

Article 12 of the PPWR further states that:

Economic operators may place a QR code or other type of standardised, open, digital data carrier on the packaging that contains information on the destination of each separate component of the packaging in order to facilitate consumer sorting.

This provision indicates that information relating to the packaging unit and all of its components may be communicated through a single label or digital data carrier. The Regulation therefore does not require every individual packaging component to carry its own separate label.

The complete legal wording is available in the official PPWR legal text (EUR-Lex).

Key takeaways

• A packaging unit may consist of multiple components.
• Components may be integrated or separate.
• One packaging label may provide information for multiple components.
• QR codes or other approved digital data carriers may be used to communicate sorting information.
• Individual labels on every packaging component are generally not required.

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How extensive are the labelling obligations for packaging?

The PPWR establishes the overall framework for packaging labelling, but many of the detailed labelling requirements are still being developed by the European Commission.

The Regulation requires harmonised labelling throughout the European Union to improve consumer sorting and recycling. However, the precise appearance of the pictograms, symbols and other labelling conventions has not yet been finalised.

By 12 August 2026, the European Commission is required to adopt implementing acts specifying the harmonised labelling system. From the date these implementing acts enter into force, businesses will generally have 24 months to transition to the new EU-wide labelling requirements.

The European Commission provides updates on the implementation of the PPWR here.

Current PPWR labelling obligations include:

Requirement	Description
Material composition	Packaging must display a harmonised label identifying its material composition to facilitate consumer sorting.
Sorting instructions	Labels will be based on harmonised pictograms designed to be easily understood by consumers across the EU.
Substances of concern	Packaging containing substances of concern must be identified using standardised, open digital marking technologies.
Deposit & return systems	Packaging participating in deposit and return schemes must carry a clear and unambiguous identifier.
Manufacturer information	Manufacturers must provide a type, batch or serial number (or equivalent identifier) together with their name, registered trade name or trademark, and postal address. Where appropriate, this information may be provided through a QR code or another approved digital data carrier.

Although the broad obligations are already established, businesses should expect additional technical guidance from the European Commission before implementation begins.

For more information on EU packaging and packaging waste policy, see: Official PPWR legal text (EUR-Lex)

Key takeaways

• Detailed labelling requirements are still being finalised.
• Harmonised EU-wide pictograms will be introduced.
• Businesses will generally have 24 months to comply after the implementing acts are adopted.
• QR codes and digital data carriers will play an important role in communicating packaging information.
• Manufacturers should begin reviewing their packaging and data management processes ahead of implementation.

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When do the PPWR recyclability requirements apply?

The general requirement that all packaging placed on the market must be recyclable applies from 12 August 2026. However, the detailed design for recycling and recycled-at-scale requirements will apply later, following the adoption of delegated and implementing acts by the European Commission.

Article 6(1) of the PPWR states that:

All packaging placed on the market shall be recyclable.

Unlike some other provisions of the Regulation, Article 6(1) does not specify a later application date. According to the European Commission’s interpretation, this means the general recyclability requirement applies from 12 August 2026, when the relevant provisions of the PPWR become applicable.

However, Article 6(2) explains what constitutes “recyclable” packaging by introducing two separate conditions that apply on different timelines.

Design for recycling requirements

Article 6(2)(a) requires packaging to be designed for material recycling, enabling the resulting secondary raw materials to substitute primary raw materials where appropriate.

These requirements will apply from:

• 1 January 2030, or
• 24 months after the delegated act adopted under Article 6(4) enters into force, whichever is later.

The European Commission is expected to adopt this delegated act by 1 January 2028. It will establish harmonised EU-wide design-for-recycling criteria and the methodology for assessing compliance.

Once the delegated act enters into force, manufacturers will generally have 24 months to ensure their packaging complies with the new design-for-recycling requirements.

Recycled-at-scale requirements

Article 6(2)(b) requires packaging to be capable of being:

• separately collected,
• sorted into appropriate waste streams without affecting other recyclable materials, and
• recycled at scale.

These requirements apply from:

• 1 January 2035, or
• for the recycled-at-scale criterion, five years after the relevant implementing acts enter into force, whichever is later.

This phased implementation recognises that collection, sorting and recycling infrastructure must continue to develop before uniform EU requirements can be fully enforced.

What should manufacturers do before the new rules apply?

Until the detailed design-for-recycling requirements become applicable, manufacturers should continue complying with the existing requirements under the Packaging and Packaging Waste Directive (94/62/EC) and the relevant harmonised standards, including EN 13430:2004 – Requirements for packaging recoverable by material recycling.

The European Commission has clarified that manufacturers do not need to perform the conformity assessment procedure in accordance with Article 38 and Annex VII of the PPWR for recyclability until the entry into force of the delegated act(s) under Article 6(4) PPWR.

Timeline

Date	Requirement
12 August 2026	General requirement that all packaging placed on the market must be recyclable applies.
By 1 January 2028	European Commission expected to adopt delegated act establishing harmonised design-for-recycling requirements.
1 January 2030 (or 24 months after delegated act enters into force)	Design-for-recycling requirements under Article 6(2)(a) become applicable.
1 January 2035 (or later where applicable)	Collection, sorting and recycled-at-scale requirements under Article 6(2)(b) become applicable.

For further guidance from the EU Commission, see the official guidance document here.

Key takeaways

• The general requirement for packaging to be recyclable applies from 12 August 2026.
• Harmonised design-for-recycling requirements will not apply until 2030 at the earliest, or later depending on when the Commission adopts the delegated act.
• Recycled-at-scale requirements will apply from 2035 at the earliest.
• Until the new harmonised criteria apply, manufacturers should continue following the existing Packaging and Packaging Waste Directive and relevant harmonised standards such as EN 13430:2004.

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How ArtemLEX helps businesses comply with the PPWR

The Packaging and Packaging Waste Regulation introduces new obligations for manufacturers, importers, distributors and other economic operators across the packaging value chain. As delegated acts and implementing rules continue to be published, keeping track of changing requirements can become increasingly complex.

ArtemLEX helps businesses understand and manage their PPWR obligations by providing practical regulatory intelligence and compliance support in one platform.

More specifically, the PPWR Compliance Studio clearly and simply sets out the requirements of the PPWR, while ensuring all requirements are covered. Review requirements through a simplified compliance flow, confirm compliance and prepare compliance documentation with confidence.

Learn more about how ArtemLEX can support your PPWR compliance programme by contacting the Artem team or requesting a demonstration of the platform.