The European Commission has published a second, updated version of its FAQ on the Packaging and Packaging Waste Regulation (PPWR), just days before the first operational PPWR obligations take effect on August 12, 2026. Changes are expressly marked as NEW or UPDATED, focusing on manufacturer status, packaging components, and Extended Producer Responsibility (EPR). Here is a summary of what has changed.
BP Consultants has compiled all NEW and UPDATED points into a compact, bilingual (DE/EN) overview: download it here.
1. Packaging, Manufacturer, and Producer: Sharper Distinctions
The phrase “whether empty or with a product” does not change the definition of packaging; it merely clarifies that both cases are covered. Sales, grouped, and transport packaging continue to be classified by function, not by material or appearance. For packaging units, integrated components (e.g., label, closure) are assessed together with the main body, whereas separate components (e.g., peel-off lids, crown caps, or pallets, shrink wrap, and edge protectors) require their own entries in the Declaration of Conformity.
Manufacturer status follows a test logic: the brand or name holder is generally the manufacturer; where there is no brand, the party that sets the design specification is decisive; for generic packaging, it is usually the physical manufacturer. For transport packaging, the manufacturer is determined once the empty packaging reaches its final usable form. Importers must ensure the conformity assessment and provide their own contact details; generic imports are not exempt, and mere EU transit does not count as placing on the market. Producer (EPR) status is determined separately for each Member State and may differ from manufacturer status; there is no industry-wide exemption.
BP Consultants assessment:
Manufacturer and producer are frequently confused. Capture the two roles separately for each packaging unit and Member State, since the same company can take on different roles depending on the distribution channel.
2. EPR Updates for Implementation
Micro-enterprises are not exempt across the board, but below 10 t/year per Member State they benefit from simplified reporting obligations. Reuse systems leave EPR with the producer but must support its implementation on a procedural level. Online platforms can pay fees by mandate, but registration remains with the producer, PRO, or authorized representative. Eligible single-use deposit-return systems (DRS) can register and report on behalf of participating producers.
BP Consultants assessment:
Helpful clarity for platform and reuse models, but the reporting burden remains with the producer. Clarify contractually who takes on which EPR task.
3. Further Updates and What Matters Now
Also sharpened: dangerous-goods exemptions, the removal of the presumption of conformity under EN 13428:2004 for substances of concern, recycled-content requirements for plastic parts, the <5% exemption for glass-bottle caps/labels, documentation obligations for suppliers, and simplified notifications to authorities.
Most time-critical: stock placed on the market before August 12, 2026 does not have to be destroyed or relabeled; packaging placed afterward needs identification and manufacturer information; traceability can usually be handled at the batch level rather than per individual item; and information provided under food law does not automatically satisfy PPWR labeling.
BP Consultants assessment:
Check now whether food-law labeling can serve as a substitute for PPWR identification, and close the gap before August 12.
Our assessment: next steps
- Capture every packaging unit (main body + components).
- Determine the manufacturer (brand / design authority / final form).
- Determine the EPR producer for each Member State and channel.
- Close documentation gaps (Declaration of Conformity, technical documentation, supplier/import data, traceability).
- Prepare for the obligations that apply from August 12, 2026, 2028, and 2030.
Recommended next step: build a responsibility matrix for each packaging.
Need to move fast? Our PPWR Late-Starter Package offers a practical entry point.
Source: European Commission, PPWR FAQ, August 2026 edition.
Questions about your PPWR roadmap?
Every packaging portfolio raises its own questions about manufacturer, producer, and EPR roles. If you need a second opinion on your role assessment, a gap analysis of your documentation, or concrete support before and after August 12, get in touch, and we are glad to address your specific situation.
Your contact
Jenny Walther-Thoß (walther-thoss@bp-consultants.de)
