§12 Reusable packaging placed on the market prior to the application of the requirements in Article 11

Legal provisions: Article 11(1): ‘Packaging placed on the market from 11 February 2025 shall be considered to be reusable where it fulfils all of the following requirements: (a) it has been conceived, designed and placed on the market with the objective to be re-used multiple times; (b) it has been conceived and designed to accomplish as many rotations as possible under normally predictable conditions of use; (c) it fulfils applicable requirements regarding consumer health, safety and hygiene; (d) it can be emptied or unloaded without being damaged in a way that would prevent its further function and re-use; (e) it is capable of being emptied, unloaded, refilled or reloaded while maintaining the quality and safety of the packaged product and ensuring compliance with the applicable safety and hygiene requirements, including those on food safety; (f) it is capable of being reconditioned in accordance with Part B of Annex VI, while maintaining its ability to perform its intended function; (g) it allows for affixing of labels and the provision of information on the properties of that product and on the packaging itself, including any relevant instructions and information for ensuring safety, adequate use, traceability and shelf-life of the product; (h) it can be emptied, unloaded, refilled or reloaded without risk to the health and safety of those responsible for doing so; and (i) it fulfils the requirements specific to recyclable packaging set out in Article 6, so that it can be recycled when it becomes waste.’ Article 11(2): ‘By 12 February 2027, the Commission shall adopt a delegated act in accordance with Article 64 to supplement this Regulation by establishing a minimum number for the rotations for reusable packaging, for the purpose of paragraph 1, point (b), of this Article for the packaging formats which are most frequently used in re-use, taking into account hygiene and other requirements such as logistics.’ Article 15(9): ‘By way of derogation from paragraph 8 of this Article, the obligation to bring into conformity, withdraw or recall packaging which is believed not to be in conformity with the requirements laid down in or pursuant to Articles 5 to 12 shall not apply to reusable packaging placed on the market before 11 February 2025.’ Commission’s interpretations: Article 11 sets re-use criteria applicable from 11 February 2025, which is the date of entry into force of the Regulation. However, the Regulation applies from 12 August 2026. This means that reusable packaging already placed on the Union market before the date of entry into force of the Regulation (11 February 2025) does not need to be brought in compliance with these requirements retroactively. This is explicitly stated in Article 15(9) of the Regulation. Reusable packaging placed on the market after 11 February 2025 will have to comply with the Regulation. However, the competent authorities will be able to check the compliance of such packaging in accordance with Article 11 and other provisions of the Regulation only after 12 August 2026. The requirements set out in Article 11 are substantially like the requirements on reusable packaging contained in the previous PPWD and the related harmonised standard EN 13429:2004 (24) on packaging re-use. This means that the requirements on reusable packaging under the PPWR are not completely new.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07