COMMISSION NOTICE Guidance document for Regulation (EU) 2025/40 on packaging and… · Lexiara

COMMISSION NOTICE Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste

guidance · European Union · 52026XC03084

354 provisions in 531 nodes

Defined terms · All instruments · EU law · European standard · TRIPS · VAT · branch · carbon · consumer · consumer

COMMISSION NOTICE

Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste

Subject matter and scope of this Commission guidance document

1. Definition of packaging

Legal provisions:

Commission’s interpretation:

2. Definition of a manufacturer of packaging

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Commission’s interpretation:

3. Definition of a producer of packaging

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Commission’s interpretation:

Overview of the different roles of manufacturers and producers in the PPWR

4. Definition of importer and the status of a ‘branch’

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Commission’s interpretation:

5. Enforcement of PFAS restrictions in food contact packaging and exhaustion of stocks

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Commission’s interpretation:

6. Date of application of the requirement to ensure that packaging is recyclable

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Commission’s interpretation:

7. Exemptions from recycled content targets

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Commission’s interpretation:

8. Flexibility for Member States to mandate compostable packaging and presumption of conformity

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Commission’s interpretation:

9. Definition of the terms ‘permeable’ and ‘soft after-use’ in the context of compostable packaging

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Commission’s interpretation:

10. Packaging minimisation

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Commission’s interpretation:

11. Relationship between the minimisation requirements in Article 10 and the empty space ratio in Article 24

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Commission’s interpretation:

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

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Commission’s interpretations:

13. Scope of harmonised packaging labelling

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Commission’s interpretation:

14. Labelling of existing reusable transport packaging

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Commission’s interpretation:

15. Reporting obligations for waste management operators

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Commission’s interpretation:

16. Relationship between the Single-Use Plastics Directive (SUPD) and PPWR as regards packaging bans

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Commission’s interpretation:

17. Scope of the packaging bans in Article 25 and Annex V, points 1–4, as regards plastic content

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Commission’s interpretation:

18. Re-use targets for sales packaging used for transporting products

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Commission’s interpretation

19. Re-use targets for transport packaging in international trade

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Commission’s interpretation:

20. Responsible economic operator for the re-use targets on transport packaging

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Commission’s interpretation:

21. Exemptions of the custom-designed transport packaging from the re-use targets

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Commission’s interpretation:

22. Definition of ‘making available’ in the context of compliance with the re-use targets for beverages

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Commission interpretation:

23. Re-use targets for beverages in the HORECA sector

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Commission’s interpretation:

24. National exemptions from the re-use targets

Legal provisions:

Commission’s interpretation:

a) The possibility for a Member State to exceed all material specific recycling targets

b) Conditions regarding the exemption applying to composite packaging

c) Conditions related to waste prevention target

d) Conditions for renewal of the exemption:

25. Member States’ flexibilities to set up national measures

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Commission’s interpretation:

26. Flexibility for Member States to set additional recycling targets

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Commission’s interpretation:

27. Flexibility for Member States to set additional or higher re-use targets

Article 51 on re-use and refill states:

Commission’s interpretation:

28. National exemptions from Deposit and Return Systems (DRS)

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Commission’s interpretation:

29. Minimum requirements for existing Deposit and Return Systems (DRS)

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Commission’s interpretation:

30. Acceptance by retailers of deposit-bearing beverage container

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Commission’s interpretation:

31. End of life treatment of separately collected packaging which is designed for recycling

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Commission’s interpretation:

32. Separate collection rate of deposit-bearing packaging in 2026 and obligation to set up a DRS by 2029

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Commission’s interpretation:

33. Member States’ 90 % collection target for single-use plastic beverage bottles and metal beverage cans and the contribution of regional deposit return schemes

Legal provisions:

Commission’s interpretation: