PPWR – What counts as packaging?

PPWR: assess packaging in its intended use

Whether an item qualifies as packaging is determined by Article 3(1), point (1), of Regulation (EU) 2025/40. Relevant considerations include its intended use to contain, protect, handle, deliver or present products, together with the further conditions in the definition. A single characteristic such as storage, identification or use in production is not sufficient on its own to classify an item.

Examine load carriers, inserts and identification elements

In automotive logistics, load carriers and their components should be recorded according to their actual function and use. The regulation contains additional criteria for components, items attached to products and other specific cases. Annex I provides examples and distinctions. RFID tags, for instance, are expressly listed as items that are not packaging; identification systems therefore cannot all be classified as packaging.

Gather information for the assessment

Drawings, material composition, component supports, packing operations and transport routes help define the application. It is also useful to establish which elements remain with the recipient, are returned or are discarded. The requirements, deadlines and exceptions applicable to the particular packaging format, use and company role then need separate assessment.

A reusable design alone confirms neither compliance with every PPWR requirement nor an environmental advantage. Each such claim requires appropriate evidence for the specific packaging or the actual logistics process.

Legal references: Regulation (EU) 2025/40, particularly Article 3 and Annex I, and the European Commission guidance of June 2026.

Editorially updated in September 2026. The previous simplified list of functions has been replaced with an explanation based on the legal criteria.