PPWR – What is Considered Packaging?

The new EU Packaging and Packaging Waste Regulation (PPWR) not only introduces stricter recycling requirements but also redefines the term “packaging” more precisely. This is crucial because only items that fall under the legal definition of packaging are subject to the new PPWR regulations.

In the automotive industry, where packaging is not only used for protection but also for storage, logistics, and labeling, companies must carefully assess which of their packaging solutions are affected by the regulation.

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How Does PPWR Define Packaging?

According to Article 3 of the PPWR, packaging is any item, regardless of material, that serves at least one of the following functions:

✅ Product protection – Shields a product from damage or environmental influences.
✅ Transport/loading function – Enables safe and efficient transportation.
✅ Storage/handling function – Facilitates storage or handling of a product.
✅ Labeling/information function – Provides essential product information.
✅ Process function – Plays a role in production processes.
✅ Sales function – Supports product marketing.
✅ Hygiene/safety function – Ensures hygienic storage or safety.

If an item does not fulfill any of these functions, it is not classified as packaging and does not fall under the PPWR requirements.

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What Does This Mean for the Automotive Industry?

Automotive logistics rely on a variety of packaging solutions, including:

✅ Transport and load carriers for components and parts
✅ Protective packaging for sensitive parts
✅ Labeling and tagging systems for product identification
✅ Reusable packaging for closed-loop supply chains
✅ Single-use packaging for international or complex supply routes

Companies must now carefully assess which of their packaging solutions fall under the new definition, as they will be subject to strict recyclability, material use, and documentation requirements.

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Challenges for OEMs and Suppliers

✅ Assess existing packaging
Companies should review the materials used in their packaging and determine whether they comply with the new requirements.

✅ Ensure recyclability
Materials that are difficult or impossible to recycle must be replaced with more environmentally friendly alternatives.

✅ Provide technical documentation
OEMs and suppliers must prove that their packaging meets the new standards.

✅ Develop reusable packaging strategies
Packaging that can be used multiple times has clear advantages under the PPWR.

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What Can Companies Do Now?

✅ Analyze current packaging solutions
What packaging do you currently use? Does it fall under the PPWR definition?

✅ Adapt materials
If your packaging is difficult to recycle, start looking for alternatives now.

✅ Prepare documentation
Ensure all packaging is documented in terms of materials, recyclability, and usage.

✅ Implement reusable solutions

Reusable packaging offers a clear advantage under the PPWR framework.

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Conclusion: Act Now!

With the new PPWR definition, one thing is clear:

Not everything is considered packaging – but what qualifies as packaging must comply with strict regulations.

Companies in the automotive industry should analyze and adapt their packaging solutions now to avoid future challenges.

FEURER Automotive is already developing future-proof reusable packaging solutions that meet the new requirements.

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Need guidance on sustainable and compliant packaging solutions? Let’s talk!