PPWR – What counts as packaging?

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

Especially in the automotive industry, where packaging serves not only to protect products but also often for storage, logistics, or labeling, companies must determine which of their packaging solutions are affected by the regulation.

 

How does the PPWR define packaging?

According to Article 3 of the PPWR, packaging is an item, regardless of its material, that fulfills one of the following functions:

• Product Protection: Packaging protects a product from damage or environmental factors.
• Transport/Loading Function: Packaging enables safe and efficient transport.
• Storage/Handling Function: Packaging makes it easier to store or handle a product.
• Labeling/Information Function: Packaging contains important information about the product.
• Process function: Packaging is required in production processes.
• Sales function: Packaging is used to market a product.
• Hygiene/Safety Function: Packaging contributes to hygienic storage or safety.

If an item does not serve any of these functions, it is not considered packaging and is therefore not subject to the requirements of the PPWR.

What does this mean for the automotive industry?

Logistics in the automotive industry relies on a wide range of packaging solutions, including:

✅ Transport and loading carriers for parts and components

✅ Protective packaging for delicate parts

✅ Marking and labeling systems for product identification

✅ Reusable packaging for closed-loop delivery systems

✅ Single-use packaging for international or complex shipping routes

Companies must now carefully examine which packaging items fall under the new definition—because these items are subject to strict requirements regarding recyclability, material use, and documentation.

Challenges for OEMs and Suppliers

✅Check existing packaging
Companies should determine which materials are used in their packaging and whether they meet the new requirements.

✅Ensure recyclability
Materials that are not recyclable or are difficult to recycle must be replaced with more environmentally friendly alternatives.

✅Provide technical documentation
OEMs and suppliers must demonstrate that their packaging complies with the new requirements.

✅Further develop reusable strategies
Packaging that can be reused multiple times offers clear advantages under the PPWR.

What can companies do now?

✅ Analysis of your own packaging solutions
What packaging do you currently use? Are they defined as packaging under the PPWR?

✅ Customize materials
If your packaging is difficult to recycle, you should start looking for alternatives early on.

✅ Prepare documentation
Packaging must be documented in terms of material, recyclability, and use.

✅ Use reusablepackaging
Reusable packaging offers a clear advantage under the PPWR regulations.