Last week the European Commission published the official FAQ on the Packaging and Packaging Waste Regulation (PPWR), a document the whole sector had been waiting for because it settles practical questions that the legal text —extensive though it is— did not quite make clear. The FAQ do not amend the Regulation, but they specify how it is to be interpreted, and that is a key piece for any company that manufactures, imports, distributes or uses packaging in its operations.
A few months ago, at auma we already analysed the content of the PPWR when it was adopted The New Era of Packaging in Europe | auma. Now, with this FAQ, we can see what was still to be defined, what is clarified and which points will have a direct impact on companies and industrial SMEs.
The PPWR is an ambitious and transformative regulation, but also a complex one. BOE.es – DOUE-L-2025-80087 Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC.
Many companies —SMEs in particular— were faced with very specific questions:
What exactly is a composite packaging? How do you demonstrate that packaging is recyclable “in practice and at scale”? When is packaging reusable? Who is the “producer” under extended responsibility schemes?
The FAQ published this week answer all these questions, and they do so with practical criteria that will help apply the regulation consistently across the EU. Frequently asked questions on the Packaging and Packaging Waste Regulation (PPWR) – Environment
This article summarises the points that genuinely change the way companies will have to manage their packaging, because it is these clarifications —rather than the original legal text— that will determine what companies must do in 2026, 2027 and 2030.
1. Definitions that make the difference
One of the major challenges of the PPWR was the interpretation of many of its definitions. The FAQ provide key criteria:
What is packaging, really?
It is clarified that packaging is any item that contains, protects or presents a product, whether empty or full. A number of borderline cases are also resolved: integrated components, accessories, multilayers, etc.
Composite and multi-material packaging
The 5% by weight limit is confirmed as the determining criterion. Many manufacturers will have to review designs they considered “mono-material” which in fact are not.
Who is the producer under EPR?
The FAQ confirm that the “producer” is whoever places the packaging on the EU market, resolving common doubts around imports, ecommerce and subcontracting.
These definitions are not mere nuances: they determine obligations, costs and compliance plans.
2. Substances of concern: what really has to be controlled
The Regulation refers to substances of concern, but the FAQ set out the detail:
- it is not only PFAS that are covered: there are other chemical families potentially affected
- the criteria are not cumulative: if a single criterion applies, the substance is considered to be of concern
- the technical basis is the definitions in the ESPR Regulation and in CLP.
For an SME this means having to require detailed chemical information from its suppliers and, in some cases, adapting formulations or materials.
3. PFAS: the point of greatest concern for the sector
The FAQ make it very clear that:
- the limit applies to all PFAS present, not only to those intentionally added
- compliance with the limit values will have to be demonstrated using harmonised methods that the EC is already developing,
- the risk is particularly high in food-contact packaging.
This is one of the points that will generate the most testing, declarations and adaptations in the coming years.
4. Recyclability: from theory to practice
The PPWR introduces the obligation to design packaging that is recyclable “in practice and at scale”. The FAQ give three critical clarifications:
The packaging unit is key
Integrated components, separable components and the main part of the body all count. A non-recyclable component can penalise the whole unit.
Recyclability does not depend on your country
It does not matter whether a technology exists in Spain or Catalonia, the reference is European.
This removes many of the sector's usual arguments.
The assessment will be public and harmonised
The European Community technical guidelines will set common criteria.
5. Recycled content: what has to be demonstrated (and what does not)
The FAQ confirm that:
- adhesives and inks do not count as plastic
- recycled content has to be evidenced in accordance with Annex VII
- companies will be able to demonstrate it per plant and per year
- there is a 5% exemption for small parts
In practice, SMEs will need more traceability and documentation than they have had until now.
6. Compostability: the real timetable and its limits
The FAQ confirm:
- the requirement for capsules and permeable bags starts on 12 February 2028
- Member States cannot impose compostability on metals or materials that do not comply with EN 13432
- compostability does not replace recyclability in most cases
7. Minimisation: the examples that affect design
The FAQ clarify what counts as oversizing:
- double walls
- false bottoms
- misleading volumes
And when exceptions are accepted on grounds of design, product quality or intellectual property.
8. Labelling and greenwashing: greater precision
The FAQ set out in detail:
- when a QR code may be used for environmental information
- which claims will be considered misleading
- what will have to be labelled digitally (substances of concern, recycled content, etc.)
This connects directly with the anti-greenwashing Directive.
9. Reuse, DRS and Extended Producer Responsibility (EPR)
This is where the FAQ have the greatest impact:
- it defines how rotations of reusable packaging are counted
- the conditions for requesting exemptions from DRS schemes are clarified
- it is confirmed that micro-enterprises are not exempt from most EPR obligations
This is a critical point for small or artisanal sectors.
10. What all of this means for companies
The FAQ are the official interpretation that the European Commission—and therefore the Member States—will use to apply penalties, inspections and compliance criteria.
For that reason, after reading them, a company should:
- review its packaging definitions and classifications
- adapt design and material compositions
- prepare RAP and substances documentation
- review labelling and claims
- anticipate design changes ahead of 2027–2030
At auma we can help you to:
- analyse the real impact of the FAQ on your packaging formats
- check whether your packaging complies with definitions, recyclability and minimisation
- prepare the documentation and evidence for RAP, EPR and recycled content
- and define a 2026–2030 adaptation plan with practical, realistic criteria
This FAQ confirms that the PPWR is no longer “a rule for the future” but a present-day roadmap for any company working with packaging.