EU PPWR FAQs Updated August 2026 - Flipbook - Page 10
II.
DEFINITIONS
Definition of packaging
1) Does the wording packaging 8…whether empty or with a product…9 modify the
definitions of packaging and of manufacturer under the PPWR?
Article 3(1), point (1), contains a definition of packaging, which remained largely unchanged
compared to the packaging definition in the Directive 94/62/EC. However, the new definition
contains the new wording 8…whether empty or with a product…9. This new wording does not
modify the definition of packaging or the definition of manufacturer but is intended to cover all
different factual situations and types of packaging that come within the scope of the PPWR. For
further information on the packaging definition, please consult the Commission guidance
document.
2) Why does the definition of packaging for tea and coffee mention 8machine use9 only
in point (g) and not in point (f) of Article 3(1)?
The wording indicates the difference between systems for filter coffee/tea bags and those for coffee
extraction machines. Machine use is one of the key criteria to decide if a tea/coffee capsule falls
under Article 3(1), point (1)(f), or point (1)(g). Permeability is another element that needs to be
considered.
This distinction is important in relation to the compostability requirements in Article 9. Permeable
tea, coffee or other beverage bags, or soft after-use system single-serve units that contain tea, coffee
or another beverage, which are intended to be used and disposed of together with the product (point
(1)(f)), are mandatorily compostable. Non-permeable tea, coffee or other beverage system
singleserve units intended for use in a machine, and which are used and disposed of together with
the product (point (1)(g)) are not. However, Member States may decide to make the latter
mandatorily compostable on their territories, under certain conditions, such as the existence of an
appropriate collection and waste treatment infrastructure for bio-waste. Member States cannot ban
or require compostability as regards metal capsules.
3) Are envelopes containing letters, invoices, statements and other correspondence
which serve a communication function considered to be packaging under the PPWR?
NEW!
Whether an item qualifies as packaging must be assessed based on the definition of packaging set
out in Article 3(1), point (1). Furthermore, Annex I to the Regulation provides an indicative list of
items that are considered packaging and items that are not.
Packaging is defined in Article 3(1) of the PPWR as
