EU PPWR FAQs Updated August 2026 - Flipbook - Page 11
This is to be contrasted with empty envelopes which are intended for the containment, protection,
handling, delivery or presentation of products, as well as envelopes that contain a product (such as
a catalogue or magazine), both of which are to be considered packaging.
Lastly, empty envelopes that are sold in a supermarket to consumers for private use are not
considered to be packaging.
4) What is the difference between sales, grouped and transport packaging? NEW!
Sales, grouped, and transport packaging are defined separately in the PPWR, based on their
intended use. They are also subject to different requirements in the PPWR.
Sales packaging (Article 3(1), point (5)) is the packaging that, together with the product, forms a
unit intended for sale to an end user. Sales packaging is often in direct contact with the product and
adapted to a specific product based on its special needs and characteristics. Sales packaging is also
typically used for the branding of the product and for consumer information.
Grouped packaging (Article 3(1), point (6)) is packaging that bundles several sales units (packaged
products). It often displays the name of the specific product and can be removed without changing
the characteristics of the product. Its purpose is typically adapted to the individual product, such as
facilitating stockkeeping or shelf display, or enabling or encouraging consumers to buy more than
one product. It varies whether it is sold with the product or not, and for this reason, grouped
packaging may be disposed of either in a commercial setting or at the consumer9s premises.
Transport packaging (Article 3(1), point (7)) forms the outer layer of packaged products and is used
during transport of sales units. It often contains information about logistics, transport and storage.
Transport packaging prevents damage to packaged products and facilitates handling, and it is
therefore often more standardized, bigger in size and sturdier than sales and grouped packaging,
and disposed of in a commercial or industrial setting.
However, e-commerce packaging (Article 3(1), point (8)), which is a special form of transport
packaging used for distance sales to 8end users9, will often be disposed of at the consumer9s
premises.
Definition of 8manufacturer9
5) Who is the manufacturer of transport packaging? NEW!
Following the definition of packaging (Article 3(1), point 1), transport packaging should be
considered packaging when it is manufactured and placed on the market with the intention of being
used for 8[..] the containment, protection, handling, delivery or presentation of products [..]9.
The manufacturer of transport packaging must therefore be identified at the stage where the empty
packaging has reached its final form. A packaging has reached its final form when it can be used
as transport packaging without any further components or ancillary elements added to it. In that
respect, it is important to clearly distinguish a combination of packaging items used for transport,
handling or sale of products from a genuine assembly or transformation operation of the packaging,
such as on-site moulding of materials or the creation of a packaging item from components which
in itself do not perform a packaging function.
The use of multiple packaging items (tape, wrap, boxes, pallets etc.) together does not mean that
each item is not already in its final form. Indeed, there can be packaging from multiple
manufacturers in one shipment of packaged products, and each manufacturer must provide the
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