EU PPWR FAQs Updated August 2026 - Flipbook - Page 24
IV.
RECYCLABILITY
1) In the context of recyclability performance grade assessment:
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how is a packaging unit defined,
what is the difference between integrated and separate components, and
what is the main body of the packaging unit?
A 8unit of packaging9 is defined in Article 3(1), point (45), of the Regulation as a unit, including
any integrated or separate components, which as a whole serves a packaging function, such as the
containment, protection, handling, delivery, storage, transport or presentation of products. A unit
of packaging is independent from units of grouped or transport packaging where the latter are
discarded prior to the point of sale. The term 8unit of packaging9 should be considered equal to
8packaging unit9, which is a term also used in the PPWR. Integrated and separate components are
also defined in the Regulation, in Article 3(1), points (43) and (44), respectively.
An illustrative example of a packaging unit is a plastic ketchup bottle made available to consumers
at the point of sale. Such a ketchup bottle consists of the following packaging components: plastic
bottle, removable lid (i.e. peelable foil), which is typically fully removed by consumers to access
the product, label, and the closure system. If a removable lid needs to be fully completely and
permanently separated by consumers to access the ketchup, then it should be considered as a
separate component. As regards the closure system, it typically does not need to be completely and
permanently separated by consumers and is thus disposed of together with the ketchup bottle.
Assuming that the closure system on a ketchup bottle is not meant to be separated by consumers,
it should be considered as an integrated component. As for the label, it is typically attached to the
plastic bottle and disposed of together with a ketchup bottle. Hence, it is considered an integrated
component; in this context, the plastic bottle itself is the main body of the packaging unit.
Against this background, it could be considered that the main body of the packaging unit is the
packaging part of the packaging unit with the highest share, by weight, except closure on flexible
packaging.
According to Article 6(9), 8where a unit of packaging includes integrated components, the
assessment of compliance with the design for recycling criteria and with the recycled-at-scale
requirements shall include all integrated components. A separate assessment shall be carried out
for integrated components that can become separated from each other as a result of mechanical
stress during transportation or sorting9.
2) If there is no recyclable alternative for a specific packaging or its components on the
market, could such packaging or its component get an exemption under Article 6?
The exemptions from the recyclability obligations are listed in Article 6(11). The Commission is
not empowered to grant any further exemptions. However, in case of innovative packaging, as
brought to the attention of the competent authorities in the Member States, the Commission must
assess the requests from the competent authorities and update or adopt new delegated acts under
Article 6(4). Innovative packaging is defined as 8packaging that is manufactured using new
materials, resulting in a significant improvement in the functions of the packaging, such as the
containment, protection, handling, or delivery of products, and in overall demonstrable
environmental benefits, with the exception of packaging that is the result of modification to existing
packaging for the main purpose of improving the presentation of products and marketing9 (Article
3(1), point (46)).
The Commission will monitor the impact of the derogations contained in Article 6(11) and
derogations as regards innovative packaging contained in Article 6(10), and may propose
amendments to the Regulation, if necessary.
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