EU PPWR FAQs Updated August 2026 - Flipbook - Page 26
account sustainability criteria of recycling technologies and the environmental cost, which are to
be developed by the Commission under Article 7(9) by the end of 2026.
5) If Member States do not reach the recycling targets, is there any mechanism foreseen
to take this into account in the recyclability 8at scale9 assessment?
The 8at scale9 assessment will be based on a recycling target of 55%17 to be achieved at EU level
per packaging categories listed in Table 2 of Annex II. The Commission is empowered to amend
the list of these categories to adapt them to the technical and scientific developments regarding
packaging and packaging waste management. The 8at scale9 assessment is not based on the
recycling rates achieved at national level and therefore there is no need for a specific mechanism
in the recyclability at scale assessment, which would take into account the fact that a specific
Member State did not reach specific recycling targets.
However, it is important that all Member States strive to optimise their collection, sorting and
recycling systems to improve the overall recycling rate at the Union level and the availability of
secondary feedstock. The Regulation provides for several support measures, such as the obligation
to set up deposit and return systems, mandatory harmonised waste sorting labels, the obligation on
Member States to establish mandatory collection targets, and the prohibition to landfill or incinerate
recyclable packaging. The implementation of these requirements will help increase the overall
recycling rate in the EU and thus allow economic operators to fulfil the recycling 8at scale9
requirement.
6) What is the scope of the exemption under Article 6(11)(e) for baby food?
The exemption for baby food as referred to in Regulation (EU) No 609/201318 should be understood
in line with the definition given in its Article 2(2f). Therefore, the exemption should not be
understood as covering all fruit juices and purees and other products that are marketed for
consumption by babies.
7) Will the recyclability 8at scale9 assessment be based on all packaging waste generated
regardless of its origin, sector or type?
The recyclability 8at scale9 assessment and the related 55% recycling target for all packaging
materials and 30% for wood indeed refers to all packaging waste generated and recycled in the EU,
regardless of its origin (household, commercial and industrial waste), sector or type. Calculation of
the recycling rate should be based on the existing rules for the calculation of recycling rates laid
down in Commission Decision 2005/270, as amended, which will be replaced by a new decision
under Article 56(7) PPWR.
8) Does Article 6 apply to reusable sales and transport packaging placed on the EU
market prior to the entry into force of the requirements under Article 6(1) PPWR?
Recital (14) explains that 8packaging should be placed on the market only if it complies with the
sustainability requirements and labelling requirements laid down in or pursuant to this Regulation9
(emphasis added). Packaging already placed on the Union market before the date of application of
relevant requirements, including packaging in the stocks, does not need to meet the sustainability
17
For all materials except for wooden packaging, where it is 30%.
18
Regulation No 609/2013 of the European Parliament and of the Council of 12 June 2013 on food intended for infants
and young children, food for special medical purposes, and total diet replacement for weight control and repealing
Council Directive 92/52/EEC, Commission Directives 96/8/EC, 1999/21/EC, 2006/125/EC and 2006/141/EC,
Directive 2009/39/EC of the European Parliament and of the Council and Commission Regulations (EC) No
41/2009 and (EC) No 953/2009 (OJ L 181, 29.6.2013, pp. 35356)
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