EU PPWR FAQs Updated August 2026 - Flipbook - Page 27
and labelling requirements laid down in or pursuant to this Regulation and does not need to be
withdrawn.
Article 6(2) requires that all packaging placed on the market 24 months from the date of entry into
force of the delegated acts adopted pursuant to Article 6(4) is recyclable according to the DfR
principles laid down therein. This obligation refers to every type of packaging, regardless of
whether it is reusable or single-use, or sales, grouped or transport packaging.
Therefore, since the delegated acts under Article 6(4) are to be adopted by 1 January 2028, reusable
or transport packaging which manufacturers will have placed on the market before 1 January 2030,
can stay on the market even if it is not compliant with the recyclability requirements. Placing on
the market refers to every single packaging unit and not to the packaging design.
9) Are the exemptions from the recyclability requirements for packaging made from
cork, lightweight wood, textile, ceramics rubber, porcelain and wax valid until 2035?
Article 6(1) requires that all packaging be recyclable. Article 6(11) establishes exemptions from
this requirement for certain packaging materials and sectors. The Commission will review these
exemptions by 1 January 2035 to consider if it is appropriate to maintain them. Based on this
assessment, it may propose to amend or remove them.
The exceptions for packaging made from cork, lightweight wood, textile, ceramics rubber,
porcelain and wax apply only to sales packaging and mean that such packaging will not have to
undergo the recyclability assessment for the purpose of determining if it can be placed on the
market.
However, the obligation to adjust the EPR fees based on the recyclability performance will apply
also to such sales packaging. The recyclability assessment for such packaging will thus be carried
out only for the purpose of determining the EPR fee modulation.
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