EU PPWR FAQs Updated August 2026 - Flipbook - Page 33
VII.
PACKAGING MINIMISATION
1) Do both Article 10(1) and (2) on packaging minimisation apply by 1 January 2030?
Yes. Both Article 10(1) and (2) apply by 1 January 2030. Until the end of 2029, the essential
requirements from the PPWD continue to apply and thus also the existing standard EN 2004:13428.
This results from Article 70(1)(b) of the Regulation.
2) How should the term 8increase the perceived volume of the product9 in Article 10(2)
be understood?
The use of certain packaging characteristics, such as double walls or false bottoms, is not allowed
when the perceived volume of the product is increased.
An illustrative example below is provided to help better understanding.
Example
Packaging minimisation
Plastic or glass 50 ml jar Plastic or glass jars are reduced
for facial cream
to the minimum volume
necessary to protect the
product inside
Choices that might increase the
perceived volume of the product
Use of double walls or false bottoms to
make it appear that the content of the cream
as more than 50 ml
Use of cardboard boxes around the jar
which make it appear that the content of the
cream larger than 50 ml
Moreover, the Impact Assessment that supported the legislative proposal of the PPWR outlines a
few examples on 8increase the perceived volume of the product920.
Overall, the economic operator must prove that double walls, false bottoms, frontal flaps and
additional layers are used only in circumstances where the packaging functionality cannot be
ensured otherwise and/or in cases where these components add legitimate functionality to the
packaging. This will have to be demonstrated via tests and proven in the technical documentation,
by providing a sufficient justification.
3) How will the requirements of packaging minimisation be enforced for other than the
most common packaging types and formats?
By 12 February 2027, the Commission will request the European standardisation organisations to
prepare or update, as appropriate, harmonised standards laying down the methodology for the
calculation and measurement of compliance with the minimisation requirements. These standard(s)
will be an update of the existing standard EN 13428:2004 to account for the changed performance
criteria set out in Annex IV of the Regulation and will outline the methodology for demonstrating
compliance with the minimisation requirements for all packaging. Once adopted, economic
operators will be able to use the updated standard and thus benefit from the presumption of
conformity with the minimisation requirement.
20
Assessment of options for reinforcing the Packaging and Packaging Waste Directive9s essential requirements and
other measures to reduce the generation of packaging waste - Publications Office of the EU, page 26: an identical
packaging format in terms of size, weight and volume is used to pack different amounts of the same type of
screws. In the first case, the packaging fits 100 screws, whereas in the second case the same packaging contains
20 screws of the same size. Therefore, the second case (i.e. pack of 20 screws) is considered over-packaged, both
in terms of the volume and weight of the pack.
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