EU PPWR FAQs Updated August 2026 - Flipbook - Page 34
In addition, for the most common packaging types and formats, the Commission will request the
European standardisation bodies to prepare standard(s) specifying the maximum adequate weight
and volume limits and, where appropriate, wall thickness and maximum empty space.
4) What are the 8most common packaging types and formats9 mentioned in Article
10(3)?
The Commission will identify the 8most common packaging types and formats9 in its forthcoming
standardisation request pursuant to Article 10(3) PPWR.
These types and formats will be identified in collaboration with the industry and other stakeholders
and be based on the available market data in terms of units placed on the market, on a level of
granularity which accounts for the packaging functionality, packaging material and shape, as well
as the packaged product. The potential for minimisation will also be considered in the framing of
the standardisation request.
5) Which packaging is exempted from the minimisation requirements?
The following packaging is excluded from the minimisation requirements (Article 10(2)):
Packaged products or beverages that benefit from a geographical indication protected under Union
law, such as under Regulation (EU) No 1308/2013 for wine, Regulation (EU) 2019/787 for spirit
drinks or Regulation (EU) 2023/2411 for craft and industrial products or is covered by a quality
scheme as referred to in Regulation (EU) 2024/1143.
If packaging design is protected by a Community design pursuant to Council Regulation (EC) No
6/2002 (64) or by design rights falling within the scope of Directive 98/71/EC of the European
Parliament and of the Council (65), including international agreements having effect in one of the
Member States. For the exemption to apply, the packaging design must be protected before 11
February 2025, and the application of the minimisation requirements affect the packaging design
in a way that it would alter its novelty and its individual character
If packaging shape is a trademark falling within the scope of Regulation (EU) 2017/1001 (66) or
Directive (EU) 2015/2436 (67), including trademarks registered under international agreements
having effect in one of the Member States. For the exemption to apply, the trademark must be
protected before 11 February 2025, and the application of the minimisation requirements affect the
packaging in a way that the trademark can no longer distinguish the marked product from those of
other undertakings.
If the economic operator wants to use these exemptions, it will need to provide evidence related to
them in the technical documentation. It will not be sufficient to provide a licencing number. It will
also be necessary to demonstrate the existence and assessment of other conditions.
6) How will the packaging 9shape9 affect the packaging minimisation assessment?
Firstly, the economic operator will have to consider if its packaging is covered by the exemption in
Article 10(2)(a) related to shapes which are protected trademarks and if the conditions set out in
that provision for exemption from the minimisation requirements are fulfilled. The verification of
said conditions needs to be demonstrated by the economic operator.
If the packaging is not covered by the exemption, economic operators will apply the updated
harmonised standard on the methodology for packaging minimisation assessment to be requested
by the Commission pursuant to Article 10(3). This updated harmonised standard will take the
packaging shape into account in its methodology. For example, if a specific shape is necessary to
provide packaging for the packaging functionality, such as safe-handling design, child resistance,
anti-tamper, anti-theft, anti-counterfeit, hazard warnings, or specific product characteristics.
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