EU PPWR FAQs Updated August 2026 - Flipbook - Page 37
IX.
ENVIRONMENTAL CLAIMS
1) Will businesses be allowed to make environmental claims about features that are
equivalent to those established by the Regulation?
Article 14 applies only to 8properties for which legal requirements are set out in this Regulation9.
Environmental claims and sustainability labels related to, e.g., recyclability, compostability,
recycled content, reusability, weight and volume minimisation, fall under the PPWR and
manufacturers will need to make sure that such claims comply with Article 14, i.e. relate to
properties that go beyond minimum requirements set by the PPWR and specifies if the claim refers
to the whole packaging unit or a specific part of it.
As regards environmental claims related to sustainability requirements outside the scope of this
Regulation, for example recycled content in aluminium packaging, they must comply with the
existing EU rules on environmental claims, in particular the Empowerment of Consumers Directive
(EU) 2024/825, which amends the Unfair Commercial Practices Directive (2005/29/EC) and the
Consumer Rights Directive (2011/83/EU). For further information on the relationship between the
Unfair Commercial Practices Directive and other legislation, please, consult the Commission
Guidance document on its interpretation22, in particular parts 1.2.1. on relationship with other EU
legislation and part 4.1.1.1 on the Interplay with other EU legislation on environmental claims,
which explains that lex specialis (e.g. PPWR) prevails over lex generalis (UCPD) in case of
conflict.
2) In case the manufacturer wants to make a claim about the share of recycled content
on the packaging unit, which threshold should be considered as the minimum
requirement established by law? Will it be possible to make claims about 10, 20 or
50% of recycled content in each unit?
In case a manufacturer makes a claim about the share of recycled content in packaging placed on
the market, the applicable minimum targets (calculated as an average per manufacturing plant and
per year), will apply and the manufacturers will be allowed to make the claim only if the recycled
content exceeds those targets. For recycled content, the calculation and verification methodology
will be established by 31 December 2026 in an implementing act, and environmental claims will
need to comply with these rules. The voluntary label for recycled content will be developed by the
Commission.
3) Does Article 14 apply only for environmental claims which refer to requirements
stated in the PPWR (e.g. recyclability) or also for any other kind of environmental
claims on sustainable packaging?
Article 14 applies only to 8properties for which legal requirements are set out in this Regulation9.
Therefore, as regards environmental claims which are not regulated under the PPWR, e.g. related
to recycled aluminium content, they must comply with the existing EU rules on environmental
claims, in particular the Empowerment of Consumers Directive (EU) 2024/825.
22
Commission Notice 3 Guidance on the interpretation and application of Directive 2005/29/EC of the European
Parliament and of the Council concerning unfair business-to-consumer commercial practices in the internal
market (OJ C 526, 29.12.2021, pp. 13129).
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