EU PPWR FAQs Updated August 2026 - Flipbook - Page 40
7) Under what circumstances can the obligations under Article 15(5) & (6) be fulfilled
via accompanying documents? NEW!
These obligations apply to all packaging placed on the market after 12 August 2026, regardless of
the type of packaging or the material used.
Where the size or nature of the packaging does not allow for the affixing of a unique identifier and
the name and address of the manufacturer, as established under articles 15(5) and (6) of the PPWR,
the information can be provided in a document accompanying the packaging. Whether or not it is
possible to affix the information on the packaging should be assessed on a case-by-case
basis, taking into account the physical dimensions, shape and functional characteristics of the
packaging. In addition, packaging that has not been placed on the market by 12 August 2026, but
that has already been produced or sits in stock, may also use an accompanying document to meet
these requirements before being placed on the market.
8) In practice, do the requirements of Article 15(5) mean that every individual unit of
packaging needs to be traceable? NEW!
Article 15(5) requires packaging to bear information enabling its unique identification, such as a
serial number, batch number or another equivalent element. The purpose of this provision is
to facilitate traceability of the packaging placed on the market for compliance verification and
market surveillance purposes 3 i.e. to enable the packaging to be identified (for example a
packaging type, model or production batch), so that it can be linked to the relevant technical
documentation and declaration of conformity.
The Regulation does not require every single component of a packaging unit to be individually
marked for traceability purposes. For example, for a yoghurt cup consisting of a plastic cup, lid and
sleeve or label, it should be sufficient if the required information is displayed on only one
component of the sales packaging.
In addition, where the size or nature of the packaging does not allow for the identifier to be on the
packaging itself, Article 15(5) allows it to be provided in a document accompanying a packaged
product.
In general, identification may be provided through batch numbers or other equivalent means and
may refer to types or production batches of packaging rather than to each individual item.
Commonly used and standardised packaging items such as adhesive tapes, generic plastic
bags, or desiccant bags that are bought from suppliers are normally traceable at the level of the
production batch, and not at the level of each individual unit.
9) Can manufacturers delegate responsibilities to third parties? NEW!
As Article 15(1) sets out, manufacturers are responsible for ensuring the compliance of the
packaging they place on the market with the PPWR rules. Before placing packaging on the market,
the manufacturer must therefore undertake certain steps, including those outlined in Article 15(2):
carry out a conformity assessment procedure, draw up an EU declaration of conformity and compile
the other technical documentation required (see Articles 38 & 39 and Annexes VII & VIII).
In relation to the conformity assessment procedure: as per Article 15(2), manufacturers may carry
this out themselves or opt to have it carried out on their behalf (e.g. by a laboratory or a certification
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