EU PPWR FAQs Updated August 2026 - Flipbook - Page 46
XII.
BANS AND THE USE OF CERTAIN PACKAGING
1) What instruments are available to ensure legal harmonisation and predictability of
the implementation of Annex V?
The Regulation empowers the Commission to adopt guidelines by February 2027, in consultation
with Member States and EFSA (European Food Safety Authority), to explain Annex V in more
detail, including examples of packaging formats in scope, and any exemptions from the restrictions,
and provide a non-exhaustive list of fruits and vegetables that are excluded from point 2 of Annex
V (Article 25(6) PPWR).
The Commission has started preparatory works for the guidelines and intends to ensure that these
guidelines are based on science and on the latest technological developments. The intention is to
ensure a common understanding and the equal implementation of the packaging formats in scope,
and any exemptions from restrictions. While the Regulation does not empower the Commission to
harmonise the list of exempted fruits and vegetables via an implementing or delegated act, the
Commission, together with EFSA, has been working hard to ensure a solid scientific basis for the
future guidelines, and expects that Member States will follow the guidelines, once published.
Finally, the Regulation contains a specific review clause requiring the Commission to assess, by
2032, the packaging bans and empowering it to propose new restrictions or to amend the existing
derogations and exemptions.
2) What do the terms 8unprocessed fresh fruits and vegetables9 and 8demonstrated need9
in point 2 of Annex V mean?
The terms 8unprocessed fresh fruits and vegetables9 and 8demonstrated need9 will be further
clarified after the formal consultation with the related stakeholders and EFSA, in the context of the
development of the Commission guidelines.
The term 8unprocessed fresh fruits and vegetables9 refers to fresh fruit and vegetables that have not
been altered.
When such fruits and vegetables weigh less than 1,5 kg, they cannot be prepacked. The Commission
will develop guidelines explaining, based on scientific studies, which unprocessed fresh fruit and
vegetables are appropriate for exemptions.
3) Is it possible to extend the scope of the illustrative formats and products covered by
point 4 of Annex V to additional sectors (e.g. schools), beyond the exemptions
explicitly listed?
Point 4 of Annex V concerns single-use plastic packaging for condiments, preserves, sauces, coffee
creamer, sugar and seasoning in the HORECA sector. It expressly exempts only (a) take-away
ready-prepared food intended for immediate consumption and (b) the healthcare sector. The
illustrative formats will be developed in the guidelines. The PPWR does not provide a legal basis
to enlarge the list of exemptions to other sectors.
4) How shall the term 8necessary to facilitate handling9 under point 1 of Annex V to be
understood?
The restriction in question concerns 8single- use plastic grouped packaging used at the point of sale
(…), designed as convenience packaging to enable or encourage consumers to purchase more than
one product9. What is targeted is unnecessary single-use plastic grouped packaging designed for
ease of use and portability, and which also incites consumers to buy more.
Both conditions should be fulfilled for the ban to apply. The most common examples of such
packaging are collation films and shrink wraps, grouping two or more stock keeping units (SKUs).
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