EU Publishes New FAQs on the PPWR

With Regulation (EU) 2025/40 on packaging and packaging waste ("PPWR") set to become applicable on August 12, 2026, the European Commission has published further guidance in the form of an updated second edition of its Frequently Asked Questions document. Published last week, the revised FAQ document updates and replaces the first edition of March 30, 2026. According to the Commission, the new guidance addresses practical issues raised by stakeholders since the adoption of the PPWR.

As an interpretive and non-binding document, the FAQ complements the Commission's formally adopted guidance, the Commission Notice Guidance document for Regulation (EU) C/2026/3084, published on June 10, 2026, and repeatedly refers readers back to it.

Most notably, the revised FAQ document adds a dedicated section on enforcement in the period immediately following the PPWR's application date. It also refines the guidance on the manufacturer's role for transport packaging and unbranded packaging, as well as the treatment of existing stocks.

The revised FAQ, however, leaves some key gaps unresolved. For example, there is still no harmonized EU verification methodology for compliance with the Article 5(5) PFAS limits.

The short period between the publication of the revised FAQ and the start of the PPWR's applicability gives affected companies limited time to review the guidance. The publication falling during the European summer break further exacerbates the challenges for affected companies.