On Monday 30 March, the European Commission published the Guidance document and a Frequently Asked Questions (FAQs) document on Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), with the aim of supporting a uniform application of the new framework since 12 August 2026. The Commission expressly states that the guidance does not amend the Regulation itself, but provides interpretative clarification on selected provisions, where there is an evident margin of legal discretion, while the FAQs complement it through more operational answers to the questions raised by Member States and stakeholders.
From a structural standpoint, the Guidance document is drafted as an interpretative notice divided into 33 thematic sections covering the most sensitive legal and implementation issues: definitions, substances of concern and PFAS, recyclability, recycled content, compostability, minimisation, labelling, interaction with the SUPD, reuse, EPR, separate collection and deposit return systems. The FAQs document follows a more practical and systematic logic, organised into 19 chapters ranging from definitions and compliance to waste prevention, extended producer responsibility, collection systems and DRS.
The publication of these documents is particularly relevant from both a regulatory and implementation perspective, as it consolidates the Commission’s first interpretative positions on several key issues for the packaging sector and for extended producer responsibility systems. In particular, three areas deserve close attention:
- harmonisation and internal market: the Commission confirms that packaging labelling and several sustainability requirements under the PPWR are strongly harmonised, leaving limited room for diverging national rules;
- roles and responsibilities: the documents provide more precise clarification of the notions of manufacturer and producer, with direct implications for EPR, compliance and allocation of obligations across the value chain;
- key operational issues: the package contains relevant guidance on recyclability, recycled content, minimisation, compostability, reuse and DRS, alongside an important clarification that PFAS restrictions for food-contact packaging will apply from 12 August 2026, with no general stock exhaustion period for packaging placed on the market after that date.
The Commission has specified that the FAQs are subject to future revisions and will be treated as a living document to support Member States and industry in the transition toward an increasingly circular economy.