Clarification regarding the application of the PPWR to existing stock

The requirements of the PPWR apply to all packaging and packaged products placed on the EU market from 12 August 2026 onwards. The determining factor is not the date of manufacture, but when the packaging is placed on the market – meaning when it was first made available in a country within the EU.

Packaging that was transferred to an independent retailer or distributor before 12 August 2026 is generally considered to have already been placed on the market and is therefore not subject to the requirements of the PPWR.

However, stock that remains at the manufacturer’s own premises or with a logistics provider is not automatically considered to have been placed on the market. Packaging that was manufactured but had not yet been placed on the market as of 12 August 2026 is not covered by any general transitional provision. Once it is placed on the market, it must comply with all PPWR requirements applicable at the time it is placed on the market.

As an alternative, the PPWR’s labelling requirements for such packaging can be fulfilled by providing the required information in an accompanying document. Existing stock therefore generally does not need to be destroyed or relabelled. However, it is crucial to distinguish between packaging that has been “manufactured” and packaging that has been “placed on the market”.

Companies should therefore document when the packaging was first made available, for example through contracts, invoices, delivery documents and batch references.

The Commission’s statement is an important source for interpreting the rules, but it is not a legally binding court ruling.