PPWR · EU Companies · Packaging
Classification
Overview
Classification is the first step of every packaging item's journey, and everything else depends on it. It answers whether the item is packaging at all (Art. 3, Annex I), what kind it is, and the two attributes that gate later requirements: single-use or reusable, and food contact. The later steps read these values; they are maintained here only.
Before you start
- Know what the item is and does: its function relative to the product, its material, and how it is used.
- Know whether it is used once or designed for rotation, and whether it touches food.
Step by step
- Open the item from the Packaging list and start with the Classification step.
- Get the verdict. The item is classified as packaging or not packaging, with the reasoning shown:
- Definition basis, for example Art. 3(1)(1)(a), the limb of the packaging definition the item falls under.
- Annex I match, for example "Item performs a packaging function (Annex I)". An item classified as packaging shows the Packaging badge with Confirmed and its classification date; an item that is not packaging gets the Not packaging verdict and the compliance status Not relevant for PPWR.
- Set the packaging type and level where applicable, the category attributes the list filters use.
- Set Single-use / Reusable. Choose one explicitly; Unset means not yet answered. This drives reuse-related duties and the retention period of your marking evidence.
- Set Food contact. Yes or No, explicitly. Yes gates the PFAS limits (Art. 5(5)) and the PFAS test documentation slot in Supplier information.
- Re-classify or edit later with the actions in the step header, for example when the item's design or use changes.
The two gating attributes
| Attribute | Gates |
|---|---|
| Single-use / Reusable | Reuse obligations, and how long marking evidence is kept: 5 years for single-use, 10 years for reusable packaging (Art. 15(3)). |
| Food contact | The PFAS limits of Art. 5(5) and the corresponding test documentation from your supplier. |
After classification
- The verdict, type, level, and single-use values appear in the Packaging list and its filters.
- Master data & marking, Substances, and the retention logic read the classification values from here.
- Items with the Not packaging verdict are done: no further steps required.
Tips
- Classify honestly rather than conveniently. A Not packaging verdict you cannot defend is worse than a documented Packaging verdict with a thin obligation set.
- Answer the toggles explicitly instead of leaving Unset; downstream steps cannot compute with unanswered attributes.
ℹ️ Regulatory context. The packaging definition sits in Article 3(1)(1), with the illustrative criteria and examples in Annex I. The two attribute gates come from Article 15(3) (retention by single-use or reusable) and Article 5(5) (PFAS in food-contact packaging). See Regulation (EU) 2025/40.