Overview
A quick reference for the terms this documentation and the regulation use. Terms are grouped so you can scan by topic.
Packaging and categories
| Term | Meaning |
|---|
| Packaging | Any item used for the containment, protection, handling, delivery, or presentation of products, from producer to end user. |
| Packaging unit | The individual unit that requirements attach to. Every unit needs classification, substance compliance, technical documentation, and a Declaration of Conformity where required. |
| Sales packaging (primary) | Packaging conceived to constitute a sales unit to the end user at the point of purchase. |
| Grouped packaging (secondary) | Packaging conceived to group a number of sales units. |
| Transport packaging (tertiary) | Packaging conceived to facilitate handling and transport, such as pallets and wrapping films. |
| E-commerce packaging | Packaging used to deliver products sold online to the end user. |
| Single-use packaging | Packaging conceived to be used once and not designed for reuse. |
| Contact-sensitive packaging | Packaging in contact with sensitive product categories, most importantly food. Food-contact packaging carries the PFAS limits of Article 5(5). |
Companies and roles
| Term | Meaning |
|---|
| Economic operator | Collective term for the companies with duties under the regulation: manufacturers, importers, distributors, and related actors. |
| Manufacturer | The company that manufactures packaging or a packaged product, or markets it under its own name or trademark. Own-brand selling can make you a manufacturer even if a partner produces the goods (Article 3(1)(13), Article 21). |
| Importer | The company that places packaging or packaged products from a third country on the EU market. |
| Distributor | A supply-chain company, other than the manufacturer or importer, that makes packaging available on the market. |
| Producer | The company responsible in a member state for the packaging it supplies there. The anchor for registration and EPR (Articles 44 and 45). |
| Authorised representative for EPR | A representative a producer appoints in a member state where it has EPR obligations but no establishment. |
| Placing on the market | The first making available of packaging on the EU market. One placed packaging is enough to trigger company-level obligations. |
| Term | Meaning |
|---|
| Packaging conformity | The packaging meets the regulation's requirements, from substances to design. From 12 August 2026, market access is only for conform packaging. |
| Substances of concern | Restricted substances in packaging, including the heavy-metals sum limit of 100 mg/kg (Article 5(4)) and PFAS limits for food-contact packaging (Article 5(5)). |
| Technical documentation | The evidence file behind a packaging unit's conformity. |
| Declaration of Conformity (DoC) | The formal declaration that a packaging unit conforms with the regulation, drawn up before placing on the market. |
| Marking and labelling | The required markings on packaging, with a harmonised EU label expected from 2028. |
| Term | Meaning |
|---|
| Design for recycling grades | Recyclability performance grades A, B, and C (thresholds 95, 80, and 70 percent) defined via Annex II. Packaging below grade C is progressively excluded from the market. |
| Recycled content | Minimum shares of recycled material in plastic packaging, phasing in from 2030 with higher targets by 2040. |
| Empty-space ratio | The share of a package that is empty space. At most 50 percent for transport and e-commerce packaging from 2030 (Article 24(1)). |
| Reuse targets | Binding reuse shares for packaging categories, including 40 percent for transport packaging by 2030 (Article 29(1)). |
| Extended producer responsibility (EPR) | The producer's financial and organisational responsibility for packaging at end of life, run per member state. |
| Simplified reporting threshold | Below 10 tonnes of packaging per year in a member state, reporting is simplified (Article 44(8)). It is not an exemption from registration or EPR. |
ℹ️ Regulatory context. Definitions sit in Article 3 of the regulation, with packaging examples in Annex I and recyclability parameters in Annex II. See Regulation (EU) 2025/40.
