Packaging and products in scope
Overview
PPWR has the broadest possible scope: all packaging placed on the EU market, regardless of material, and all packaging waste. There is no product list to check against, the way other regulations work with CN codes or commodity lists. Instead, the scope question is about the item itself: is it packaging, and if so, what kind?
What counts as packaging
Packaging is any item used for the containment, protection, handling, delivery, or presentation of products, from the producer to the end user. The regulation groups it into categories that later requirements refer to (Article 3 and Annex I):
| Category | Also called | Typical examples |
|---|---|---|
| Sales packaging | Primary packaging | The bottle around a drink, the box around a phone, the wrapper around a chocolate bar. |
| Grouped packaging | Secondary packaging | The film bundling six bottles, the display carton holding twelve wrappers. |
| Transport packaging | Tertiary packaging | Pallets, pallet wrapping films, crates and boxes used to move goods safely. |
| E-commerce packaging | The shipping box, filling material, and mailing bag used to deliver an online order. |
Some attributes cut across these categories and matter for later obligations, most importantly whether a unit is single-use and whether it is contact-sensitive (for example food-contact packaging, which carries the PFAS limits of Article 5(5)).
What is not packaging
Items that are part of the product itself, that are needed to contain or support the product for its whole lifetime, or that are intended to be used together with the product for its whole lifetime, are not packaging. In kolum, the classification step gives such items a Not packaging verdict, and they are marked as not relevant for PPWR so they do not carry per-unit obligations.
How scope works in practice
Two things follow from the scope design, and both shape how kolum works:
- Binary obligations. Placing a single packaging unit on the market triggers your company-level obligations. Quantities never switch duties on or off; they only matter for fees and reporting later. This is why kolum runs an applicability check per company rather than per shipment.
- Per-unit classification. Because requirements attach to the packaging unit and its category, every unit you place on the market must be classified before its obligations can be evaluated. This is what the Packaging section of the PPWR module in kolum is for.
ℹ️ Regulatory context. The definitions of packaging and its categories sit in Article 3 of the regulation, with illustrative examples in Annex I. See Regulation (EU) 2025/40.