Colloquially, many know GTIN as a barcode, but technically, GTIN is the number found beneath the barcode symbol itself, and can therefore also be used for other technologies such as 2D barcodes and RFID tags.
Nine days before the Packaging and Packaging Waste Regulation (PPWR) began to apply on August 12, 2026, the European Commission published a 69-page guidance document and an updated FAQ containing a number of significant clarifications to the rules.
The PPWR FAQ provides, among other things, further clarification on who is considered a producer, how producer responsibility is assigned for transport packaging, and what requirements apply to importers and technical documentation.
We have compiled five of the most important clarifications for companies that produce, import, or market packaging and packaged goods in the EU.
The Commission clarifies that the producer of the packaging is, as a starting point, the entity that determines the design of the packaging. Therefore, it is not necessarily the company that physically manufactures or fills the packaging.
In practice, the company's name or trademark can be an important indicator of who is considered the producer, while the physical manufacturer will often be responsible for standard packaging.
The updated FAQ emphasizes that empty transport packaging is also considered packaging under the PPWR. The producer of transport packaging must therefore be identified when the packaging is empty.
When trading across EU countries, producer responsibility can shift between the physical manufacturer, the filler, and the brand/name owner.
The PPWR imposes extensive requirements for documentation. Producers must, among other things, be able to document the packaging's design, materials, traceability, and EU Declaration of Conformity (DoC).
The Commission also clarifies that packaging produced before August 12, 2026, can continue to be used, while new packaging must, as a rule, be provided with unique identification information directly on the packaging. If this is not possible, the required information can be provided in an accompanying document.
From August 12, 2026, importers must ensure that packaging from third countries meets the requirements of the PPWR and is accompanied by the necessary documentation.
This includes, among other things, verification of the conformity assessment, the EU declaration of conformity, and information about the manufacturer.
The Commission clarifies that the PPWR obligations apply from August 12, 2026, and must be enforced from that date. At the same time, it is emphasized that non-compliance should not automatically lead to a general ban on the sale of products.
The Commission highlights that, as a starting point, member states should first give companies the opportunity to rectify the situation before imposing sanctions.
According to the FAQ, enforcement should be carried out in a way that does not unnecessarily disrupt trade flows, supply chains, or access to goods on the market.
Please note that this is only a brief summary. For the full guide to understanding the PPWR, we refer you to the Commission's FAQ. If you have questions about how the rules affect your business, we recommend that you contact your collective scheme.
Read the full FAQ from the European Commission
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GTIN (also known as EAN) stands for “Global Trade Item Number” and is the number sequence shown beneath a barcode symbol.
GTIN (EAN) is a global standard used to uniquely identify digital and physical products, allowing the barcode to be scanned anywhere in the world throughout the supply chain.
A GLN (also known as EAN) allows you to uniquely identify physical, functional, legal, or digital entities. This can include the sender, receiver, buyer, seller, supplier, manufacturer, delivery location, billing location, store, or internal departments.