Summary
The PPWR replaces the informal primary, secondary and tertiary vocabulary with three defined packaging levels: sales packaging, grouped packaging and transport packaging, plus e-commerce packaging as a sub-type of transport packaging. The level is not a label you attach afterwards. It determines which requirements apply, and each level carries its own EU Declaration of Conformity covering only the packaging introduced at that level.
One Declaration of Conformity per level
PPWR DoCs are per packaging level and are not nested. Every sales unit, every grouped unit and every transport unit has its own packaging system and its own DoC, and that DoC covers only the packaging introduced at that level. The packaging of a sales unit sitting inside a grouped unit or a transport unit is already covered by its own DoC and is not re-declared higher up.
Sales, grouped and transport are functional types, not a fixed three-layer count. Real portfolios contain mixed pallets, counter displays inside floor displays, and multipacks inside multipacks. Any unit at any level that introduces new packaging gets its own packaging system and its own DoC.
Common misclassifications
- Treating a display as transport packaging. A counter or floor display used for in-store presentation and shelf replenishment is grouped packaging. A display shipper that only protects goods in transit is transport packaging.
- Re-declaring nested packaging. Repeating the sales packaging components in the transport unit DoC duplicates work and creates conflicting declarations.
- Forgetting labels, stickers and closures. Claim stickers, seals, caps and bottom labels are packaging components of the sales packaging and belong in its packaging system.
- Assuming e-commerce mailers are exempt. They are transport packaging and are subject to the 50 percent empty space ratio limit.
- Missing the non-resellable items. Individually wrapped pieces inside a party pack are not sales units, so their wrappers are included in the parent sales unit's DoC.