Understanding packaging categories, types, and components in PPWR

Last updated: June 9, 2026

This article explains the three levels of packaging structure in PPWR: categories, types, and components, and how they map to the way you add packaging in Coolset. Understanding these distinctions is essential before you start adding packaging to your products

Level 1: Packaging categories

PPWR defines five official packaging categories. Every piece of packaging placed on the EU market must be assigned to one of them. These categories replace the old "primary / secondary / tertiary" language from the previous Packaging and Packaging Waste Directive (PPWD).

Category	What it covers	Examples
Sales packaging (Art. 3(1)(5))	Constitutes a sales unit to the end user. Applies to both B2C and B2B.	Glass jar, PET bottle, blister pack, pouch
Grouped packaging (Art. 3(1)(6))	Groups multiple sales units at the point of sale; can be removed without affecting the product.	Cardboard multipack, display tray, shrink wrap around bottles
Transport packaging (Art. 3(1)(7))	Facilitates handling and transport. Excludes containers (road, rail, sea, air).	Pallets, corrugated shippers, pallet shrink wrap
E-commerce packaging (Art. 3(1)(8))	A sub-category of transport packaging used specifically for online or distance sales deliveries. Subject to empty-space ratio rules under Art. 24.	Mailer boxes, padded envelopes, shipping cartons with void fill
Service packaging (Art. 3(1)(d)+(3))	Filled at the point of sale. A new, explicit category under PPWR. Subject to specific re-use targets under Art. 11.	Paper coffee cup, take-away container, carrier bag filled at checkout

Do categories change your compliance obligations?

The packaging category affects certain specific obligations - notably the empty-space ratio rules for e-commerce packaging (Art. 24) and re-use targets for service packaging (Art. 11). However, the core obligations that apply from 12 August 2026 - issuing a Declaration of Conformity, maintaining technical documentation, PFAS and heavy metals compliance, and EPR registration - apply across all five categories.

Coolset platform will ensure that you are automatically shown all obligations that are relevant to your packaging type.

Don't forget transport packaging. It is the most commonly missed category during scoping. If you use pallets, corrugated shippers, or any tertiary packaging to move your products, those require their own DoC too.

Level 2: Packaging types

Within each category, PPWR organises packaging into packaging types. This is the level that drives your compliance workload: PPWR requires one Declaration of Conformity (DoC) per packaging type.

What makes something one packaging type?

A packaging type is the complete packaging unit - everything a customer or end user would expect to receive together, including any closure, label, liner, or cap. It is assessed as a whole.

Suncream example: A suncream brand uses a pump bottle consisting of a bottle, pump, label, and cap. Taken together, those four items form one packaging type. The customer would expect to receive all four together, so they are assessed as a complete unit. This results in one DoC for the suncream bottle packaging type.

Football example: A football is sold online in a cardboard box with bubble wrap inside. There are two packaging types here: one for the bubble wrap, one for the cardboard box. Each needs its own DoC.

Level 3: Packaging components

A packaging component is an individual material or element that makes up a packaging type. Components sit underneath a packaging type and are not assessed separately - they are assessed together as the complete unit.

Using the suncream example again: the packaging type is the suncream pump bottle. It is composed of four components:

Bottle (e.g. HDPE)
Pump (e.g. polypropylene with metal spring)
Label (e.g. paper with adhesive)
Cap (e.g. HDPE)

The DoC covers the complete packaging type, all four components together.

Note: In the Coolset platform components are added in the survey, not under the ‘packaging tab’.

Frequently asked questions

Do I need one DoC per SKU? No. You need one DoC per packaging type. If multiple SKUs use the exact same packaging - same materials, same product, same compliance outcome - they share one packaging type and one DoC. For example, a 500ml and 750ml PET bottle made from the same resin for the same product is one packaging type.
My pump bottle has four parts - do I need four DoCs? No. The pump bottle is one packaging type, composed of four components. You assess the complete unit and issue one DoC for the whole packaging type. Components are listed within that packaging type, not assessed separately. Note: There is nuance to this, if all four components are purchased separately and then manufactured together. More in this article.
Does transport packaging need a DoC? Yes. All five packaging categories - including transport packaging - require a DoC from 12 August 2026. Pallets, corrugated shippers, mailer boxes, and pallet shrink wrap are all in scope. This is one of the most commonly missed categories.
What if the same glass jar is used with both a metal lid and a plastic lid depending on the product? These are two separate packaging types, each requiring their own DoC. The material composition differs (metal lid vs. plastic lid), so the compliance assessment will differ too.
My packaging supplier says they'll handle the DoC - is that correct? Only if their brand or trademark appears on the packaging. If your brand is on the packaging, or you influenced the design specs, you are the manufacturer under PPWR (confirmed under Art. 21 for importers and distributors) and you must issue the DoC yourself. Your supplier can provide the data and test reports that support your DoC, but the document itself is yours to sign.
How does e-commerce packaging differ from regular transport packaging? E-commerce packaging (Art. 3(1)(8)) is a sub-category of transport packaging specifically for online or distance sales deliveries - for example, the box your customer receives at home. It is subject to additional empty-space ratio requirements under Art. 24 (which apply from 1 January 2030). For 2026 compliance, the DoC requirement is the same as for other transport packaging.