What is grouped packaging and do I need to declare it for EPR?

Grouped packaging is secondary packaging designed to group multiple sales units together at the point of sale. Yes, you must declare it for EPR if your business first places these packaged products on a national market. From 1 January 2030 the PPWR also caps empty space in filled grouped packaging at 50%. (52 words)

For online merchants and brands distributing products, packaging compliance can quickly turn into a complex administrative task. When shipping stock to retail partners or sending products directly to consumers, you are not just dealing with the individual box or bottle that contains the product. There is often another layer of packaging that holds these individual units together on the shelf or in the warehouse, and this middle layer frequently falls under environmental regulations.

Identifying this middle layer and understanding when it triggers Extended Producer Responsibility is essential. As environmental authorities step up enforcement, businesses must categorise every piece of packaging correctly to ensure declarations are accurate and avoid penalties. Knowing the boundaries of grouped packaging ensures that your compliance declarations are accurate, your fees are minimised, and your operations remain uninterrupted.

What grouped packaging actually means

Grouped packaging, also known as secondary packaging, is a distinct category under packaging legislation. It occupies the middle tier of the packaging hierarchy, sitting between sales packaging (primary packaging) and transport packaging (tertiary packaging) (FAQ and answers regarding covered products - VANA). Under the EU Packaging and Packaging Waste Regulation (PPWR), grouped packaging is defined as packaging conceived to constitute a grouping of a certain number of sales units at the point of sale (Packaging and Packaging Waste Regulation (EU) 2025/40). This applies regardless of whether the grouping is sold as a single unit to the final consumer or used to facilitate the restocking of shelves.

The defining characteristic of grouped packaging is that it can be removed from the product without altering or affecting the product's physical characteristics. If you remove the plastic film wrap from a multi-pack of drinks, the individual cans remain perfectly intact. Under the PPWR, grouped packaging corresponds directly to what was traditionally called secondary packaging.

Grouped packaging is secondary packaging that groups sales units at the point of sale and can be removed without affecting the product's characteristics.

In global jurisdictions, the classification focuses on where the waste accumulates. For instance, in Canadian provincial stewardship programmes, such as those in Manitoba, British Columbia, and Ontario, secondary or grouped packaging is designated and obligated if it is likely to enter the home and ultimately be managed by municipal waste systems (Multi-Material Stewardship Manitoba steward guidebook). If the grouped packaging remains in a commercial warehouse, it may be excluded as industrial waste, but any secondary wrap that accompanies the goods to a residential consumer must be reported and funded.

Does this apply to me?

Yes, if your business manufactures, imports, or distributes packaged products, grouped packaging compliance almost certainly applies to you. Under the PPWR, any economic operator who fills grouped packaging or makes packaged products available on an EU Member State's territory for the first time is classified as a producer (Commission Notice - Guidance document for Regulation (EU) 2025/40 on packaging). Brand owners, importers, or online sellers shipping directly to European end users bear this responsibility.

Fulfilling these duties requires registering with national registries, reporting weights, and paying eco-modulated fees to Producer Responsibility Organisations (PROs). Triviality limits are disappearing under modern regulations. Under Verpact in the Netherlands, the declaration threshold has been removed, meaning all producers must declare their packaging, though a simplified process exists for those placing less than 10,000 kg of packaging on the market. Sweden similarly requires all producers to be affiliated with an approved PRO and register with the Swedish Environmental Protection Agency (Naturvårdsverket) before introducing packaging to the Swedish market.

Online marketplaces also have a compliance verification duty. Platforms are legally required to declare packaging on behalf of non-compliant merchants, and failing to comply can result in account blocks and restricted market access.

Which PPWR restrictions and reuse targets apply to grouped packaging, and from when?

The regulatory landscape for grouped packaging is shifting rapidly, with several hard restrictions, targets, and deadlines coming into force over the next decade. The European Union has established strict targets regarding material recycling, empty space ratios, and reuse quotas to enforce circular economy principles.

The table below outlines the specific legal deadlines and technical metrics that apply to grouped packaging under current legislation.

Member States must achieve overall recycling targets. By 31 December 2025, Member States must recycle at least 65% of all packaging waste by weight, including specific minimums of 50% for plastics, 75% for paper and cardboard, 70% for ferrous metals, and 50% for aluminium. These targets rise by 31 December 2030 to 55% for plastics, 85% for paper and cardboard, 80% for ferrous metals, and 60% for aluminium.

Common misconceptions about grouped packaging

“Grouped packaging is exempt if consumers do not buy the whole pack”

This is incorrect. Grouped packaging is defined by its presence at the point of sale, regardless of whether it is sold as a single unit or simply facilitates restocking. Even if store clerks remove the secondary wrap, the producer who first made that packaged unit available remains responsible.

“Cardboard boxes used for grouped packaging must meet reuse targets”

This is a common misunderstanding of the reuse regulations. The PPWR explicitly excludes cardboard boxes from the reusable packaging mandates that apply to transport and grouped packaging. However, other materials, such as plastic crates, must comply with the 10% reuse target by 2030.

“Because it is cardboard or paper, grouped packaging is always eco-friendly”

While paper-based packaging generally has a high recycling rate, composite grouped packaging can be highly problematic. If paperboard is laminated with plastic film or contains more than 5% plastic by weight, it is classified as composite packaging, which complicates recycling and may trigger single-use plastic restrictions.

“Sellers do not need to declare grouped packaging if they use a distributor”

This is a risky assumption. Responsibility falls on the operator who first makes the packaged product available in the specific Member State. If your distributor imports the goods, they are the producer; otherwise, if you ship directly or place them on the market first, you are liable.

5 examples of grouped packaging

Plastic wrap around a case of water bottles

Thin plastic collation film binds individual bottles into a single unit. This single-use wrap faces strict 2030 bans under Annex V if used as convenience packaging at the point of sale.

Cardboard sleeve holding yogurt pots together

Yogurt cups are often connected by a printed paperboard sleeve. This sleeve performs a marketing and grouping function, is easily removed by the consumer, and must be reported separately.

Plastic multi-pack rings

Commonly used to group beverage cans, these plastic rings are highly regulated. Under updated EU rules, they are classified as grouped packaging and face strict bans.

Printed display boxes on retail shelves

A cardboard box containing multiple products sits on a supermarket shelf to facilitate restocking and attract consumer attention. The brand owner must report its cardboard weight to the national PRO.

Reusable plastic crates for fresh fruit

Supermarkets often receive fresh produce in rigid, reusable plastic crates. These crates act as sales packaging used for transport and must comply with the 2030 reuse requirements.

Terms related to grouped packaging

The table below outlines terms from the allowed vocabulary that represent neighbouring concepts in packaging compliance.

Frequently asked questions

Do I have to declare grouped packaging if it is made of recyclable cardboard?

Yes, you must declare all packaging materials regardless of their recyclability. While cardboard is highly recyclable, you are still financially responsible for funding its collection and processing through EPR fees.

When does the 50% empty space limit apply to grouped packaging?

The 50% maximum empty space ratio applies from 1 January 2030 under Article 24(1) of the PPWR. Economic operators who fill the packaging must ensure that the void space does not exceed half of the total volume.

Is plastic shrink wrap used to group items at the point of sale banned?

Yes, single-use plastic grouped packaging used at the point of sale to encourage consumers to buy multiple items is banned from 1 January 2030. This restriction explicitly includes collation films and shrink wrap.

Who pays the EPR fees for grouped packaging?

The economic operator who first makes the packaged product available on a specific territory is responsible for paying EPR fees. This is usually the brand owner who fills the packaging or the importer.

How do I calculate the weight of composite grouped packaging?

You must report the different materials that make up the composite packaging separately on your declaration. For example, if a paperboard box has a plastic window, you must report the paper and plastic weights individually.

What are the penalties for failing to declare grouped packaging?

Penalties are set by individual Member States and must be effective, proportionate, and dissuasive. Failing to comply can result in heavy fines, product withdrawals, or being blocked from selling on online marketplaces.

Sources:

• FAQ and answers regarding covered products - VANA
• Packaging and Packaging Waste Regulation (EU) 2025/40
• Multi-Material Stewardship Manitoba steward guidebook
• NATIONAL STEWARDS GUIDEBOOK - Multi-Material Stewardship Manitoba
• Commission Notice - Guidance document for Regulation (EU) 2025/40 on packaging
• EU PPWR - Packaging and Packaging Waste Regulation - Business.gov.uk