Product Compliance Resources provided by ProductIP


Is it packaging - yes or no?

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.


Article 3 of the Packaging and Packaging Waste Directive (PPWD) 94/62/EC defines this:
'Packaging' shall mean all products made of any materials of any nature to be used for the containment, protection, handling, delivery and presentation of goods, from raw materials to processed goods, from the producer to the user or the consumer.

Packaging components and ancillary elements integrated into packaging shall be considered to be part of that packaging.

But items that form an integral part of a product and it is necessary to contain, support or preserve that product throughout its lifetime and all elements are intended to be used, consumed or disposed of together, are not packaging.


CD Jewel case

CD jewel cases are not packaging. They are intended to keep and protect CD's. They are disposed of together with the CD and part of the product.


Spindles sold with recordable CD's are packaging. They are disposed of separately. But empty CD spindles sold for storing CD's are not considered packaging but storage products.

Silica gel and RFID

Silica gel is an ancillary element and considered as part of the packaging. But RFID tags are not considered packaging according to the directive.

Storage boxes

Storage boxes sold with products are considered as integral parts of these product. Certainly if the boxes contain instructions that shall be kept with the product until end of lifetime disposal.

Cake doilies


Cake doilies sold with cake are packaging. But cake doilies sold separately without cakes are not.

Annex I of the Packaging and Packaging Waste Directive 94/62/EC contains "illustrative examples" for the definitions mentioned at the start of this Compliance Clip.

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