12 August 2026 — the European Commission has clarified how the Packaging and Packaging Waste Regulation (PPWR) applies to packaging used for dangerous goods. For companies handling dangerous goods, the key message is: the PPWR and dangerous goods legislation need to be assessed together, with ADR, ADN, or RID requirements taking precedence where a genuine conflict arises.
The PPWR is the EU’s new framework for reducing packaging waste and increasing the use of reusable and recyclable packaging. Its requirements are being introduced progressively, with the first obligations applying from 12 August 2026.
Dangerous goods rules take priority where requirements conflict
The PPWR also covers packaging used for dangerous goods. However, Article 2 establishes an important principle: where a PPWR requirement conflicts with EU rules governing the transport of dangerous goods, the dangerous goods rules take precedence.
Companies therefore need to consider the PPWR alongside:
ADR — transport of dangerous goods by road;
ADN — transport of dangerous goods by inland waterways; and
RID — transport of dangerous goods by rail.
Where these rules impose packaging requirements that are incompatible with the PPWR, the applicable dangerous goods requirements prevail.
One of the Commission’s FAQ answers concerns Article 5 of the PPWR, which restricts certain substances in packaging, including a limit of 100 mg/kg for heavy metals.
For refillable steel cylinders used to transport dangerous gases, ADR may require components made with specific copper-zinc-lead alloys, potentially resulting in lead concentrations above the PPWR threshold.
In such circumstances, the relevant ADR safety requirements take priority over the conflicting PPWR restriction.
The same principle is relevant to future PPWR requirements on recyclability, recycled content, and reuse, many of which will apply from 1 January 2030.
Where a PPWR requirement conflicts with a technical or safety requirement imposed by ADR, ADN, or RID, the dangerous goods rules prevail. This principle also applies to Limited Quantities (LQ) shipments.
The Commission has also clarified that the use of UN-approved packaging does not, by itself, exempt a company from the PPWR. Where non-dangerous goods are transported in UN-approved packaging, the PPWR requirements continue to apply.
What does this mean for companies?
Companies that manufacture, fill, import, distribute, or transport packaged products should assess the PPWR and dangerous goods requirements together where hazardous substances are involved.
In practice, companies should:
-determine whether the packaging is subject to ADR, ADN, or RID requirements;
-identify the relevant PPWR obligations;
-check whether any requirements conflict;
-document cases where dangerous goods rules require a packaging solution that differs from a PPWR requirement; and
-avoid assuming that UN-approved packaging is automatically exempt from the PPWR.