Under the PPWR, packaging is any item used to contain, protect, handle, deliver or present goods — from the product's own wrapper to the pallet it ships on. It also includes single-use items designed to be filled at the point of sale (for example, a takeaway cup) and e-commerce mailers. Knowing whether an item is packaging at all is the first step; the second is knowing which of the three levels it belongs to.
The three levels
Primary (sales) packaging — the unit the end consumer buys: the retail box, bottle, blister or pouch. It is designed around a single sales unit.
Secondary (grouped) packaging — groups several sales units together, typically for shelf display or to make a multipack. Removing it does not change the product itself. The classic example is the tray-and-shrink-wrap around a case of drinks.
Tertiary (transport) packaging — protects goods during handling and transport and prevents damage: pallets, stretch wrap, edge protectors and large outer cartons. It is not sold to the consumer.
Why the level matters
The level drives the obligation. Recycled-content and recyclability rules bite hardest on primary plastic packaging; the empty-space and minimisation limits are aimed squarely at grouped, transport and e-commerce packaging. For Extended Producer Responsibility (EPR) reporting, you generally declare the weights and materials of every level you place on a national market — so misclassifying a component can under- or over-state your fees.
Borderline cases (is a gift box primary or secondary? is a divider packaging or a product part?) should be judged against the definitions in the official regulation.
