This Joint Industry Statement has been initiated and coordinated by the Federation of European Producers of Envelopes and Light Packaging (FEPE).
The undersigned organisations represent stakeholders from across the paper, envelope, printing, postal, mailing, direct marketing, publishing and related value chains and support the common position set out below.
Purpose
“We wish to express our shared concern regarding the lack of legal certainty surrounding the status of correspondence envelopes and other communication items under Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR), particularly as the first obligations under the Regulation become applicable on 12 August 2026.”
Outcome
On 4 August the European Commission published a Frequently Asked Questions on the PPWR regulation. Within this Definitions section you will find the following extract:
“3) Are envelopes containing letters, invoices, statements and other correspondence which serve a communication function considered to be packaging under the PPWR? NEW!
Whether an item qualifies as packaging must be assessed based on the definition of packaging set out in Article 3(1), point (1). Furthermore, Annex I to the Regulation provides an indicative list of items that are considered packaging and items that are not.
Packaging is defined in Article 3(1) of the PPWR as “an item, irrespective of the materials from which it is made, that is intended to be used by an economic operator for the containment, protection, handling, delivery or presentation of products to another economic operator or to an end user, and that can be differentiated by packaging format based on its function, material and design…”
Letters, invoices, statements and other correspondence which serve a communication function are not to be considered products for the purposes of the definition of packaging in the PPWR. Envelopes that contain these documents are not intended for “the containment, protection, handling, delivery or presentation of products”.
This is to be contrasted with empty envelopes which are intended for the containment, protection, handling, delivery or presentation of products, as well as envelopes that contain a product (such as a catalogue or magazine), both of which are to be considered packaging.
Lastly, empty envelopes that are sold in a supermarket to consumers for private use are not considered to be packaging.”
Ref: European Commission: Directorate-General for Environment, Packaging and Packaging Waste Regulation (PPWR) – Frequently asked questions, Publications Office of the European Union, 2026, https://data.europa.eu/doi/10.2779/4868962
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