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Grouped packaging and multipacks under the PPWR

Methodology: Marek Galetka, founder of Pravano. English translation of our Slovak article, which a person approved before publication; every number, date and legal reference of the translation is checked automatically against the original.

Cross-checked as of 10 September 2026 · based on primary sources

Updated 10 September 2026. Based on the PPWR, Regulation (EU) 2025/40. An informative readiness check, not a legal service or an official audit. Original: slovenská verzia.

“Grouped packaging” (commonly a multipack) is one of the packaging formats that the PPWR defines precisely. Why does it matter? Because it is the classification of packaging into a format that determines which PPWR obligations apply to it. The same piece of cardboard can be sales packaging in one case and grouped packaging in another, and what you have to meet changes with it.

Definition under Article 3, point 6 of the PPWR

Grouped packaging (secondary packaging, the so-called multipack) means, under Article 3, point 6 of the PPWR, Regulation (EU) 2025/40, packaging conceived so as to constitute, at the point of sale, a grouping of a certain number of sales units, whether that grouping is sold as such to the end user or serves as a means to facilitate replenishing the shelves at the point of sale or to create a stock-keeping or distribution unit, and which can be removed from the product without affecting its characteristics.

A typical example: film or cardboard that combines six cans into one pack bought by the customer at once. The film can be removed and the individual cans remain intact, so it is grouped packaging, not part of the sales unit.

How it differs from the other formats

The regulation distinguishes grouped packaging from sales (consumer) packaging under Article 3, point 5, which constitutes a sales unit for the end user by itself (for example the can itself and its label), and from transport packaging, which facilitates the handling and transport of several units (for example a pallet or a shipping box). Grouped packaging sits between them: it combines several sales units into one grouping at the point of sale.

Why the classification matters

The classification into a format determines which PPWR requirements apply to the packaging. For example, the empty space limit under Article 24 applies from 1 January 2030 (or later, depending on implementing acts) to grouped packaging, transport packaging and e-commerce packaging. A wrong classification can therefore mean that a company misses an obligation that applies to its multipack or, conversely, meets a requirement that does not apply to it.

What this means for you

If you pack goods into multipacks, it pays to classify every piece of packaging in your range correctly before dealing with the individual obligations. In Slovakia, the national layer under Act No. 79/2015 Coll. comes on top (registration, records, producer responsibility organisation); more in the article on the Register of Producers and EPR registration.

This article is a general explanation, not individual legal advice. A specific overview for your company (Pravano Kompas) comes with the free check – in writing, within 2 working days.