KontorBund — Explainer What counts as packaging?
Last checked 14 August 2026
kontorbund.swelis.site/explainers/what-counts-as-packaging.html

The Library

What counts as packaging?

Last checked14 August 2026

KeeperOpen — keeper wanted

StatusDraft, two edge cases open

The rule of thumb

Does it end up in your customer's bin, and was it there to hold, protect, present or hand over the goods? If yes, it is almost certainly packaging and it counts towards what you license. That one question settles most of what people ask us.

What counts

The mistake almost everyone makes is licensing the product's own box and forgetting everything they wrapped around it. All of the following is packaging you placed on the market.

The shipping carton: The outer box the order travels in. The single most commonly forgotten item.
Tape: Paper or plastic, printed or plain.
Filler: Tissue, bubble wrap, paper padding, wood wool — anything in there to stop the contents moving.
Presentation card: The card an earring or a pendant is mounted on. It presents and holds the item.
Pouches: An organza or fabric pouch the item is handed over in.
Belly bands, paper sleeves, card tubes: All packaging, including the ones that feel more like branding than protection.
Labels and stickers applied to packaging: Applied to the packaging — address labels, seals, logo stickers closing a box.
Inner wrap or bag: The bag or wrap around the item inside the box.
Ribbon, where it holds the packaging closed: If it is doing a job — tying the box, holding the wrap — it is functioning as packaging. See the edge cases below, because decorative ribbon is less clear.

What doesn't

A thank-you card or business card, enclosed loose: It packages nothing. It is an item sitting in the box, not something holding the goods.
Small free gifts, including sticker freebies: These are products, not packaging — you gave the customer a thing. See the edge cases, because a sticker's status depends on what it is doing.
Transport packaging between businesses: Packaging moving goods business-to-business that never reaches a consumer sits outside household licensing. But the moment you use it to send to a consumer, it is shipping packaging and it counts — a pallet-delivered carton you then reuse as a mailer has changed category.

Two we haven't settled

Ribbon — decorative or functional?

Ribbon that ties a box closed is doing a packaging job. Ribbon added purely as decoration is harder to place, and we have not resolved which side it falls on.

Stickers given as a gift

A sticker sealing a box is packaging. A sheet of stickers thrown in as a free extra is a product. A single logo sticker that is neither sealing anything nor really a gift sits between the two, and we cannot currently tell you which it is.

Why these are still open — and where not to look. We have now read the Commission's FAQ, 2nd edition of August 2026 in full. It does not address either question. Its definitions section covers envelopes, tea and coffee capsules, and the sales / grouped / transport split, and nothing in it turns on whether an item is decorative. So the place these get settled is the Commission Notice of 30 March 2026, which is a different and longer document, and which nobody here has read end to end. If you have, you can close both of these for us.

One neighbouring question the FAQ does answer

A sticker you add to a box for shipment purposes — an address label, a carrier sticker, a seal — is not branding, and applying one does not make you the manufacturer of that box. That is a question about the manufacturer role rather than about what counts as packaging, and the two get confused. It does not tell you whether a free sticker sheet in the parcel is packaging.

Why the weight barely matters

It is worth keeping this in proportion. For a small shop, everything on the "counts" list adds up to a few kilos a year. Licence fees are charged by weight and material, so a few kilos costs very little — that part of the system is proportionate and it is not what closes shops.

The cost that hurts is the flat one. Per-country registration and representative fees are effectively identical whether you ship 40 kg or 40 tonnes. That is the charge with no volume threshold, and it is the reason this association exists. Being scrupulous about what counts is worth doing because it keeps you compliant — not because the tonnage is what will bankrupt you.

Sources

Thin on purpose. Most of this page is the plain reading of the packaging definition applied to things makers actually put in boxes; where that reading runs out, we have said so above rather than filled the gap.

Regulation (EU) 2025/40 (PPWR) — EUR-Lex Source for the packaging definition at Art. 3(1)(1), the sales / grouped / transport categories at Art. 3(1)(5) to (7), e-commerce packaging at (8), and the indicative lists in Annex I
European Commission — PPWR Frequently Asked Questions, 2nd edition DG ENV Unit B01, August 2026 (KH-01-26-068-EN-N). Read in full for this page. Confirms the sales / grouped / transport distinctions used above, and confirms that an envelope containing only correspondence is not packaging while one containing a product is. It does not address decorative ribbon or free stickers — checked, so that nobody repeats the search
European Commission — PPWR guidance (Commission Notice) The guidance document of 30 March 2026, distinct from the FAQ above. Not read in full by us. Now the only remaining place the ribbon and sticker questions can be settled

Help us finish this page

Two edge cases are open — decorative ribbon and stickers given as gifts — and the search for them has now been narrowed. The Commission's August FAQ has been read in full and does not answer either, so the only remaining place is the Commission Notice of 30 March 2026, which nobody here has read end to end. If you have, that is a fifteen-minute contribution that finishes this page.

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