PPWR & L-BOXX
Product or Packaging? The L-BOXX in the Context of the PPWR
Why the characteristics and intended use of the L-BOXX® support its status as a product in its own right.
In connection with Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), we have considered whether the L-BOXX®, when used by our customers, should be classified as packaging within the meaning of the PPWR or as a product or component of a product system.
In our view, the product characteristics and intended use of the L-BOXX® generally support its classification as a product or as a component of a modular product system.
Basis for this classification:
The L-BOXX® is a modular system. Different L-BOXXES® can be combined and connected with one another and supplemented with inserts, accessories and other system components. Spare parts are available to support long-term use. In addition, L-BOXXES® can be purchased separately and reordered independently of any original tool configuration.
Characteristics of the L-BOXX® supporting its status as a standalone product:
- Modular system functionality
Ability to connect and combine with other L-BOXXES® and to integrate them into a comprehensive storage, organisation and transport system.
- Independent purpose of use
Long-term storage, organisation and provision of tools, accessories and work equipment, independently of any one-time delivery or sales function.
- Independent economic value
Economic value independent of the tools or products originally contained within the L-BOXX®.
- Durability and reusability
Designed for repeated and long-term use, including with changing contents; not intended to be disposed of after removal of the product originally contained within it.
- Independent marketability
The L-BOXX® can be purchased and reordered separately, with accessories and spare parts also available.
Customer-specific colours, branding and contents
In our view, the classification as a product also remains unchanged where our customers purchase L-BOXXES® in customer-specific colours and with their own branding, equip them with their tools and, where applicable, corresponding inserts or accessories, and subsequently sell them to their customers as a combined system.
The intended purpose and the manner in which the L-BOXX® is marketed by the respective party placing it on the market are decisive for the final classification.
Against this background, the L-BOXX® is to be regarded as a product in its own right or as an integral component of a modular product system and, accordingly, should not be classified as packaging within the meaning of the PPWR.
Disclaimer
The above statements reflect L-BOXX®’s current assessment of the PPWR and do not constitute a binding legal classification. The specific circumstances of each individual case must always be taken into account. An individual legal assessment therefore remains necessary.
