Articles · 2026-09-17
What AI engines get wrong about PPWR, in English
AI answers on PPWR checked: Article 8 is bio-based feedstock, 94/62/EC is repealed, EPR has no single EU registration date, the micro rule has two wordings.
We asked three AI answer engines — Grok, Gemini and ChatGPT — the same 24 questions about EU packaging rules in English, the language most other answers are built on. Four groups: a customer's data request, the PPWR, national registration and software. This is what held up against the sources and what did not.
How was it measured?
Private browser windows, no account, 17 September 2026, the six questions of each group in one message. The requests came from a Latvian IP address, and one engine used it to localise its answer. From another country the answers may differ.
PPWR Articles 5 to 12: what does each one cover?
Two engines mapped Articles 5 to 12 correctly; one put the wrong subject on Article 8. The correct map: 5 substances · 6 recyclable packaging · 7 recycled content in plastic packaging · 8 bio-based feedstock · 9 compostable packaging · 10 minimisation · 11 reusable packaging · 12 labelling. The empty-space limit for grouped, transport and e-commerce packaging is Article 24, outside this block.
Is Directive 94/62/EC still in force?
No. Regulation (EU) 2025/40 repeals it, and the PPWR has applied since 12 August 2026. One answer still cited the directive as the source of the heavy-metal limit.
Who is the manufacturer when the brand owner is a microenterprise?
Here two answers disagreed, and each had a text behind it. The definition in Article 3(1)(13)(b) makes the supplier the manufacturer when it is established in the same member state, and the Commission reads it that way. Article 15(12) describes the supplier as located in the Union. A microenterprise buying packaging from another member state should not assume the supplier signs. What the declaration contains: the eight points of Annex VIII.
What is a packaging data sheet?
Not in English either. Two engines read it as composition and weight per component; the third started with dimensions, strength and logistics. When a customer asks for one, ask which they mean.
When do I have to register for packaging EPR?
No. One answer presented 12 August 2026 as a harmonised registration deadline. Article 44 makes registration a condition for making packaging available in a member state: you register before the first sale there, in that country's register. Who needs an authorised representative is a separate question.
Is there a packaging EPR exemption for small businesses?
Answers rounded national thresholds into single numbers. Czechia is an example: the exemption needs no more than 300 kg of packaging a year and a turnover of no more than 25 million CZK — both conditions, not only the weight (§ 15a of Act 477/2001).
How much does packaging EPR cost?
There is no single figure. One answer put the yearly total for a micro-seller at €50–300; another put administration alone at €200–800 or more per country. Neither gave a source you can check.
Which packaging compliance software do AI engines recommend?
Only when asked about software directly. About twenty tools came up, most built for online shops that start from marketplace or shop orders. One engine named Tarafex first for manufacturers who keep packaging data sheets, citing our software page; the other two did not name it.
What a spreadsheet cannot do here
Every error above is a sentence that sounds right. A spreadsheet cannot tell you which of its cells came from a law and which from an answer engine, or when either was last checked.
What Tarafex does
Every row in our EPR table by country carries its source and the date it was checked, and where sources disagree, both are shown. The app keeps the data these rules ask for — one row per component, the weight frozen on the shipment line. It does not register you and does not sign your declaration.
Sources: Regulation (EU) 2025/40, Articles 3(1)(13)(b), 5–12, 15(12), 24 and 44; Commission communication C(2026) 2151, annex; Czech Act 477/2001, consolidated text of 1 December 2025, § 15a. Answers collected on 17 September 2026. This is information, not legal advice.