A new European Commission guidance document aims to clarify the details of Packaging and Packaging Waste Act, but what does the industry think? We spoke with agencies and representatives to understand their views on the confirmed deadlines, the release of rules and restrictions, shipping opportunities, and remaining questions.
The World Packaging Association describes the new guidelines as “essential tools” and “must-reads” for packaging professionals. Meanwhile, UPM Specialty Materials is considered a “long-awaited interest for the packaging industry”.
Neirin Jones, who is a shareholder, says: “When I talk to business managers in Africa and Asia, I have noticed how many people still underestimate what this means. at GreenForest Solutions. “It’s a major overhaul of how products can be sold in Europe […] PPWR requires a new configuration of supply and data generation facilities like never before. ”
In general, the Rethink Plastic Alliance praises the directive as a “great effort” to “provide a clear definition and support a consistent interpretation of the Regulation in the Member States.”
In particular, it commends the European Commission for supporting the requirements to use the existing stock of PFAS and clarifying the step-by-step procedure for testing PFAS content.
The Alliance also supports the confirmation that Member States must establish deposit return schemes for single-use plastic bottles and metal drink containers by 2029 – in particular minimum requirements established if the 90% collection target is not met, and the responsibility for retailers to accept containers with a deposit.
However, it “means[es] “strong concern” around the definition that paper-based plastic packaging containing less than 5% plastic is exempt from the Annex V ban on single-use plastics used for indoor consumption – suggesting that reducing restrictions on plastic packaging was already a “significant flaw” in the original PPWR proposal.
“This approach risks opening a wide gap, encouraging material transfers between different types of single-use plastic products, and ultimately undermining the Legislation’s waste reduction efforts,” the Alliance argues.
“Such types of packaging are clearly defined as single-use plastic products under the Single-Use Plastics Directive (SUPD) as they contain a plastic component that performs a structural function. Therefore, including them in the scope of the ban would contradict the concept of the Directive and the general purpose of the Regulation.”
In its view, further reductions in the ban could undermine the performance of PPWR and SUPD at the same time, and threaten the EU’s goal of halving marine pollution by 2030.
Forest Board takes a different view on restrictions. Describing the directive as “a long-awaited clarification for the market”, it considers the 5% exemption – and the assurance that Member States will not introduce additional national restrictions for these formats under the Single-Use Plastics Directive – as “good news for fiber packaging”. It also states that these measures bring “much-needed clarification for value chains and investments.”
Rethink Plastic Alliance continues to warn against preventing national and local authorities from going beyond minimum waste reduction and recycling requirements in the name of the Single Market agreement.
“While an agreement can support the PPWR’s objectives, it is only useful if it is supported by a sufficiently high ambition so that the main objectives of the Regulation – to promote a circular economy and provide meaningful waste prevention – are achieved,” it says. “These key elements should remain central to interpretation and implementation.
“Strengthening the Single Market should not come at the expense of environmental protection, public health or the public interest; instead, it should enable the race to the top by allowing stronger national and local measures, especially where necessary to achieve the goals of waste prevention and the promotion of re-use.”
In general, the Covenant encourages the “prompt and effective implementation” of Regulation; “Any delay could undermine the objectives of the Act, making it imperative that implementation proceed without interruption and with the highest level of ambition.”
Martin Foe, product compliance manager EMEA at Brunswick Marine, highlights “significant gaps” in the document: the absence of a method to identify PFAS in food packaging; uncertainty about compliance review procedures; “relative guidance” on recycling rates and performance measures; and “open questions” about reuse systems across sectors.
He goes on to say that not all use cases are covered, and that some definitions remain. He points out that other definitions, such as the meaning of ‘manufacturer’ in transport packages, could change the mid-term reporting cycle in 2026, leading to further confusion.
Foe also argued that the document is highly dependent on future delegation actions and implementation, with further clarification coming through an updated Frequently Asked Questions document – described as a ‘living’ document that will continue to be updated over time.
Similarly, Alexander Reitz, Customer Development and Consulting at PreZero, it does not consider the guidance a “sacred ground” of clarity, it indicates that the delegation’s future actions will be “important” when explaining technical details. He still considers it a “big compliance pain” to identify which member of the supply chain bears the responsibility of the producer in complex cross-border supply chains, and he accepts the “difficult planning trade-offs” related to the order of the Control to reduce the weight and the 50% of the empty space.
He questions the importance of recycling guidelines without secondary rules for the Plans for Recycling methods, and considers the “heavy administrative burden” of the credits for recycled content.
Europen has argued that the directive “still falls short of providing the legal certainty and clarity businesses need urgently. As a result, investment decisions are being suspended, the draft agreement is being blocked, and supply chains across the Single Market are facing increasing obstacles.”
“Accidents are no longer hypothetical,” the statement continues; “this uncertainty is already undermining the competitiveness of European industry at a time when investment and innovation should be accelerating.”
It asserts that policy makers should work together with industry stakeholders to address “critical implementation gaps” and ensure the “effectiveness” of the Regulation’s obligations.
Mark Sayers, founder and director of Circularity and EPR Compliance at CircuMetrics adds: “Work still needs to be done on a coherent eco-modulation framework for EPR payments based on recycling grades.”
Matteo Squeo, founder of The Green Clause and a member of the Permanent Commission of the Court of Justice, the General Court and the EFTA Council, said: “The firm conclusion is that the Commission has drawn up a solid interpretive framework, but the hard work remains.
“After five months, PPWR no longer faces the question of planning, but of delivery. Without clear and operational guidance, the uncertainty will not continue, it will change the behavior of the market, destroy investment, competition, and the internal cohesion of the market.”
Also commenting on a LinkedIn post, Recycda summed up: “Although the publication marks progress, those involved in the industry stress that further discussions between EU institutions and businesses are urgently needed to close the remaining implementation gaps and make concrete investment decisions.”
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