With the PPWR just a few months away from fully coming into force, organisations across the packaging value chain are working to understand how they can be compliant. We spoke with three partners at multinational law firm Eversheds Sutherland – Annamaria Tothova, Monika Zejden-Erdmann, and Dominique Strieder – to discuss potential areas of legal disputes, specific compliance issues, and how companies can deal with remaining uncertainty.
To start things off – please could you give us your general opinions on the PPWR? What is its most important strength and its biggest weakness?
AT: PPWR is a revolutionary regulation that affects a wide range of stakeholders who already have been subject to numerous packaging-related obligations. In my view, its greatest strength lies now in its ambition to harmonize these obligations across Europe and to place a strong emphasis on environmental protection.
At this stage, however, the lack of clarity around certain obligations, many of which often depend on the timely adoption of delegated acts, are leading to notable challenges such as very short, implementation deadlines.
Are there any specific areas of the regulation that you think could become the subject of legal disputes or enforcement measures from the EU?
MZE: It is not straightforward to predict what the initial focus of enforcement in the EU will be, or which aspects of the new measures will prove most contentious in practice. To a large extent, this will only become clear over time as the regime is applied, since the practical realities of compliance need to be tested.
With that being said, complex supply chains are likely to be a key source of friction. While the bulk of regulatory obligations under the PPWR rest with the manufacturer, other actors in the supply chain - such as importers and distributors - also bear certain compliance responsibilities.
This shared (and sometimes overlapping) allocation of obligations is likely to give rise to private contractual disputes.
In terms of enforcement, greenwashing is likely to remain top of the agenda. We would expect a key focus area for EU regulators to be businesses making broad, vague, or unsubstantiated sustainability claims in relation to their packaging recyclability.
We would also anticipate that enforcement efforts may target high profile cases, with regulators seeking to make examples of large, EU wide manufacturers in order to drive broader market compliance.
Technical documentation, scope three-related data, and strong governance will clearly be central to successful PPWR compliance. In your view, what can companies do to ensure they’re getting these things right?
MZE: The businesses best positioned for PPWR compliance will be those that treat the regulation not as a narrow packaging engineering exercise, but as a driver for holistic restructuring of their supply chains, internal systems, and corporate governance.
The PPWR (along other similar EU initiatives in the ESG space) demands substantive changes to how businesses have traditionally operated in their respective markets, and the best results will likely come from viewing compliance as a cross‑functional project.
Embedding PPWR obligations within broader sustainability efforts, establishing clear ownership and support mechanisms, and integrating requirements across data, processes and systems, and governance structures will be key. Companies that adopt this coordinated and organisation-wide approach will be well equipped to demonstrate compliance with the PPWR.
One of the central goals of the regulation is to increase harmony across the bloc, but do you think the PPWR leaves any room for continued divergence between different countries?
DS: One of the key objectives of PPWR is indeed harmonization. However, currently, we do not see complete harmonization. In part, this may be due to continued uncertainty about requirements and obligations under PPWR (e.g. interpretation of terms) – resulting in drawing from existing experiences and interpretation under existing regimes.
Also, it is likely that there will be different enforcement levels across members states (as well as differing priorities) – also resulting in different standards and levels of application.
What are some of the most common PPWR-related compliance concerns that companies are coming to you with?
DS: Currently, the key concerns are about the regime’s complexity and the need to interpret certain provisions and definitions (without the availability of binding legal precedence). Another, more operational aspect relates to the collection of data, incl. legal certainty in relation to verification of the data and reliance on the information obtained from suppliers.
If you were advising a packaging company or brand today, what would you identify as the single most important action they could take before the PPWR comes fully into force in August?
AT: The most important thing now is not to wait any longer. Packaging companies and brands must assess their current packaging in terms of size, weight, reusability, material content and composition, recyclability, and so on, and determine as soon as possible what this packaging might look like in the future, or whether it can even be placed on the market at all. It is essential to communicate the need for packaging changes throughout the entire supply chain and to establish appropriate processes.
Disclaimer: This article is for informational purposes only and does not constitute legal advice.
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