ELIPSO has cautioned major retailers and brands not to overstep the current legal framework of the Packaging and Packaging Waste Regulation (PPWR) by expecting suppliers to take on excessive reporting responsibilities.
As industry players prepare for the PPWR’s upcoming Declaration of Conformity (DoC) requirements, ELIPSO observes that some brands are delegating their own legal responsibilities, including detailed substance lists and recyclability ratings, onto their suppliers.
According to ELIPSO, this ‘escalation of requirements’ does not deliver any proven environmental benefit and undermines the industry as a whole. It emphasizes that DoC requirements are the responsibility of the brand owner, not the supplier – and while manufacturers must provide information on request, they are not liable for the client’s obligations.
Furthermore, several of the PPWR’s obligations will not apply until 2030, and ELIPSO argues that a ‘significant portion’ of the law’s technical requirements cannot be applied until implementing acts set out the conditions for their application.
It states the European Commission has acknowledged that some requirements are too broad to be implemented without supplementary texts – for example, the ‘A/B/C’ graded recyclability system. Until it becomes mandatory in 2030, assessments will be voluntary and based on transitional standards.
ELIPSO urges brands and retailers to avoid undermining the supply chain with ‘regulatory overreach’ – arguing that adhering to the PPWR’s set timeline is ‘the only way’ to achieve legal and industrial certainty for the entire internal market.
“At ELIPSO, we call for strict adherence to the regulatory timeline,” the trade association stated in a LinkedIn post. “Ensuring legal and industrial certainty within the Single Market requires a measured application of the legislation, in line with the timeframes set by European lawmakers.
“No excessive demands, no shortcuts. A controlled and pragmatic transition—that is what our industry needs.”
This development comes after EuroCommerce led various retailers and wholesalers in a request to introduce a twelve-month grace period and further clarity for certain legal expectations under the PPWR, including ‘clear’ and ‘practical’ compliance guidelines for the DoC and the implementation of PFAS restrictions.
ELIPSO previously signed a document calling the PPWR’s 100% reuse requirements on plastic pallet wrappings and straps for transporting products into question – arguing that they already contain post-consumer recyclate, are fully recyclable, and cannot yet be replaced by an effective alternative material. This led the European Commission to offically exempt these formats.
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