CEOs petition EU Commission to postpone enforcement of PPWR

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Yesterday, industry CEOs sent a letter urging the European Commission to postpone the enforcement of the Packaging and Packaging Waste Regulation – to provide more time to respond to awaited clarifications on restrictions and definitions, including PFAS restrictions and plastic shrink wrap for multipacks.

In a separate development, the Czech Republic has circulated an informal non-paper requesting that the Commission clarify exemptions for packaging ‘necessary to facilitate handling’ before official guidelines are published next year.

Packaging Europe has obtained the texts of both documents. See the end of the article to download the links in PDF format.

The PPWR has long been the subject of questions and complaints. One point of concern is the lack of an agreed methodology surrounding per- and polyfluorinated alkyl substances (PFAS), including the definition of intentionally versus unintentionally added substances – despite the Regulation banning market operators from utilizing PFAS above a certain threshold as of 12^th August 2026.

Industry players have also expressed confusion as to whether the restriction on plastic shrink wrap, as listed in Annex V, applies to multipacks. While the Commission has promised to clarify the Annex by 12^th February 2027, this would leave only eighteen months for companies to invest in and implement new packaging lines. Market operators fear that they cannot fulfil demand across the supply chain on such short notice.

According to impact assessments carried out by the industry, the resultant costs could be high – not only from investment, but accelerated depreciation. Many companies say they already plan to transition into cardboard multipacks, but argue that a 2035 deadline would be more realistic.

The signatories warn that failing to harmonize these measures could further fragment the Single Market and leave companies vulnerable to enforcement action as a result of legal uncertainty.

As such, the CEOs have asked the Commission to consider the following:

If full legal certainty and uniform application cannot be guaranteed, the signatories request that policymakers adjust the application date of Article 5 (5), currently scheduled for 12^th August 2026. This postponement would allow for outstanding technical, legal, and methodological issues to be resolved, and give businesses more time to ensure their compliance with the Regulation.
The signatories also call for a targeted review of the key provisions listed in the Annex – ensuring they are proportionate, practical, enforceable, and effectively aligned with the Regulation’s goals.

Apparently, the letter was initially spearheaded by the beverage sector and its value chain, but support has since broadened. The letter has been signed by leadership of Mondelēz International, The Coca-Cola Company and bottling companies, Kraft Heinz, McDonald’s, Burger King, Heineken, and more.

Support for reopening PPWR is far from universal, with many major players absent from the signatories. Packaging Europe understands that some stakeholders are opposed to reopening the legislation as a means to address issues, while some view the status quo favourably. There is speculation that a counter-intervention may ensue in response to this letter.

Czech intervention

However, in a potentially pivotal week for PPWR, the Czech Republic has also requested that the Commission clarify Annex V’s exemption for packaging that is ‘necessary to facilitate handling’ before official guidelines are published next year. In the form of a non-paper (an informal policy document proposing resolution of a contentious issue), the text urges a clarification that would provide more specificity and acknowledge grouped packaging solutions considered necessary across the value chain.

If other Member States opted to co-sign this letter, political pressure would grow for the Commission to postpone the deadlines in question.

The ongoing discussions reflect the fact that Commission’s Directorate-General for the Environment, for all its diligent work, has struggled to resolve gaps, contradictions and missing clarity that have arisen in the text of such an ambitious and wide reaching legislation.

The action led by CEOs reflects Europen’s response to the Commission’s recently-published guidance document for the Packaging and Packaging Waste Regulation, where the organization called for “a swift, high-level dialogue between institutions and packaging industry leaders to close critical implementation gaps.”

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