200 companies have signed a joint call urging the European Commission not to reopen the Packaging and Packaging Waste Regulation – instead ensuring its ‘timely and effective’ implementation through secondary legislation.
In the letter, multiple businesses and industry associations point out that the Commission worked alongside stakeholders to adopt the Packaging and Packaging Waste Regulation through the Ordinary Legislative Procedure. This process is thought to have ensured both ‘democratic legitimacy and technical robustness’.
The signatories describe secondary legislation as the ‘appropriate mechanism’ to streamline the Regulation’s methodologies, definitions, and requirements – all without reopening the core framework.
They point out that ongoing political tensions, changes in international trade measures, and the cost of energy and raw materials are already placing strain on European industry – and that a smooth transition into the Packaging and Packaging Waste Regulation should be the ‘central priority’.
To achieve this, the signatories argue that ‘robust and evidence-based’ secondary legislation should be developed in consultation with industry and technical experts. They emphasize that the Regulation should align with current market realities and technological progress, alongside wider European policies such as the Circular Economy Action Plan and the European Green Deal.
Among the signatories are Amcor, Mondi, Constantia Flexibles, Aldi, Ikea, Plastics Recyclers Europe, Flexible Packaging Europe, Aluminium Closures, the Advanced Packaging Association, LyondellBasell, and many more.
Previously, Packaging Europe obtained a letter signed by multiple industry CEOs, requesting that the European Commission extend certain deadlines under the Packaging and Packaging Waste Regulation until their restrictions and definitions are fully ironed out.
Specifically, the signatories request that the application date for legally binding restrictions on per- and polyfluorinated alkyl substances (PFAS) be postponed if full legal certainty and uniform application cannot be guaranteed. They also ask the Commission to undertake a targeted review of Annex V’s restrictions on plastic shrink wrap and clarify whether the rules apply to multipacks.
Even so, some public commentary has characterized the discussion as pushback against implementing the rules at all, or as a call to postpone the PPWR altogether (a view that is challenged by many signatories of the original CEO letter).
In this context, Packaging Europe understands that the Circular Economy for Flexible Packaging (CEFLEX) has written to the Commission to oppose reopening or renegotiating the PPWR.
CEFLEX is a European initiative involving more than 150 stakeholders from across the flexible packaging value chain. It fosters collaboration, innovation and investment to make flexible packaging circular in Europe, aiming to improve how materials are designed, collected, sorted and recycled to replace virgin materials.
In its view, members of the flexible packaging value chain have already invested time, expertise and resources into compliance with the Regulation, including operational project and implementation activities in multiple EU Member States – and even a limited reopening of the legal text would create further uncertainty for investment, planning, and implementation at a ‘critical stage’ of the circular economy transition.
It does acknowledge that stakeholders face practical and legal uncertainties in implementing the new rules, but CEFLEX favours the introduction of ‘timely and coherent’ secondary legislation, methodology, and guidance, including clarification in ‘several areas’ of the text.
“CEFLEX does not support reopening or renegotiating the PPWR,” comments Alec Walker-Love, communication lead at CEFLEX. “That said, we recognize that stakeholders across the value chain are facing real practical and legal uncertainties as the Regulation moves towards application.
“We therefore support maintaining the PPWR framework as adopted, while calling for rapid, pragmatic and legally robust implementation through secondary legislation and technical guidance.
“We continue to remain available to provide evidence and input to help the European Commission, competent national authorities and stakeholders achieve the PPWR’s objectives.”
Other industry players also reacted to the CEO letter. There was a mix of positive and negative reactions, with some parties expressing excitement that boardrooms are engaging with the Regulation – perhaps too late, in the opinion of some.
Certain respondents cautioned that the administrative burden is spreading companies too thin and uncertainty remains; others argue that businesses are scrambling to catch up after a strategic delay, and warn that any postponements will lessen the Regulation’s impact.
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.
The letter asks the Commission to clarify Annex V’s exemption for packaging that is ‘necessary to facilitate handling’ before official guidelines are published next year. This clarification is intended to provide greater specificity and acknowledge grouped packaging solutions deemed necessary across the value chain – and could place additional political pressure on the Commission to reconsider the Regulation’s deadlines if other Member States co-sign.
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Supporting documents
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