German industry associations including the Federation of German Industries, GemPSI and WVMetalle have signed a statement urging the European Commission to use the Omnibus proposals as a chance to simplify PPWR legislation for industrial and commercial packaging.
The simplification measures include proposals for exemptions from the Packaging and Packaging Waste Regulation (PPWR)’s reuse targets, an evaluation of the Single-Use Plastic Directive’s success, and reduced scope and postponed deadlines for EU reporting requirements. The statement from the associations specifically calls for industrial and commercial packaging to be exempted from parts of the PPWR across the areas of reuse obligations, reporting obligations for reuse, labelling with sorting pictograms, financial requirements, empty space restrictions and reduction targets.
These points are expanded on in more detail below.
Correct ‘unrealistic’ reuse targets
The document states that reuse targets in Article 29(1) to (3) of the PPWR are unrealistic, describing the required 100% quota for certain industrial and commercial packaging as ‘simply unworkable’. It adds that the requirement to achieve a quota of 40% for cross-border transports also creates ‘immense bureaucratic effort’ without offering any added ecological value.
‘Don’t penalise reusable packaging’
The associations claim that Articles 30 and 31 of the PPWR impose ‘considerable reporting obligations’ on every user of reusable industrial packaging, and that this also puts reusable systems at a disadvantage compared to single-use packaging.
Pictogram exemption
The statement notes that while pictograms help private consumers to separate waste correctly, they can be ‘superfluous and even misleading’ for trained waste management professionals. It requests that the existing exemption for transport packaging should be extended to industrial and commercial sales packaging.
‘Market logic’ instead of detailed control
When it comes to financial requirements for eco-modulation and the financing of prevention measures, the associations say this cannot be applied to industrial and commercial packaging if the producer organizes its own take-back system, in which these mechanisms don’t apply.
Legal requirements and new documentation obligations for minimum rotation rates are seen as ‘unnecessary’ as the industry already reuses packaging as often as possible when ‘technically feasible and economically viable’. Restrictions on empty space, weight and volume are also said to be unnecessary as logistics companies often minimize space on their own initiative.
Legal certainty instead of ‘a patchwork of different national rules’
Article 43 of the PPWR sets waste prevention targets for Member States, including industrial and commercial packaging by means of a cross-reference. However, the associations point out that this contradicts Recital 120, which clarifies that these reduction targets are not intended to apply to industry and commerce. They call for ‘legal certainty’ as without clear exceptions in the text of the law, they are concerned that Member States could ignore this intention.
In December last year, we examined how the Environmental Omnibus simplifies EU legislation, including the Commission’s plans to support the implementation of the PPWR with a Frequently Asked Questions document, offering guidance on application dates, reuse targets, labelling requirements, PFAS testing and other points raised in the call for evidence and bilateral exchanges.
Last month we published the ultimate guide to the PPWR in 2026, which recaps the most significant developments over the last twelve months, from official updates to industry-wide action.
If you liked this story, you might also enjoy:
The ultimate guide to packaging innovation in 2026
Packaging and Packaging Waste Regulation: what to know in 2026
Everything you need to know about global packaging sustainability regulation
No comments yet