The European Commission’s new guidance document sets out to clarify elements of the Packaging and Packaging Waste Regulation, but what does the industry think? We consulted organizations and representatives to understand their views on the confirmed deadlines, rule exemptions and restrictions, logistical feasibilities, and remaining questions.
The World Packaging Organization describes the new guidance as “valuable material” and a “must-read” for packaging professionals. Meanwhile, UPM Specialty Materials considers it a “long-waited milestone for the packaging industry”.
“Speaking with business managers in Africa and Asia, I’ve realised how most people are still underestimating what this means,” says Neirin Jones, shareholder at GreenForest Solutions. “It’s quite a significant redesign of how products can be sold to Europe […] PPWR requires supply chain redesign and data disclosure infrastructure unlike ever required before.”
Generally, the Rethink Plastic Alliance praises the guidance as a “substantial effort” to “provide clarity and support a consistent interpretation of the Regulation across Member States.”
In particular, it commends the European Commission for upholding requirements to exhaust existing PFAS stocks and clarifying the stepwise methodology for testing PFAS content.
The Alliance also supports the confirmation that Member States are required to set up deposit return schemes for single-use plastic bottles and metal beverage containers by 2029 – especially the established minimum requirements if the 90% collection target is not achieved, and the responsibility for retailers to accept deposit-bearing containers.
Even so, it “express[es] strong concern” around the interpretation that plasticized paper-based packaging containing less than 5% plastic is exempt from Annex V’s ban on single-use plastic packaging used for indoor dining – suggesting that limiting the bans to plastic packaging was already a “significant weakening” of the initial PPWR proposal.
“This approach risks opening a significant loophole, encouraging material substitution between different types of single-use plastic products, and ultimately undermining the Regulation’s waste reduction efforts,” the Alliance argues.
“Such packaging formats are clearly defined as single-use plastic products under the Single-Use Plastics Directive (SUPD) as they contain a plastic component performing a structural function. Excluding them from the scope of the ban would therefore run counter to the Directive’s logic and the overall objectives of the Regulation.”
In its view, continuing to narrow the ban could undermine the effectiveness of the PPWR and the SUPD simultaneously, and threaten the EU’s goal to halve marine litter by 2030.
Metsä Board takes a different stance on the bans. Describing the guidance as “long-awaited clarity for the market”, it considers the 5% exemption – and the confirmation that Member States cannot introduce additional national bans for these formats under the Single-Use Plastics Directive – to be “great news for fibre-based packaging”. It also states that these measures bring “much‑needed clarity for value chains and investments.”
The Rethink Plastic Alliance goes on to warn against restricting national and local authorities from exceeding minimum waste reduction and reuse requirements in the name of Single Market harmonization.
“While harmonization can support the PPWR’s objectives, it is only helpful if it is underpinned by sufficiently high ambition so that the Regulation’s core objectives – advancing the circular economy and delivering meaningful waste prevention – are achieved,” it says. “These priorities should remain central to both interpretation and implementation.
“Strengthening the Single Market must not come at the expense of environmental protection, public health or the public interest; rather, it should enable a race to the top by allowing more ambitious national and local measures, particularly where they are needed to meet waste prevention targets and support reuse.”
Overall, the Alliance encourages “rapid and effective implementation” of the Regulation; “Any delay risks undermining the Regulation’s objectives, making it imperative that implementation continues without disruption and at the highest level of ambition.”
Martin Foe, product compliance manager EMEA at Brunswick Marine, highlights “key gaps” in the document: the absence of a methodology to identify PFAS in food-contact packaging; uncertainty surrounding conformity assessment procedures; “limited guidance” on recyclability criteria and performance thresholds; and “open questions” on reuse systems across sectors.
He continues that not all uses cases are covered, and that some interpretations remain case-by-case. He points out that some definitions, such as the meaning of a ‘producer’ in transport packaging, could change mid-reporting cycle in 2026, leading to further confusion.
Foe also argues that the document relies heavily on upcoming delegated and implementing acts, with further clarification coming through an updated Frequently Asked Questions document – described as a ‘living’ document that will continue to be updated over time.
Similarly, Alexander Reitz, Customer Development & Consulting at PreZero, does not consider the guidance the “holy grail” of clarity, pointing out that future delegated acts will be “crucial” in defining the technical details. He still considers it a “massive compliance headache” to identify which member of the supply chain bears the responsibility of a producer in complex cross-border supply chains, and acknowledges “difficult design trade-offs” related to the Regulation’s weight reduction mandate and 50% empty space ratio.
He questions the usefulness of the guidance’s recyclability timelines without secondary legislation for Design for Recycling criteria, and considers the “heavy bureaucratic burden” of recycled content exemptions.
Europen has argued that the guidance “still falls short of providing the legal certainty and operational clarity businesses urgently require. As a result, investment decisions remain on hold, compliance planning is constrained, and supply chains across the Single Market face growing disruptions.”
“The risks are no longer theoretical,” the statement continues; “this uncertainty is already eroding Europe’s industrial competitiveness at a time when investment and innovation should be accelerating.”
It asserts that policymakers should work alongside industry players to address “critical implementation gaps” and ensure the “practical feasibility” of the Regulation’s obligations.
“Still work to be done on harmonized eco-modulation framework for EPR fees based on recyclability performance grades,” adds Mark Sayers, founder and Circularity and EPR Compliance director at CircuMetrics.
Matteo Squeo, founder of The Green Clause and member of the Permanent Delegation of the Court of Justice, the General Court and the EFTA Court, stated: “The honest conclusion is that the Commission has laid out a solid interpretive framework, but the hard work is still ahead.
“With five months to go, the PPWR no longer faces a question of design, but of delivery. Without clear and operational guidance, uncertainty will not simply persist, it will shape market behaviour, to the detriment of investment, competitiveness, and internal market coherence.”
Also commenting in a LinkedIn post, Recycda summarized: “While the publication marks progress, industry stakeholders stress that further dialogue between EU institutions and businesses is urgently needed to close remaining implementation gaps and enable confident investment decisions.”
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