Led by EuroCommerce, retailers and wholesalers have urged EU Environmental Ministers to enforce a twelve-month grace period and further clarification surrounding upcoming legal deadlines under the Packaging and Packaging Waste Regulation.
Yesterday, Environmental Ministers met at the European Convention Center in Luxembourg to discuss matters such as the next steps for EU chemical policy under the REACH legislation; the risks of biodiversity loss for businesses, competitiveness and the economy, and potential economic solutions; and the challenges faced and lessons learned over the past year of EU water resilience strategy.
Retailers and wholesalers asked the ministers to agree on a ‘clear and realistic’ plan to introduce the new rules – and to avoid supply disruptions, unnecessary costs, and unintended environmental consequences through further clarification and support.
“We are just weeks away from implementation, yet key questions remain unanswered,” said Christel Delberghe, director general of EuroCommerce. “This is not sustainable. EU ministers must now provide clarity, flexibility, and a realistic transition period to avoid serious disruption across Europe’s supply chains.”
With the 12 August deadline fast approaching, the sector argues that a twelve-month transition period would give businesses and authorities time to understand, interpret, test and adapt the new rules, as well as to address unexpected challenges. It argues that this transition period should prioritize guidance and support over enforcement and punitive action.
Specifically, it asserts that clearer guidance should be provided for compliance rules surrounding the Declaration of Conformity and the implementation of PFAS restrictions. This should provide ‘clear’ and ‘practical’ pathways to compliance, and should acknowledge the diversity of contractual relationships within the supply chain.
The absence of a harmonized EU testing method for PFAS is highlighted as another priority issue. To avoid legal uncertainty and delays in issuing Declarations of Conformity, the retailers and wholesalers ask Member States to recognize the Commission guidelines and the methodology under preparation by the PFAS Task Force as a temporary reference.
They continue that reuse investment risks should be avoided through feasible requirements and exemptions. With Member States already investing in deposit return schemes, the companies caution that overlapping requirements could result in duplicated infrastructure, increased costs, inefficient resource allocation, and environmental impacts.
Food packaging transferred to a European economic operator before the 12 August should not be subject to the Regulation’s rules, they suggest. This should include empty packaging, and packaging that is later filled.
Adequate transition periods must also be ensured between the adoption and application of all future secondary legislation, the retailers and wholesalers add.
To conclude, they posit that clear, practical guidance through outstanding technical issues, realistic timelines that reflect operational supply chain constraints, and strong stakeholder consultation are important factors in ensuring a smooth transition. An enabling framework that considers technical limitations while maintaining flexible implementation is also considered to be essential.
The retailers and wholesalers urge EU institutions and Member States to work alongside businesses over the next few months to streamline the Regulation’s implementation.
Back in April, a letter was signed by multiple industry CEOs and delivered to the European Commission. It requested that the Regulation’s legal deadline to address per- and polyfluorinated alkyl substances (PFAS) by 12 August 2026 be postponed if a harmonized methodology cannot be provided, and called for a targeted review of the key provisions listed in Annex V.
The packaging industry reacted strongly to this development. Some were optimistic that boardrooms are engaging with the PPWR and acknowledged the difficulties of the incoming deadline, while others argued that brands have had plenty of notice to ensure their compliance and accused the CEOs of ‘strategic delay’.
Shortly after, a joint call signed by 200 companies asked the Commission not to reopen the text. Instead, it called for ‘timely and effective’ implementation through secondary legislation – especially as the packaging industry already contends with political tensions, shifting international trade measures, and high energy and raw material costs.
Systemiq, Eunomia, Circle Economy and the Ellen MacArthur Foundation have also led twenty-two financial investors in submitting a private letter urging the Commission not to reopen the text. While the Commission’s Impact Assessment expects the Regulation to deliver net economic savings of €53 billion if implemented in a timely fashion, the investors expect packaging-related environmental costs to rise from €6 billion in 2018 to €17 billion by 2040 if the PPWR is not implemented.
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