News
15 Apr 2026

PPWR: Habemus Guidance (and FAQ)

The white smoke 

One year, one month, and seventeen days. That is roughly how long the Guidance on the Packaging and Packaging Waste Regulation (PPWR) has been in the making since the Regulation entered into force on 11 February 2025. Conclave enthusiasts reading along will appreciate that this is much longer than the average duration of a papal election over the past century. Which naturally invites the question: was the wait worthwhile? 

Those in the packaging value chain will know that, with many of the PPWR provisions applying on 12 August this year - indeed, that is less than five months away(!) - the publication of the PPWR Guidance was seen as a key milestone. Stakeholders have been looking to it for clarity on several provisions and underlying definitions, support for investments’ decisions, and to create the confidence needed for an industry that is keen on embarking a transformation journey despite the geopolitical and economic challenges that are so defining of our present times.   

Our conclusion? The Commission’s Guidance is a step, but it falls short of providing what businesses need to invest, innovate, and deliver on the Regulation’s ambitions. Critical implementation gaps remain open, including on the PFAS ban under Article 5 and on the packaging restrictions applicable from 2030. The Guidance also creates confusion regarding the application date of essential sustainability requirements, such as packaging recyclability, and provides only partial direction on definitions and conformity assessment procedures. 

The surprise 

Several fundamental questions raised by industry over the past year have been tackled not in the Guidance itself, the only act that will be published in the EU Official Journal, but in an extensive Frequently Asked Questions (FAQ) document published alongside it. The FAQ elaborates on key PPWR sustainability requirements and is in many instances anticipating aspects of the Regulation that should be addressed in secondary legislation. 

Although both documents are non-binding, the conclave analogy is not accidental. The preparation of the PPWR Guidance and FAQ was done with no formal opportunity for stakeholders to contribute to their development. This has come at the expense of their practical relevance, weakening the added value of the Expert Group on Waste, under which a dedicated group of experts, representing industry and civil society organisations, sit with Member States’ representatives and the EU Commission to support the development of secondary legislation and guidance documents foreseen under the PPWR.  

Against this background, EUROPEN has been calling for an urgent, high-level engagement between EU institutions and industry to provide the clarity required for businesses to move forward with confidence.  

WHAT DID YOU MISS?    

  • 18 March 2026: 3rd meeting of the PPWR Expert Group. 

WHAT'S NEXT?   

  • A wave of secondary legislation, from substances of concern to recycled content and reuse calculation rules.