PPWR: The clock is ticking

Time is running out.  

Muse fans will relate to the title. But we are unfortunately not hinting at the return of the famous English rock band, rather at the widespread feeling around the application of the Packaging and Packaging Waste Regulation (PPWR), set to start applying in 8 months from now, on 12 August 2026.

We want to deliver, but how?

This was the message echoed by many on the occasion of the two PPWR Expert Group meetings, held in mid-June and mid-October 2025. Created to inform and support the development of the numerous acts of secondary legislation foreseen under the PPWR, the Expert Group comprises diverse stakeholders - from industry representatives to NGOs - as well as Member States experts, and the EU Commission Service responsible for the file. The Expert Group is tasked to support the EU Commission with the development of all PPWR-related secondary legislation and guidance documents and therefore serves as a forum for the discussion of very complex technical and legal issues, from definitions to calculation methodologies and rules.

Any Christmas present?

So far, the Expert Group has discussed a number of key topics, such as the definitions of ‘packaging’, ‘manufacturer’ and ‘producer‘, all the way down to the ban on certain food contact packaging containing PFAS and reuse targets, to mention a few. However, the documents that many, in Brussels and national capitals, are awaiting ahead of the Christmas break are the Legal Notice and the Frequently Asked Questions (FAQ), which are meant to clarify provisions of the PPWR that remain open to interpretation. While a draft of the Legal Notice has been leaked, it is already raising concerns. In EUROPEN’s view, it falls short of providing the level of precision and clarity required. In several instances, it appears to go beyond the legal framework and the agreement reached by the co-legislators, leaving key elements of the Regulation ambiguous or unaddressed and ultimately jeopardising the industry’s ability to implement the PPWR swiftly and effectively.

What else is on the Christmas wish list?  

With a long list of secondary legislation expected to see the light between now and 2030, EUROPEN is wishing for the swift adoption of all implementing and delegated acts that will be essential to achieve the PPWR objectives and provide clarity to operators both within and outside the EU. Our non-exhaustive top five, certainly features the delegated acts establishing design for recycling criteria, including a mechanism to ensure that those remain at pace with innovation; the long awaited calculation rules for recycled content targets; a derogation for all single use wraps and straps currently subject to a 100% reuse targets (a draft is currently subject to a 4-week consultation); the guidelines on Annex V and related packaging bans and the implementing act mandating harmonised EU sorting instructions to consumers. Imagine when, in a few years from now, you will be able to sort all your Christmas wraps, bags and boxes in the same way everywhere in Europe, whether you spend your winter holidays eating Panettone in the Italian Alps, chasing your Galette de Roi figurine in Brussels, or tasting Roscón de Reyes in Spain.

WHAT DID YOU MISS?   

17 June 2025: 1st meeting of the PPWR Expert Group
15 October 2025: 2nd meeting of the PPWR Expert Group

WHAT'S NEXT?  

Q4 2025/ Q1 2026 (TBC): Publication of PPWR Legal Notice and FAQ document