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The\u00a0European Commission<\/a>\u2019s new\u00a0guidance document<\/a>\u00a0sets out to clarify elements of\u00a0the Packaging and Packaging Waste Regulation,\u00a0but what does the industry think? We consulted organizations and representatives to understand their views on\u00a0the confirmed deadlines, rule exemptions and restrictions, logistical feasibilities, and remaining questions.\u00a0<\/p>\n The World Packaging Organization<\/a> describes the new guidance as \u201cvaluable material\u201d<\/a> and a \u201cmust-read\u201d for packaging professionals. Meanwhile, UPM Specialty Materials<\/a> considers it a \u201clong-waited milestone<\/a> for the packaging industry\u201d.<\/p>\n \u201cSpeaking with business managers in Africa and Asia, I\u2019ve realised how most people are still underestimating what this means,\u201d says Neirin Jones, shareholder at GreenForest Solutions<\/a>. \u201cIt\u2019s quite a significant redesign of how products can be sold to Europe [\u2026] PPWR requires supply chain redesign and data disclosure infrastructure unlike ever required before.\u201d<\/p>\n Generally, the Rethink Plastic Alliance<\/a> praises the guidance as a \u201csubstantial effort\u201d<\/a> to \u201cprovide clarity and support a consistent interpretation of the Regulation across Member States.\u201d<\/p>\n In particular, it commends the European Commission for upholding requirements to exhaust existing PFAS stocks and clarifying the stepwise methodology for testing PFAS content.<\/p>\n 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 \u2013 especially the established minimum requirements if the 90% collection target is not achieved, and the responsibility for retailers to accept deposit-bearing containers.<\/p>\n Even so, it \u201cexpress[es] strong concern\u201d around the interpretation that plasticized paper-based packaging containing less than 5% plastic is exempt from Annex V\u2019s ban on single-use plastic packaging used for indoor dining \u2013 suggesting that limiting the bans to plastic packaging was already a \u201csignificant weakening\u201d of the initial PPWR proposal.<\/p>\n \u201cThis approach risks opening a significant loophole, encouraging material substitution between different types of single-use plastic products, and ultimately undermining the Regulation\u2019s waste reduction efforts,\u201d the Alliance argues.<\/p>\n \u201cSuch 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\u2019s logic and the overall objectives of the Regulation.\u201d<\/p>\n In its view, continuing to narrow the ban could undermine the effectiveness of the PPWR and the SUPD simultaneously, and threaten the EU\u2019s goal to halve marine litter by 2030.<\/p>\n Mets\u00e4 Board<\/a>\u00a0takes a different stance on the bans. Describing the guidance as \u201clong-awaited clarity for the market\u201d, it considers the 5% exemption \u2013 and the confirmation that Member States cannot introduce additional national bans for these formats under the Single-Use Plastics Directive \u2013 to be \u201cgreat news for fibre-based packaging\u201d. It also states that these measures bring \u201cmuch\u2011needed clarity for value chains and investments.\u201d<\/p>\n 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.<\/p>\n \u201cWhile harmonization can support the PPWR\u2019s objectives, it is only helpful if it is underpinned by sufficiently high ambition so that the Regulation\u2019s core objectives \u2013 advancing the circular economy and delivering meaningful waste prevention \u2013 are achieved,\u201d it says. \u201cThese priorities should remain central to both interpretation and implementation.<\/p>\n \u201cStrengthening 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.\u201d<\/p>\n Overall, the Alliance encourages \u201crapid and effective implementation\u201d of the Regulation; \u201cAny delay risks undermining the Regulation\u2019s objectives, making it imperative that implementation continues without disruption and at the highest level of ambition.\u201d<\/p>\n Martin Foe, product compliance manager EMEA at Brunswick Marine<\/a>, highlights \u201ckey gaps\u201d<\/a> in the document: the absence of a methodology to identify PFAS in food-contact packaging; uncertainty surrounding conformity assessment procedures; \u201climited guidance\u201d on recyclability criteria and performance thresholds; and \u201copen questions\u201d on reuse systems across sectors.<\/p>\n 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 \u2018producer\u2019 in transport packaging, could change mid-reporting cycle in 2026, leading to further confusion.<\/p>\n Foe also argues that the document relies heavily on upcoming delegated and implementing acts, with further clarification coming through an updated Frequently Asked Questions<\/a> document \u2013 described as a \u2018living\u2019 document that will continue to be updated over time.<\/p>\n Similarly, Alexander Reitz, Customer Development & Consulting at PreZero<\/a>, does not consider the guidance the \u201choly grail\u201d<\/a> of clarity, pointing out that future delegated acts will be \u201ccrucial\u201d in defining the technical details. He still considers it a \u201cmassive compliance headache\u201d to identify which member of the supply chain bears the responsibility of a producer in complex cross-border supply chains, and acknowledges \u201cdifficult design trade-offs\u201d related to the Regulation\u2019s weight reduction mandate and 50% empty space ratio.<\/p>\n He questions the usefulness of the guidance\u2019s recyclability timelines without secondary legislation for Design for Recycling criteria, and considers the \u201cheavy bureaucratic burden\u201d of recycled content exemptions.<\/p>\n Europen<\/a> has argued that the guidance \u201cstill 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.\u201d<\/p>\n \u201cThe risks are no longer theoretical,\u201d the statement continues; \u201cthis uncertainty is already eroding Europe\u2019s industrial competitiveness at a time when investment and innovation should be accelerating.\u201d<\/p>\n It asserts that policymakers should work alongside industry players to address \u201ccritical implementation gaps\u201d and ensure the \u201cpractical feasibility\u201d of the Regulation\u2019s obligations.<\/p>\n \u201cStill work to be done on harmonized eco-modulation framework for EPR fees based on recyclability performance grades,\u201d adds<\/a> Mark Sayers, founder and Circularity and EPR Compliance director at CircuMetrics<\/a>.<\/p>\n Matteo Squeo, founder of The Green Clause<\/a> and member of the Permanent Delegation of the Court of Justice<\/a>, the General Court and the EFTA Court<\/a>, stated<\/a>: \u201cThe honest conclusion is that the Commission has laid out a solid interpretive framework, but the hard work is still ahead.<\/p>\n \u201cWith 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.\u201d<\/p>\n Also commenting in a LinkedIn post<\/a>, Recycda summarized: \u201cWhile 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.\u201d<\/p>\n If you liked this story, you might also enjoy:<\/p>\n The ultimate guide to packaging innovation in 2026<\/a><\/p>\n Packaging and Packaging Waste Regulation: what to know in 2026<\/a><\/p>\n Everything you need to know about global packaging sustainability regulation<\/a><\/p>\n