EU Environmental Omnibus sparks industry debate over PPWR simplification

The European Commission (EC) has published the new Environmental Omnibus to simplify environmental legislation in the circular packaging economy, industrial emissions, and environmental assessments. 

Packaging Insights speaks to Ecosurety, the European Organisation for Packaging and the Environment (EUROPEN), and Zero Waste Europe, to explore how the Environmental Omnibus will affect the packaging industry, including the EU’s Packaging and Packaging Waste Regulation (PPWR).

Francesca Stevens, the secretary general at EUROPEN, tells us: “The Environmental Omnibus was never expected to affect the PPWR beyond removing the obligation for companies to appoint authorized legal representatives in each member state.”

Carlos De Souza, international services manager at Ecosurety, says that prior to the Omnibus, “producers faced a maze of fragmented national rules.”

“Different labeling, fee structures, and reporting formats in every market. Appointing authorized representatives in each member state added cost and complexity, while granular data demands on recyclability and material composition slowed progress. These reforms start clearing that path, paving the way for a harmonized system that supports circularity instead of bureaucracy.”

Stevens notes that this requirement was already recognized as a Single Market barrier, and the EC had planned to remove it across all waste legislation. “Companies will still have to comply with all their EPR obligations, including for reporting.” 

“Currently, the packaging industry’s focus is on a smooth implementation of PPWR, which is set to apply in just eight months from now. Companies need clarity today to plan investments, adapt supply chains, and secure full compliance within the implementation timelines.”

Weakening PPWR rules

The EC says that the changes aim to reduce the administrative burden for businesses, while keeping the EU’s “ambitious objectives” to protect the environment and human health.

Francesca Stevens, secretary general at EUROPEN.However, a spokesperson for Zero Waste Europe tells us: “With the inclusion of the PPWR in the Omnibus process, it risks reopening and potentially weakening key provisions, particularly those already highlighted by the EC in relation to the F&B sector.”

Of particular concern to Zero Waste Europe is the following EC statement: “The EC will consider in its implementing measures additional flexibilities for other packaging formats, notably where hygiene and food safety issues prevent the achievement of those targets.”

The spokesperson argues that the language in the statement “creates a tangible risk to Articles 29 and 33, concerning the ‘Re-use offer obligation for the take-away sector,’ by potentially allowing additional exemptions (while there are so many already) or delayed implementation under the pretext of hygiene and food safety.”

“In practical terms, weakening these provisions could undermine the development of standardized reusable packaging systems, reduce incentives for businesses to adopt reusable solutions, and slow the overall transition toward a truly circular packaging economy,” says Zero Waste Europe.

PFAS concerns

The Zero Waste Europe spokesperson says that enabling the use of unrecycled plastics for recycled content targets means the continuous use of virgin plastics.

“Additionally, it is important to recall that the PFAS ban established under Article 5 of the PPWR is for both intentionally and unintentionally added PFAS in food contact packaging. The EC promised to issue guidance on testing for PFAS, also to address stakeholder concerns about the current lack of standardized analytical methods.”

According to the spokesperson, one of the EC’s main suggestions is to “adjust the restriction to only intentionally added” PFAS. “We hope that the EC will not consider this suggestion for this or future proposals.” 

Zero Waste Europe also regrets that the 10% landfill target was not simplified or replaced, as it is said to drive investment toward incineration, discourage “real” waste prevention, and reward high waste generation. 

“At the same time, emissions from waste incinerators have doubled, while a significant share of what is burned is known to be recyclable or reusable. This approach penalizes frontrunners in waste reduction.”

“This approach has pushed countries, especially in Central and Eastern Europe, to invest in incineration instead of building effective separate collection and high-quality recycling systems, creating long-term lock-ins that contradict circular economy and climate goals.”

Deregulation or simplification?

Carlos De Souza, international services manager at Ecosurety.Meanwhile, Ecosurety, the UK-based environmental consultancy implementing the country’s packaging EPR, has reacted positively to the EU’s Environmental Omnibus.

“Simplification means we can focus on what truly matters, helping members design packaging for recyclability, optimize eco-modulation fees, and prepare for digital product passports,” tells us De Souza. 

He says that Ecosurety is building data-driven solutions aligned with the EU’s vision for a single market for recycled materials and a digital one-stop shop. 

“Our goal remains clear and simple: turn regulatory change into an opportunity to rid the world of unnecessary packaging and accelerate the circular economy.”

The most effective tool to meet climate goals, according to Zero Waste Europe, includes “moving up on the waste hierarchy, delaying the moment packaging becomes waste with the scale up of reuse systems and waste prevention.”

“However, the Environmental Omnibus refers to additional flexibilities for packaging where hygiene and food safety concerns may hinder compliance with the targets, while these claims have limited evidence.”

“The reuse sector, especially, needs regulatory certainty to guide future investments. Indeed, current circular economy investment volumes account for just 2% of total tracked investment, according to the Circularity Gap Report on Finance. It’s a direct threat to transition towards circularity within the packaging sector.”

EC to clarify uncertainties

Zero Waste Europe points to the potential “additional flexibilities” for the use of “unrecycled” plastics to meet recycled content requirements from Article 7 (of the PPWR), “which acts as a clear backtrack on ensuring that packaging is designed for recycling and actually being recycled.”

“At a moment when the industry is seeking support from the EC, this message delivers the opposite.”

EUROPEN’s Stevens asserts that despite the packaging industry’s commitments, the recently leaked draft PPWR Legal Notice still leaves “critical questions unanswered and, in several instances, worryingly expands beyond the legal framework and the agreement reached by the co-legislators.”

De Souza asserts that clear guidance from the EC is critical. “Without practical guidance on labelling, reuse targets, and application dates, member states risk inconsistent interpretations that undo harmonization.”

“FAQs, templates, and delegated acts must land early. Clarity isn’t just about compliance, it’s about giving businesses confidence to invest in better packaging design.”