Industry warns EC guidance on PPWR compliance does not address PFAS and recycling gaps

The European Commission (EC) has published a new guidance document to support the implementation of the EU’s Packaging and Packaging Waste Regulation (PPWR) to simplify compliance for economic actors and member states. However, industry stakeholders note the guidance does not sufficiently address recycling rules and PFAS compliance for investment decisions. 

The EC’s guidance document aims to “clarify rules where the PPWR needs further interpretation and areas where stakeholders have requested assistance,” such as when a company is considered a manufacturer or producer, as well as which items are considered packaging under the PPWR.

“The document also spells out the restrictions on single-use packaging, enforcement of the PFAS restriction in food contact packaging, and the application of reuse targets. In addition, it provides guidance on how to apply EPR for packaging and on the obligation to set up deposit and return systems,” the EC details.

However, Francesca Stevens, secretary general at The European Organisation for Packaging and the Environment (EUROPEN), tells Packaging Insights: “The PPWR’s implementation is still characterized by significant uncertainty, which is already affecting investment decisions.”

“Companies are expected to redesign products, invest in new materials, and scale recycling solutions, but the lack of regulatory clarity prevents confident long-term planning.”

Recycling and PFAS uncertainty 

Stevens says that recycling and PFAS are among the PPWR areas that are particularly challenging for companies to interpret or implement following the update.

“The new guidance introduces confusion regarding the applicability of recyclability rules, which should instead clearly be linked to the upcoming delegated acts. PFAS compliance lacks a harmonized EU testing methodology and clear conformity procedures, and no transition period exists for stocks.”

“Recycled content exemptions require extensive technical justification,” she continues. “Meanwhile, the scope of packaging restrictions under annex V remains unclear.”

“For example, the scope regarding group packaging for handling was extended by introducing bans on composite packaging, such as beverage cups and food containers, which were clearly excluded in the final text agreed by the co-legislators.”

Stevens asserts that this uncertainty is delaying and canceling investments, increasing compliance risks, and weakening the competitiveness of the EU packaging value chain.

“While the Commission’s Guidance Notice is a step forward, it largely restates existing interpretations and does not resolve the operational questions businesses need to plan and innovate effectively.”

Ensuring a smooth transition

The EC has also released an accompanying FAQ with the aim of addressing “a wide range of practical issues raised by stakeholders” since the adoption of the PPWR text last year.

“We will update the FAQ document as needed. While providing more clarity on key provisions of the new packaging rules, the guidance document and the FAQs do not replace, add to, or amend the provisions of the PPWR,” the EC indicates.

Jessika Roswall, Commissioner for Environment, Water Resilience, and a Competitive Circular Economy at the EC, comments: “I encourage all stakeholders to make use of this guidance and work together to ensure a smooth implementation of the PPWR, so we can achieve our ambitious goals and create resilience based on a competitive and sustainable footprint.”

However, EUROPEN’s Stevens argues: “The EC should move beyond general guidance and provide operational clarity to restore confidence.”

She outlines key actions to build confidence: speeding up delegated acts on recyclability and recycled content, creating a harmonized PFAS testing methodology, and issuing binding clarifications on definitions and annex V scope.

“A structured dialogue with industry and member states is also needed to ensure consistent interpretation and close implementation gaps. Without these steps, regulatory uncertainty will continue to delay investment and undermine the objectives of the PPWR.”