With the Packaging and Packaging Waste Regulation close to its August 2026 application date, a coalition of approximately 200 companies and trade organizations, has sent a joint letter to the European Commission urging it to refrain from reopening it for revision, Packaging Europe reports. The letter calls for the regulation’s prompt and effective implementation through secondary legislation rather than any structural revision to the text itself.
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The statement arrives in a context of considerable tension around the PPWR. This letter represents a direct counterpoint to a separate communication sent to EU institutions in late April, in which industry CEOs called for a postponement of certain provisions and a targeted legislative review, a development we previously covered.
The Case for Stability
The coalition’s argument rests on the democratic and technical legitimacy of the process through which the PPWR was adopted. The regulation passed through the Ordinary Legislative Procedure with extensive stakeholder consultation and the signatories consider that process to have produced both a sound legal framework and a commercially workable outcome. Reopening the regulation, they argue, would create further uncertainty at a time when European industry is already navigating elevated energy costs, supply chain disruption and shifting global trade conditions.
The signatories include companies from across the packaging value chain, from raw material producers and converters to retailers and brand owners. This reflects the breadth of businesses that have already begun adapting their operations to meet the PPWR’s requirements. For many of them, the investment in compliance infrastructure, reformulation and supply chain documentation is already underway or complete.
The letter specifically addresses the appropriate role of secondary legislation, the implementing acts and delegated acts that the Commission is empowered to adopt under the PPWR’s framework. These acts can refine methods, clarify definitions and set technical requirements within the bounds of the regulation without amending its core structure. The coalition’s position is that this is the correct instrument for addressing outstanding technical questions, not a reopening of the primary legislation.
The Counter-Pressure: CEO Letter and PFAS Concerns
The coalition’s statement is a direct response to a separate letter sent to EU institutions in late April 2026, in which a group of industry CEOs called on the Commission to postpone certain PPWR provisions and initiate a targeted review of key requirements. That letter cited two specific concerns: the absence of an agreed methodology for PFAS compliance under Article 5, including the definition of intentionally versus unintentionally added substances and uncertainty over whether the Annex V restriction on plastic shrink wrap applies to multipacks. On the latter point, the Commission has committed to clarifying Annex V by February 2027, leaving, according to CEOs, insufficient time for companies to invest in new packaging lines before being expected to comply.
The letter was interpreted as a demand to delay the entire PPWR, a reading that several of its original signatories subsequently disputed. The 200-company coalition’s letter appears in part designed to counter that interpretation and to signal to the Commission that a substantial part of the packaging industry wants implementation to proceed on schedule.
Conclusion
The competing industry letters reflect a packaging sector that is genuinely divided over how to approach the PPWR’s August 2026 application date, over whether the technical framework for compliance is sufficiently clear. The Commission now faces a difficult balancing act: on one side, a substantial coalition of businesses that have already invested in compliance and want the stability of a fixed regulatory framework; on the other, operators with specific, concrete concerns about PFAS methodology and Annex V that remain unresolved. How the Commission responds will set the tone for PPWR implementation across all member states.
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