As reported by Packaging Europe, the European Commission announced on 8 July 2026 that it has taken legal action against 14 EU Member States for failing to meet binding waste recycling targets. The action covers failures under both the Waste Framework Directive and the Packaging and Packaging Waste Directive (PPWD), the predecessor to the PPWR. The announcement is part of the Commission’s July 2026 infringement package and it came just weeks before the PPWR became applicable.
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Which Countries are Affected
On recycling targets, Bulgaria, Czechia, Germany, Greece, Spain, Croatia, Cyprus, Hungary, Malta, Poland, Portugal and Romania have all received formal notices or reasoned opinions for failing to prepare 50 % of municipal waste for reuse and recycling by the 2020 deadline set under the amended Waste Framework Directive. Several of these countries also failed to meet the packaging-specific recycling rates set by the Packaging and Packaging Waste Directive for categories including glass (60 %), paper and cardboard (60 %), metals (50 %), plastics (22.5 %) and wood (15 %), which had a deadline of 31 December 2008. This means that the non-compliance in question has, in some cases, been running for nearly two decades.
Seven member states missed packaging-specific recycling targets for the reporting years 2020–2023. Most failed on glass (Croatia, Cyprus, Portugal, Greece, Romania, Hungary), while Croatia and Malta also missed targets for metals, paper or total packaging.
Slovakia and the Single-Use Plastics Directive
Separately, Slovakia received a reasoned opinion for failing to correctly transpose parts of the Single-Use Plastics Directive, particularly regarding extended producer responsibility schemes, with the Commission identifying a series of gaps in the Slovak implementation. Tobacco producers are not obliged under Slovak law to pay for waste collection. Producers of food and beverage containers, cups, lightweight plastic bags and other SUP items are not required to cover transport and treatment costs. Slovak rules also lack provisions for litter cleanup costs. A formal notice was sent in May 2025 and Slovakia indicated it would amend its legislation, but the changes have not been enacted.
The Broader Pattern
Τhis is not the first time the Commission has taken such action. In 2024, it opened infringement proceedings against all 27 member states for missing collection and recycling targets, and against 17 member states for incorrect waste sorting labelling and recyclable materials ending up in landfill. More recently, it opened proceedings against 20 member states for failing to transpose the Directive on Empowering Consumers for the Green Transition into national law, which must be applied from 27 September 2026. The overall picture shows a Commission pursuing non-compliance simultaneously across packaging, waste, labelling and sustainability legislation and at a pace that leaves little room for inaction.
The France case, which we covered previously, is running in parallel. France has been referred to the Court of Justice of the European Union over its mandatory Triman sorting logo, a case that sits at the intersection of packaging labelling and internal market obligations.
What the Infringement Process Involves
The EU infringement procedure operates in three stages. A letter of formal notice is the first step, giving the member state two months to respond. If the response is unsatisfactory, the Commission issues a reasoned opinion, a more formal statement of the alleged breach, which again gives the member state two months to act. If the matter remains unresolved, the Commission can refer the case to the Court of Justice of the European Union. Financial penalties can follow a Court ruling.
Germany and Finland are among the countries currently at the letter of formal notice stage, while a larger group including Greece, Bulgaria, Czechia, Spain, Croatia, Cyprus, Hungary, Malta, Poland, Portugal and Romania have already received reasoned opinions, meaning they are further along in the procedure and closer to potential Court referral.
Relevance for Packaging Producers
Infringement proceedings against member states do not directly create obligations for businesses, but they carry indirect significance. On one hand, they signal which aspects of waste and packaging legislation the Commission is prioritizing. On the other, they pressure national governments to accelerate implementation (EPR scheme design, labelling requirements, fee structures), which can lead to new or tighter obligations for producers.
For companies active in the affected markets, particularly in Bulgaria, Croatia, Hungary, Malta, Poland, Romania or Spain, it is worth monitoring how national legislation evolves as a result of these proceedings.
Conclusion
Fourteen member states in infringement proceedings over waste recycling is a clear signal that the Commission is taking non-compliance seriously. With the PPWR now applicable since 12 August 2026 and waste prevention targets reaching 15 % by 2040, the pressure on member states is set to intensify.
