The IK Industrial Association for Plastics Packaging generally rates the new EU Commission guidelines on the PPWR positively, while Metal Packaging Europe (MPE) continues to express significant criticism. Both associations see progress, but are calling for additional clarifications before the regulation comes into effect in August 2026.
The guidelines published by the European Commission on the EU Packaging and Packaging Waste Regulation (PPWR) are welcomed by the IK Industrial Association for Plastic Packaging. In the association's assessment, they create more clarity in key areas, particularly regarding which actors along the supply chain bear which responsibilities.
More clarity, but questions remain unanswered
„The guidelines are a step towards greater practicality and legal certainty,“ says Dr. Martin Engelmann, CEO of the IK. „Many companies now have a little more clarity as to whether they are considered ‚producers‘ and ‚manufacturers‘ within the meaning of the PPWR. However, due to the complexity of supply chains, many questions remain open.“
The IK also positively rates the clarification regarding reuse requirements in the B2B sector. According to this, reusability depends more heavily on the respective filling good. Packaging should only fall under corresponding requirements if it serves a clear transport function beyond its protective function.
The association also sees progress in dealing with PFAS limit values. The Commission is taking a step-by-step approach as long as harmonised test methods are lacking. Packaging with a total fluorine content below 50 mg/kg is therefore considered compliant, which, according to IK, enables a practical assessment.
Criticism of detailed regulations and potential loopholes
At the same time, the IK expresses criticism on individual points. the guidelines. The association sees risks in the planned exemption for fibre-based composite packaging with a plastic content of up to 5 percent. This regulation is neither legally nor ecologically sound and could undermine the credibility of the regulation.
Metal Packaging Europe also acknowledges the Commission's communication as an important step, but criticises the lack of clarity regarding key requirements. In particular, the association continues to see significant uncertainties regarding technical documentation obligations and the handling of „Substances of Concern“ such as PFAS.
Industry warns of fragmented implementation
According to MPE's assessment, without further clarification, significant challenges can be anticipated for companies along the value chain. Unclear requirements could lead to additional complexity and uncertainty during implementation.
Furthermore, there is a risk of fragmented application of the PPWR within the EU if necessary delegated and implementing acts are not adopted in a timely manner. National regulations could continue to apply in parallel, leading to differing interpretations by authorities.
„With only five months remaining until the PPWR comes into application, the industry still lacks essential clarity on key requirements. Without further clarifications, there is a risk of a patchwork of national interpretations, creating unnecessary burdens for businesses and hindering the effective implementation of the regulation.“
Krassimira Kazashka, CEO of MPE
Request for further clarification
Both associations see the guidelines as an important interim step, but emphasises that further action is still needed. While the IK in particular refers to practical interpretation aids and guidance from national bodies, MPE calls for additional clarifications from the EU Commission and more intensive dialogue with the industry.
Looking at the application launch of the PPWR on 12 August 2026, it remains crucial from the industry's perspective that open questions are clarified promptly to ensure uniform implementation across the European internal market.
Sources: IK, MPE
