PPWR Guidance provides necessary clarity, implementation must proceed without delay

The Rethink Plastic Alliance welcomes the European Commission’s publication of its Guidance on the Packaging and Packaging Waste Regulation (PPWR). We recognise the substantial effort undertaken to provide clarity and support a consistent interpretation of the Regulation across Member States. At this crucial stage, the guidance must support rapid and effective implementation. Any delay risks undermining the Regulation’s objectives, making it imperative that implementation continues without disruption and at the highest level of ambition.

We also commend the Commission for upholding the restrictions on PFAS in food contact packaging, including the requirement to exhaust existing stocks, and clarifying the stepwise methodology to test for PFAS content. This represents an important step towards reducing exposure to harmful chemicals and accelerating the transition to safer, non-toxic packaging solutions.

In addition, the Commission’s reaffirmation of the obligation to establish deposit return schemes (DRS) for single-use plastic bottles and metal beverage containers by 2029 is very positive. In particular, we welcome the confirmation that Member States must meet the Regulation’s minimum requirements if the 90% collection target is not achieved, and the clarification on retailers’ obligation to accept deposit-bearing containers, which are important to ensure effective and accessible systems across the EU.

Nevertheless, we express strong concern regarding the interpretation that plasticised paper-based packaging containing less than 5% plastic would fall outside the ban on single-use plastic packaging for indoor dining under Annex V. This approach risks opening a significant loophole, encouraging material substitution between different types of single-use plastic products, and ultimately undermining the Regulation’s waste reduction efforts. Such packaging formats are clearly defined as single-use plastic products under the Single-Use Plastics Directive (SUPD) as they contain a plastic component performing a structural function. Excluding them from the scope of the ban would therefore run counter to the Directive’s logic and the overall objectives of the Regulation.

We underline that limiting the bans in Annex V to plastic packaging already represents a significant weakening compared to the Commission’s initial PPWR proposal. Any further narrowing through interpretative guidance risks compromising the Regulation’s effectiveness and could also undermine the objectives of the SUPD – as well as the EU’s commitment to reduce marine litter by 50% by 2030 – by incentivising a shift towards alternative single-use formats that still contain plastic but evade restrictions.

Furthermore, we caution against the risk that Single Market harmonisation is misused to excessively restrict the ability of national and local authorities to go beyond EU minimum requirements on waste reduction and reuse. While harmonisation can support the PPWR’s objectives, it is only helpful if it is underpinned by sufficiently high ambition so that the Regulation’s core objectives – advancing the circular economy and delivering meaningful waste prevention – are achieved. These priorities should remain central to both interpretation and implementation. Strengthening the Single Market must not come at the expense of environmental protection, public health or the public interest; rather, it should enable a race to the top by allowing more ambitious national and local measures, particularly where they are needed to meet waste prevention targets and support reuse.

In light of the Commission’s laudable commitment to tackling Europe’s major packaging waste problem, we urge that the PPWR be implemented in a manner that preserves its ambition and integrity. Only a robust and coherent approach will provide Member States with a fair chance of meeting their legally binding waste prevention targets and ensure that Europe stays on track towards a truly circular economy.