The EU’s flagship regulation to promote a circular economy is under threat. “I think the European Commission is doing its best to address uncertainty in the content of the PPWR but uncertainty remains – they may decide to buy time and delay things for a year,” Gerard McElwee, an EU regulation expert at law firm Squire Patton Boggs, based in Brussels, told Just Drinks this week.
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Frequently asked questions
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What is the EU Packaging and Packaging Waste Regulation (PPWR) and why does it matter to food and drink businesses?
The PPWR is the EU’s flagship framework for reshaping packaging around a circular-economy model, with binding requirements designed to reduce waste, improve recyclability and increase reuse, while creating more consistent rules across the single market. For food and drink companies, it matters because packaging is central to product protection, shelf life, brand identity, logistics costs and customer expectations, all of which sit within complex multi-country supply chains. In practical terms, the PPWR is set to force earlier and more fundamental decisions about materials, formats and pack design. It also strengthens the direction of travel on recycled content, packaging minimisation and the principle that producers should carry more responsibility for the waste their packaging creates. The regulation is also significant politically and commercially because it has become a focal point for lobbying and for a wider debate about Europe’s competitiveness versus environmental ambition. That tension is now playing out as some businesses push for delays, while others argue postponement would penalise companies that have already invested in redesign and compliance.
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When do the key PPWR obligations start and what is driving calls for a delay?
The current flashpoint is the set of obligations due to apply from 12 August 2026. Calls for delay are being driven by what signatories describe as “legal uncertainty” and a lack of sufficiently detailed, harmonised guidance on how to demonstrate compliance in practice. Businesses are arguing that they cannot invest confidently when they believe key definitions, testing approaches and enforcement expectations could still shift or be interpreted differently between member states. Supporters of sticking to the timetable counter that the discomfort is the point: the PPWR is intended to accelerate change after years of slow progress on reuse and waste prevention. They also argue that repeated postponements distort competition by disadvantaging early movers who have already absorbed redesign and compliance costs. A delay, in their view, risks becoming a gateway to reopening the regulation itself, weakening provisions that have been positioned as world-leading.
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Why are PFAS “forever chemicals” such a contentious issue in PPWR, and what should companies be doing now?
PFAS are contentious because they sit at the intersection of public health, food contact safety, environmental persistence and regulatory credibility. These substances have been used in some food contact materials and concern is rising because of their persistence in the environment and links in research, for certain PFAS, to serious health harms. The immediate industry problem is operational: businesses fear they will be held accountable for compliance without a harmonised, legally binding EU-wide methodology for PFAS testing that works in practice across all member states.
