A note from six Member States — the Czech Republic, Bulgaria, Italy, Latvia, Romania and Slovenia — submitted for the Council (Environment) meeting on 25 June 2026 warns that the Packaging and Packaging Waste Regulation (PPWR), applicable from 12 August 2026, still lacks sufficient legal clarity for implementation.
The document, dated 23 June 2026, highlights that key requirements remain undefined due to unadopted delegated and implementing acts, leaving industry without a clear compliance pathway and harmonised methodologies. Member States are already taking diverging approaches, risking single market fragmentation. Costs are estimated at approximately EUR 160 per household, with billions of euros across the EU, disproportionately affecting SMEs. Packaging labelling changes are scheduled between 2026 and 2028, but harmonised EU rules are not yet adopted, risking repeated relabelling. The six states also stress that the PPWR shall not limit Member States’ ability to maintain reporting obligations under Extended Producer Responsibility (EPR) schemes necessary for market surveillance and preventing freeriding from third countries. They call on the Commission to provide a clear timeline for all delegated and implementing acts, accelerate adoption of measures for legal certainty — including updating the Guidance and FAQs with operational explanations — and engage in structured dialogue with Member States and Market Surveillance Authorities on a common enforcement approach. Without urgent Commission action on secondary legislation and guidance, the note warns, the PPWR risks regulatory fragmentation, high costs, and disruption to the internal market, undermining its environmental goals.