A group of eight EU member states has warned that the Packaging and Packaging Waste Regulation (PPWR) risks regulatory fragmentation, billions in costs and disruption to the internal market unless the European Commission urgently clarifies key obligations. In a note for the Council (Environment) meeting of 25 June 2026, the Czech Republic, Bulgaria, Italy, Latvia, Poland, Romania, Slovakia and Slovenia argue that the current level of clarification is insufficient to ensure legal certainty and consistent implementation across the EU.
The PPWR becomes applicable on 12 August 2026, but many delegated and implementing acts remain unadopted, leaving industry without a clear compliance pathway and harmonised methodologies. The eight member states estimate the cost increase at approximately EUR 160 per household, with costs running into billions of euros across the EU, disproportionately affecting SMEs. Specific challenges include fragmented packaging labelling requirements, with multiple changes foreseen between 2026 and 2028, and lack of clarity on PFAS testing rules. The note also stresses that the PPWR should not limit member states' ability to maintain reporting obligations under Extended Producer Responsibility (EPR) schemes necessary for market surveillance and fair competition.
The eight member states call on the European Commission to urgently provide a consolidated timeline for all relevant delegated and implementing acts, prioritise and accelerate measures essential for legal certainty—including updating the Guidance document and FAQs with operational explanations—and engage in structured dialogue with member states and national Market Surveillance Authorities on a common enforcement approach. Without such action, the signatories warn, member states are already taking diverging approaches, risking single market fragmentation and legal uncertainty for businesses and consumers alike.
EU producers and SMEs face significant compliance costs and uncertainty without clear rules, potentially disrupting investment and operations. National authorities risk inconsistent enforcement and additional administrative burdens. Consumers may bear higher costs and experience confusion from fragmented labelling. The European Commission is pressed to accelerate secondary legislation and guidance to avoid market disruption.