Pro Food, Unionplast and their member companies have signed and are promoting the "Stop the Clock" appeal addressed to the European institutions, calling for a postponement of at least 24 months of the general application date of the European Packaging and Packaging Waste Regulation (PPWR), currently set for 12 August 2026.
The reasons behind the request
With only a few weeks remaining before the Regulation becomes applicable, implementing acts, technical criteria, harmonised methodologies and operational guidance essential for the consistent application of the PPWR across the European Union are still missing.
As a result, companies are being required to comply with new obligations, prepare conformity documentation and plan investments without having full knowledge of the rules they will ultimately have to meet. The issue lies in the gap between the imminent compliance deadline and the delayed adoption of the technical tools needed to demonstrate compliance, creating a situation of regulatory and operational uncertainty for businesses.
The request for a "Stop the Clock" does not question the environmental objectives of the Regulation. On the contrary, the postponement is intended to ensure that a regulation whose principles are widely shared does not, in practice, generate legal uncertainty, unnecessary costs and outcomes contrary to the objectives of the green transition.
"The Stop the Clock initiative is a call for responsibility and legal certainty, not a step backwards on sustainability," said Mauro Salini, President of Pro Food.
The critical issues identified by Pro Food
Among the unresolved issues are testing methodologies, criteria for assessing packaging recyclability and the allocation of responsibilities among the different operators in the value chain. Companies are therefore expected to certify the compliance of their products while significant parts of the implementing framework will only be defined through future delegated acts, technical standards and interpretative guidance.
According to Pro Food, the postponement is also necessary to assess the impact of the restrictions set out in Article 25 and Annex V of the PPWR, which from 1 January 2030 will apply, among other things, to single-use plastic packaging for fresh, unprocessed and pre-packed fruit and vegetables weighing less than 1.5 kg, as well as to certain packaging formats used in the HORECA sector.
These restrictions were not preceded by a specific comparative impact assessment capable of evaluating the performance of alternative solutions throughout their entire life cycle. According to Pro Food, simply replacing one material with another does not automatically deliver environmental benefits. Factors such as recyclability, recycled content, transportation, product protection, shelf life and food waste prevention must also be taken into account.
This approach is particularly important for the fruit and vegetable sector, where packaging plays a crucial role throughout processing, transportation, distribution and product preservation. Moreover, many of the packaging formats that could be banned under the PPWR already contain post-consumer recycled content at levels exceeding the targets established by the Regulation for 2040. Banning them solely on the basis of the material used risks penalising solutions that are already aligned with circular economy principles, without demonstrating that alternative materials would deliver better overall environmental performance.
What the SUP Directive has taught us
The need to carefully assess the consequences of restrictions is also highlighted by the experience of the Single-Use Plastics (SUP) Directive, which since 2019 has banned several categories of single-use plastic products, including plates, cutlery and straws.
The value of European Union imports from China, Turkey and India of substitute products, such as paper or moulded fibre cups and plates, and wooden cutlery, increased from approximately €290 million in 2018 to around €730 million in 2025, reaching a cumulative value of almost €5 billion over the period.
"Before banning one solution, we must carefully assess what will replace it and under what conditions" - Salini concluded. "Otherwise, we risk shifting production, employment and a significant share of environmental impacts outside the European Union, without achieving the stated objectives."
