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★Mark us as a preferred sourceThe first month of PPWR has passed, and initial experiences show that packaging companies are struggling with significant administrative burdens and regulatory chaos. A recent flash survey by the Industry Association for Paper and Foil Packaging (IPV) reveals that while the sustainability and recycling goals look promising on paper, their practical implementation is heavily hampered by unclear responsibilities and contradictory customer demands.
Flash Survey Highlights Struggles in the First Month of PPWR
The flash survey conducted by the IPV among its member companies paints a highly critical picture of the early phase following the implementation of the European Packaging and Packaging Waste Regulation. The first month of PPWR demonstrates that although many businesses had prepared thoroughly, they are now facing conflicting interpretations, continuous influxes of new customer questionnaires, and unresolved jurisdictional issues.
This situation places an especially heavy burden on medium-sized packaging manufacturers. It results in considerable additional costs and requires a vast deployment of personnel in sales, work preparation, compliance, and master data maintenance. IPV Managing Director Karsten Hunger emphasized that while the companies strongly support the goal of sustainable and circular packaging, regulations can only benefit the environment if they are understandable and applied uniformly across entire supply chains.
Four Major Problems Plaguing the Packaging Sector
According to the IPV, the current false start can be summarized into four primary issues. First, there is a highly inconsistent interpretation of definitions and roles within the supply chain. Customers, retailers, and suppliers are often unsure of their exact obligations, leading to individual requirements that frequently exceed the actual text of the regulation, justified only by internal corporate guidelines.
Second, the distinction between the roles of the producer and the manufacturer remains extremely blurred. Companies report that it is completely unclear who holds responsibility when a customer exclusively dictates the printing motifs, and who should bear the costs for modified printing images or new tools.
Third, the growing burden of proof and documentation is severely hindering daily operations. Even before an order is placed, manufacturers receive extensive conformity requests, technical documents, and massive spreadsheets. They are being asked to provide detailed information on adhesives, inks, and ingredients—data that manufacturers find irrelevant to the specific order and that goes far beyond current PPWR requirements. Some customers even refuse standardized conformity documents, demanding confirmations that anticipate potential regulations for the next two to ten years.
Fourth, these challenges lead to significantly increased costs and operational strain. ERP, article, and master data systems require extensive modifications. Several member companies have already been forced to increase their staff for certification, compliance, and sustainability to handle the flood of inquiries. Furthermore, economic disincentives are emerging: due to the complicated transfer of licensing obligations, customized printed goods might have to be replaced by neutral, unprinted packaging.
IPV Demands Rapid Clarification from the EU
To resolve this regulatory chaos, the IPV has formulated five short-term demands. They urge the European Commission and relevant authorities to provide Europe-wide, uniform, and unambiguous guidelines for typical business cases. They demand a clear and practical delimitation between producer and manufacturer roles. Furthermore, the association is calling for standardized proofs of conformity rather than individual questionnaires, clear rules for EPR (Extended Producer Responsibility) obligations, and risk-based documentation requirements. Karsten Hunger stressed that the first few weeks must serve as a warning signal and that authorities must urgently publish reliable examples for standard situations.
Is Sustainable Packaging Innovation at Risk?
Industry representatives warn against confusing bureaucratic effort with positive environmental outcomes. The IPV expects the practical implementation of the regulation to be strictly measured by whether it actually makes packaging more resource-efficient and recyclable. Claus Jung, Managing Director of Jung Verpackungen GmbH, summarized the frustration of member companies: “It just creates a lot more paperwork, which keeps many people who could otherwise have taken care of developing innovations away from meaningful work.”
FAQ
What were the experiences in the first month of PPWR for the packaging industry?
Companies reported significant regulatory chaos, contradictory customer requirements, and increased bureaucratic burdens, particularly affecting medium-sized enterprises from day one.
What are the main demands of the IPV to the European Commission?
The IPV demands uniform European guidelines, clear delimitation of producer and manufacturer roles, standardized conformity certificates, clear EPR rules, and practical, risk-based documentation.
Why might PPWR hinder sustainable innovation?
Industry experts warn that the massive increase in paperwork, certification, and compliance tasks is diverting workforce and resources away from actually developing green packaging innovations.
Sources:
For further official information on the regulation’s background, visit the European Commission’s environmental policy page and the original IPV press release.
