PPWR: 200 Companies Tell the EU — Do Not Reopen

"Do Not Reopen the PPWR": What the Industry Coalition Letter Means for Printers and Converters

On June 3, 2026, a coalition of packaging companies and trade bodies — reported by Packaging Europe as around 200 signatories, and by other outlets as "more than 120" — sent a joint appeal to the European Commission, the Parliament and the Council with one blunt message: do not reopen Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation — and instead deliver the missing detail through secondary legislation. The letter lands roughly ten weeks before the August 12, 2026 core-compliance date, and it is the clearest signal yet to every packaging printer, label converter, importer and brand owner: the framework is staying, so the operational work cannot wait.

For converters weighing whether to keep investing in mono-material migration, recyclability testing and Declaration-of-Conformity data, the political noise of the last six weeks has been a real distraction. This article cuts through it: who wrote what, what the coalition actually wants, the economics driving the "don't reopen" camp, what remains genuinely unresolved, and what a printer or converter should do on the press and in the prepress file regardless of how Brussels settles the procedural fight.

Two Letters, Not One

Two separate appeals are being conflated in the trade press, and the distinction matters. The first, drafted in late April 2026 and widely reported in mid-May, came from the consumer-brand side: roughly 130-plus food-and-beverage companies — with names including The Coca-Cola Company, McDonald's, Burger King, Kraft Heinz, Heineken and Mondelēz reported among the signatories — asked the Commission to postpone certain deadlines until specific restrictions and definitions are resolved. Their headline asks: adjust the application date of the Article 5(5) PFAS restriction if full legal certainty and uniform application cannot be guaranteed; conduct a targeted review of the Annex V single-use restrictions; and clarify whether the plastic shrink-wrap restriction captures multipacks.

The second appeal, on June 3, was the counter-signal — coordinated by Plastics Recyclers Europe and backed by companies and associations including Amcor, Mondi, Constantia Flexibles, LyondellBasell, Aldi, IKEA, Veolia, Flexible Packaging Europe, Aluminium Closures and the Advanced Packaging Association. Its core argument: the regulation was adopted through the Ordinary Legislative Procedure with stakeholder input, a process that ensured "democratic legitimacy and technical robustness", and the "appropriate mechanism" to streamline its methodologies, definitions and requirements is secondary legislation— delegated and implementing acts plus technical guidance — "without reopening the core framework". A smooth transition into the regulation, they argue, should be the "central priority". Separately, CEFLEX, the flexible-packaging circularity initiative with more than 150 stakeholders, wrote to the Commission to oppose reopening. "CEFLEX does not support reopening or renegotiating the PPWR," said Alec Walker-Love, its communication lead. "We therefore support maintaining the PPWR framework as adopted, while calling for rapid, pragmatic and legally robust implementation through secondary legislation and technical guidance." The June appeal was not the first of its kind: a Reloop-coordinated joint call in November 2025, signed by more than 110 organisations and addressed to Executive Vice-President Stéphane Séjourné and Environment Commissioner Jessika Roswall, had already urged the Commission not to reopen the PPWR within its Environmental Simplification Package. More than 160 environmental and health groups separately wrote in May 2026 urging the Commission to hold the August date.

What the Coalition Actually Wants

This is not "keep the rules" versus "scrap the rules". Almost the entire value chain agrees the framework should stand. The disagreement is about sequencing and instrument: do you pause headline obligations until every definition is final, or hold the framework and fill the gaps via secondary legislation in parallel? The coalition and CEFLEX want the latter, and their case is explicitly economic. They point to "geopolitical tensions, evolving international trade measures, and increased cost pressures on energy and raw materials" already straining European industry — the same competitiveness backdrop the Draghi report quantified, with EU industrial electricity prices running roughly two to three times US levels and gas several times higher. Their conclusion is the opposite of the brand-owners': in a fragile environment, the worst thing for investment is to reopen a settled law.

The Economics Behind "Don't Reopen"

The most revealing part of the coalition letter is who signed it: the converters, recyclers and material suppliers who have already spent the money. Flexible Packaging Europe estimates the sector has invested more than €1 billion in R&D to meet PPWR objectives, and notes that over 95% of the flexible packaging used in Europe is also converted in Europe. That investment is visible on the shelf: Amcor's AmPrima and Liquiflex AmPrima mono-PE structures, Mondi's re/cycle portfolio (mono-PP/PE pouches certified recyclable, some with 35% post-consumer content), and Constantia Flexibles' EcoLam recyclable laminates replacing PET/ALU/PE constructions. Converters that retooled early would be penalised relative to laggards if the rules were now loosened — the stranded-investment argument, even if the letters do not use that phrase.

The recyclers' side is starker. Plastics Recyclers Europe reports that the European plastics-recycling industry — over €8.6 billion turnover, around 13.5 million tonnes of capacity, roughly 850 facilities and 30,000 jobs — suffered its sharpest decline on record in 2024, with turnover down 5.5% and close to one million tonnes of recycling capacity lost between 2023 and the end of 2025, squeezed by high energy costs and low-priced imports. The recycled-content economics are equally tight: through 2025, food-grade rPET traded at a premium of roughly €600–800 per tonne over virgin PET, pushing some brands back to the legal minimum recycled content. For recyclers, the PPWR's recyclability and recycled-content mandates are the demand signal that justifies the capacity; reopening the text would pull that signal at the worst possible moment.

The scale behind all of this: the EU generated 79.7 million tonnes of packaging waste in 2023 — 177.8 kg per inhabitant — of which paper and board made up about 40% and plastic about 20%, with only 42% of plastic packaging recycled (Eurostat). That is the gap the PPWR is designed to close, and the market converters are competing to serve.

What Is Genuinely Still Open

It would be wrong to pretend everything is settled. Several technical questions that bear directly on converters remain unresolved — and are exactly what the secondary legislation is meant to answer:

• PFAS in food-contact packaging (Article 5(5)).The August 12, 2026 ban stands, but there is still no harmonised EU test method. The Commission's March 2026 guidance set out a stepped approach — screen total fluorine first, then use pyrolysis-GC/MS to separate organic from inorganic fluorine — and the line between intentionally-added and trace-present PFAS is still contested. This is precisely where the brand-owner letter sought a delay.
• Annex V shrink wrap and multipacks. Whether the restriction on certain grouped-packaging plastics applies to multipack shrink film is unresolved. The Commission has promised clarification by February 12, 2027; industry argues that leaves only about 18 months to re-tool and that a 2035 horizon would be more realistic. Collation-shrink and transport-film converters need this pinned down to know which formats survive.
• Handling and grouped-packaging exemptions.The Czech Republic has circulated an informal non-paper asking the Commission to clarify the Annex V exemption for packaging "necessary to facilitate handling" — a sign that Member States, not just industry, may add pressure on timing.
• Recyclability design criteria (Article 6). The harmonised design-for-recycling methodology and performance grades arrive via delegated act, due by January 1, 2028, with the grade thresholds biting from 2030. The framework is known; the precise pass/fail lines are not yet final.

The Deadline Has Not Moved — and That Is the Point

Nothing in the current debate changes the dates a converter must plan around. Regulation (EU) 2025/40 entered into force in February 2025; the heavy-metals limit (lead, cadmium, mercury, hexavalent chromium, summed under 100 mg/kg) has applied since January 1, 2026; and the core obligations — Declaration of Conformity (Article 39), recyclability assessment (Article 6), minimisation (Article 10) and labelling — apply from August 12, 2026. The Commission has reinforced that timetable rather than relaxing it: it published implementation guidance and FAQs in March 2026, and Environment Commissioner Jessika Roswall has confirmed the obligations apply from August 12, 2026 and ruled out a formal postponement, while signalling that pragmatic flexibility for Member States would be handled within the existing legal framework. A live illustration of its policing role came in late May 2026, when it withdrew its detailed opinion on Germany's national packaging implementation act — clearing that law to take effect alongside the PPWR while signalling it will challenge national measures that diverge from the regulation, for example on reporting frequency.

The expensive mistake is to treat the lobbying as a reason to pause. The obligations that decide whether a carton, film, label or closure can stay on the market in 2030 — its Annex II grade, its substance profile, its recycled content, its DoC evidence — are stable. The only rational posture for a printer or converter is to keep building the data and migrating the constructions, while tracking the secondary acts for the narrow points that genuinely affect specific formats.

Action Plan for Printers and Converters

• Do not pause your compliance programme. The framework and the August 12, 2026 date are not on the table. Treat the reopening debate as background, not as a reason to delay.
• Lock down the PFAS position now.Collect supplier declarations to the molecule level on grease-resistant and release coatings, and align with the Commission's stepped total-fluorine test approach; do not bet a food-contact range on a delay the majority of the industry is actively opposing.
• Stress-test shrink-film and multipack formats against the Annex V questions, and keep a mono-material or fibre-carrier fallback ready in case the multipack scope is confirmed.
• Keep building per-SKU Declaration of Conformity data. The DoC obligation is fixed; structured, machine-readable component data is what brand-owner tenders will demand from August 2026.
• Track the secondary acts, not the headlines. Watch the Article 6 design-for-recycling delegated act and the implementing acts on PFAS testing, labelling and recycled-content calculation — that is where the operational detail actually lands.

How PPWR Connect Helps — and Why That Matters Now

The clearest lesson from the June 3 letter is that the operators who are already compliant by design are the ones defending the regulation, because they have the most to lose from delay and the most to gain from certainty. PPWR Connect exists to put any printer, converter, importer or brand owner in that position. It inventories every active construction, runs automated Annex II recyclability grading on the full material stack, tracks substance restrictions including PFAS and heavy metals, manages recycled-content evidence, and generates audit-ready Declarations of Conformity per market — and it absorbs the secondary-legislation detail as the delegated and implementing acts arrive, so your data stays current without a re-platforming exercise.

This is not theory. VEORIA and Rutherford already run PPWR solutions in production — the PPWR Connect compliance platform and the ColorLoop colour-and-material workflow — used today by packaging operators preparing for August 12, 2026. While the political debate plays out in Brussels, the practical answer for converters is the one the coalition is implicitly making: the framework is here, it is staying, and the businesses that keep building their compliance data now are the ones that will hold their job book into 2030.