‘Stop the Clock’ campaign argues that complete rules are needed before the regulation is enforced
Italian packaging association Pro Food and plastics manufacturer Unionplast have joined a petition backed by more than 500 European businesses and associations calling for the 12 August application date for the Packaging and Packaging Waste Regulation (PPWR) to be postponed by at least 24 months.
With just weeks to go before the new rules come into force, the ‘Stop the Clock’ campaign argues that implementing decrees, technical criteria, harmonised methodologies and the operational guidance needed to apply the PPWR consistently and uniformly across the European Union are still missing.
“Under these conditions, businesses are being asked to take on new obligations, prepare compliance documentation and plan investments without full knowledge of the rules they will need to meet,” Pro Food said.
The conflict lies between the compliance obligation – due to take effect within weeks – and the delay in adopting the technical tools needed to demonstrate it, risking a climate of regulatory and operational uncertainty for businesses.
The campaign does not challenge the regulation’s environmental goals. Pro Food said it shares the need to promote recycling, increase the use of secondary raw materials and reduce impacts across the packaging life cycle.
“The postponement is sought precisely to prevent a set of rules whose underlying principles are widely supported from generating – once put into practice –regulatory uncertainty, unnecessary costs and outcomes that run counter to the aims of the green transition,” it said.
Among the issues the association sid are still to be resolved are testing methodologies, the criteria for assessing packaging recyclability, and how responsibilities are divided among the various supply chain operators. Businesses are therefore being asked to certify the compliance of their products while significant parts of the implementing framework will only be defined through subsequent delegated acts, technical standards and interpretative clarifications.
“Businesses are not asking for the transition to be halted, but to be able to carry it out on the basis of complete, verifiable rules,” said Mauro Salini, president of Pro Food. “It is not reasonable to ask companies to declare conformity, change their processes and plan investments while essential elements of the implementing framework have yet to be defined. Stop the Clock is a call for responsibility and legal certainty, not a step back on sustainability.”
Moreover, Pro Food argues that the postponement is needed to give closer consideration to the effects of the restrictions set out in Article 25 and Annex V of the PPWR, which from 1 January 2030 will affect, among other things, single-use plastic packaging for fresh, unprocessed fruit and vegetables pre-packed in quantities below 1.5kg, along with certain formats used in the Horeca sector.
The association argues that these restrictions were not preceded by a specific, comparative impact assessment capable of weighing the performance of alternatives across their full life cycle. According to Pro Food, simply swapping one material for another does not automatically deliver an environmental improvement: recyclability, recycled content, transport, product protection, shelf life and food waste prevention all need to be taken into account too.
This approach is especially important for the fresh produce sector, where packaging plays an essential role during post-harvest handling, transportation, distribution and storage. Moreover, many of the formats currently in use that could be banned under the PPWR already contain percentages of post-consumer recycled material that exceed the targets the PPWR sets for 2040.
Pro Food said banning them purely on the basis of material therefore risks penalising solutions that are already aligned with circular economy principles, without demonstrating that the alternatives deliver better performance.
The need to assess the effects of restrictions in advance is also apparent from the experience with the EU’s Single-Use Plastics (SUP) Directive, which since 2019 has banned the use of certain categories of single-use plastic products such as plates, cutlery and straws. The value of EU imports from China, Turkey and India of substitute products – including paper or cellulose-pulp cups and plates and wooden cutlery – rose from approximately €290mn in 2018 to around €730mn in 2025, reaching a combined total of almost €5bn over the period.
Pro Food argued that while this data does not amount to a full assessment of the Directive’s effects, it does point to a concrete risk: namely replacing single-use products made in Europe with others imported from third countries, manufactured using alternative materials under economic conditions unattainable in Europe. Pro Food notes that this does not deliver a genuine reduction in consumption or a proven environmental benefit – while all but guaranteeing that European production is penalised without the objectives of the legislation being met.
“Before banning a solution, careful consideration needs to be given to what will replace it and under what conditions,” Salini said. “Otherwise, we risk shifting production, jobs and a good part of the environmental impact outside the European Union, without achieving the stated objectives.”
Pro Food is therefore calling for the postponement to be used to complete the delegated acts, testing methodologies and technical standards that are still missing, to clarify the obligations of the various operators, and to ensure uniform application and enforcement across all Member States. It said it is also essential to carry out comparative, performance-based impact assessments before imposing bans on specific formats, ensuring equivalent conditions and checks are applied to imported products as well.
“The goal is not to have fewer rules, but rules that are clear, consistent and capable of delivering measurable environmental results, without fragmenting the single market or undermining the competitiveness of European industry,” the association concluded.
