The German Chamber of Commerce and Industry (DIHK) advocates for a more practical implementation of the new EU Packaging and Packaging Waste Regulation (PPWR). Numerous feedback from companies, two months after the PPWR's entry into force, indicates that there are still significant uncertainties in the affected sectors. According to DIHK, this is partly due to the lack of essential technical guidelines and significant bureaucratic burden, especially for cross-border activities. As a result, small businesses, in particular, are increasingly withdrawing from the internal market, according to observations from the IHK organisation.

© DIHK / Jens Schicke

Sebastian Bolay, DIHK Director for Energy, Environment and Industry: “The experiences from the initial months clearly show: companies urgently need greater legal clarity, practical transitional arrangements, and consistent harmonisation within the internal market. The economy continues to support the goal of reducing packaging waste and improving the circular economy. However, to contribute effectively, it needs a legal framework that is particularly practical for SMEs.” Currently, the PPWR does not meet this standard. “Many technical specifications remain unclear while companies are already making investment and design decisions. Small and medium-sized enterprises, in particular, risk being overwhelmed by extensive documentation, registration, and verification obligations,” Bolay added.

From DIHK’s standpoint, the PPWR must be improved in five key areas:

• Documentation and verification requirements must be simplified and assigned to companies possessing the necessary information.
• Registration, verification, and reporting obligations should be standardised across the EU and handled via an EU-wide digital one-stop shop.
• Greater legal certainty for companies must be created through timely and complete secondary legislative acts. For instance, there should generally be a minimum lead time of 12 months between the publication of technical guidelines and their mandatory application.
• Industry and trade also require longer transitional and grandfathering provisions to ensure that already produced or lawfully marketed goods can continue to be sold.
• Complete harmonisation of packaging regulations across Europe, eliminating national special rules, is essential.

A practical PPWR must combine ambitious environmental goals with clear responsibilities, proportionate obligations, and unified European digital enforcement. Companies must be able to clearly understand their roles and obligations. Only in this way can both the circular economy and the internal market be strengthened, according to the DIHK.

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The DIHK position paper can be found here in full:

DIHK Measures Paper PPWR (PDF, 61 KB) (only available in German)