By Delphine Close, Senior Public Affairs Manager, UNESDA Soft Drinks Europe
The recent consultation on simplifying EU environmental legislation drew participation from a wide range of stakeholders – including industry, NGOs and national authorities – and gathered nearly 200,000 responses. The European Commission now faces the critical task of reviewing this feedback and translating it into meaningful reform. Europe is a leader in sustainability and circularity, backed by ambitious legislative frameworks. However, these frameworks have become too complex, too fragmented, and too burdensome – hindering innovation and undermining competitiveness instead of driving them forward. The need for simplification is not just a technical issue – it is a strategic imperative for Europe’s competitiveness, innovation, and circular transition.
The EU Competitiveness Compass rightly acknowledged that regulatory complexity is increasingly holding back Europe’s economic dynamism. We urgently need a legislative framework that is simpler, lighter, and faster – and this can absolutely be achieved without compromising Europe’s environmental ambition.
The European soft drinks sector fully supports the goals of EU environmental legislation but we see firsthand how implementation challenges undermine those very goals. If rules are unclear, overlapping, or delayed, businesses struggle to comply efficiently – and the environment does not benefit either.
Clarity First: Simplifying the Rules
New legislative initiatives must prioritise clarity and coherence. Today’s environmental laws contain various vague provisions. Take Article 29 of the Packaging and Packaging Waste Regulation (PPWR): the exemption mechanisms from the reuse targets are too vague or generic to guide meaningful investment.
The criteria for exemptions – particularly the reference to recycling rates ‘per material’ – risk penalising highly recycled formats like PET bottles or aluminium cans by lumping them into broader categories such as ‘plastics’. This undermines the complementarity between reuse and efficient collection and recycling systems, such as Deposit Return Systems (DRS). With consistently high collection and recycling rates across Europe, DRS have become a benchmark for effective beverage packaging recovery.
Moreover, while the PPWR allows for further exemptions based on economic or environmental constraints, it offers no timeline or clarity on how these would be developed.
Timely Guidance: Coherent Secondary Legislation
Legal certainty is essential for compliance. Yet, too often, targets are adopted without the necessary measurement methodologies or guidelines. Article 25 of the PPWR bans certain packaging types by 2030 but fails to define key exemptions, leaving industries guessing what ‘necessary to facilitate handling’ actually means. This lack of clarity delays innovation and risks non-compliance.
Similarly, while the Single-Use Plastics Directive (SUPD)’s first recycled content targets (Article 6) are set for 2025, the implementing act defining how to calculate recycled content remains under review, and no reporting template has been provided to economic operators. To address this, the Commission must not only prioritise timely guidance but also invest in the resources and capacity needed to deliver it effectively.
Avoiding Duplication: One Target, One Timeline, One Method
Duplication in reporting and legal requirements is another growing concern. For example, both the EU SUPD and the PPWR set a 90% collection target for beverage containers but assess compliance using different timelines. The SUPD uses 2029 data, while the PPWR is said to rely on mid-2027 figures. This inconsistency creates regulatory uncertainty and risks pushing Member States to upgrade infrastructure on an unrealistic timeline. A unified reporting format and timeline would go a long way toward restoring coherence.
The issue extends beyond collection targets and timelines. The SUPD mandates recycled content levels in beverage bottles, calculated as an average per Member State. However, the PPWR – which will take over from the SUPD in 2030 – introduces a different method, requiring calculations per format, type, and manufacturing plant. This shift forces businesses to rethink their production and reporting systems just a few years after the first methodology was adopted.
Regulatory Readiness: PFAS and Testing Gaps
The PPWR restrictions for PFAS in food contact materials are set for August 2026, yet there is no agreed EU method to measure PFAS levels. This disconnect leaves industry without a reliable compliance pathway. Developing test methods before implementation, and allowing for stock exhaustion, would be a pragmatic step toward ensuring regulatory clarity and a smoother transition for affected sectors.
As we look ahead, it is understood that the Commission is preparing an omnibus environmental proposal by the end of the year. But with so much feedback to digest, we must ask: how will the Commission find the time to carefully review all input and develop a proposal that truly reflects the need for simplification?
The stakes are high. If we get this right, we can unlock innovation, strengthen competitiveness, and accelerate the circular transition.
It is time to make better regulation a reality – not just a principle.
