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No more waiting: Businesses push for clarity from the European institutions as EU packaging law applies soon

 

By Nicholas Hodac, Director General, UNESDA Soft Drinks Europe

Time is almost up for the EU Packaging and Packaging Waste Regulation to take effect on 12 August 2026. Yet, businesses still face many uncertainties over key compliance requirements. The European institutions must now take their responsibility and offer practical solutions that provide the industry with a way forward.

The European soft drinks sector remains committed to accelerating the transition to a circular economy for beverage packaging in Europe. Our sector has been proactively taking action for many years to achieve this goal. Our efforts include using fully recyclable packaging, supporting effective collection and waste management systems across the Continent to ensure high-quality recycling, increasing the use of recycled content in our packaging, and providing reusable beverage systems. The results speak for themselves:

  • UNESDA corporate members have either already achieved the objective of 100% recyclability or are close to achieving it.
  • currently, there are already 16 EU countries with a Deposit Return System (DRS) in place and more to come in the coming years thanks to the investments of our members.
  • 51.7% of the PET used in our plastic bottles was recycled PET in 2024, meaning our sector has already exceeded its 2025 target of 50% recycled PET and the mandatory EU SUPD targets for 2025 and 2030.

 

Our sector has supported the EU’s ambition to advance packaging circularity and has actively contributed to making the EU Packaging and Packaging Waste Regulation (PPWR) as practical and realistic as possible. We have since remained closely involved in its implementation phase, helping to shape clear and timely secondary legislation and guidelines for proper compliance. We have proposed workable solutions, together with other stakeholders, to address the many implementation challenges. After all this, where do we stand right now?

 

We have run out of time: It is now an operational issue

The countdown is on with just five months to go before the PPWR takes effect. Yet, businesses remain in the dark regarding several key compliance requirements. But businesses cannot afford to wait any longer. Businesses cannot afford halting operations. Businesses need legal clarity and certainty to be able to plan investments, prepare for compliance and keep their operations and their supply chain running effectively. Their competitiveness is already being undermined.

We appreciate that the PPWR Legal Notice will certainly help bring some much-needed clarity, but let’s be realistic: it is not the silver bullet, and it will not resolve all uncertainties. Many questions are likely to remain unaddressed or even not fully resolved.

 

Time to act: EU institutions must now move faster

Clearly, there is no time to lose. The European institutions must accelerate their actions and offer practical solutions that provide the industry with a way forward. It is critical that harmonised, technically sound, and ready‑to‑implement guidance is adopted without further delay. It is also crucial to provide clear and timely secondary legislation based on practical solutions to simplify unclear, or overly complex requirements. EU action is urgently needed on these provisions in particular:

 

  • PFAS ban

It is much welcomed that the forthcoming Commission Legal Notice is expected to propose a pragmatic approach for compliance with PPWR PFAS requirements. However, there is still no harmonised methodology for detecting and quantifying PFAS in food contact packaging at EU level and Member States can still decide not to follow the Commission approach, undermining Single Market harmonisation and jeopardising the free movement of goods. That’s why it is crucial to ensure formal support and approval from all Member States towards this approach. This is the only way to ensure a consistent Single Market.

 

  • Plastic grouped packaging

Guidance on single-use plastic grouped packaging is not expected before 2027. Without this guidance, our sector simply cannot make the necessary adjustments to the packaging we currently use ahead of the 2030 PPWR deadline. In fact, we already know that there will be serious supply bottlenecks, and the cost for transitioning to different solutions will be substantial (well above €2bn just for the soft drinks sector, according to recent estimates). That’s why clarity is crucial: businesses need to know which specific types of packaging will be permitted or banned to plan properly and still aim for full compliance with the PPWR. Timely guidance in the coming months is critical to giving companies the predictability they need.

 

  • Reuse

Our sector continues to recognise that reusable models play an important role in helping reduce packaging and packaging waste, as a complementary solution to existing high-performing recycling systems. The co-legislators have rightly acknowledged the need to provide guidance for national context-based exemptions where they make sense from an environmental or economic perspective. Yet, the current PPWR exemption framework does not sufficiently recognise the significant progress already made by some Member States to improve beverage packaging circularity through well-designed collection and recycling systems. With the 2030 target fast approaching, it is urgent that clear guidelines are provided. Businesses need clarity to make the right investment decisions and that means that any exemption requests must be decided in time.

 

The clock is worryingly ticking. This is not the responsibility of just one EU institution. It is for all EU institutions to realise the urgency of the situation and take their responsibility in providing regulatory clarity to address the pressing operational issue that our businesses are facing.

 

Current water challenges

We cannot deny the current water challenges our world is facing. We are experiencing increased water scarcity, with demands for safe, usable water exceeding supply in many areas, including in Europe. 

  • Freshwater use has been growing by about 1% per year since the 1980s and as water demand is expected to continue increasing at a similar rate until 2050, this will account for an increase of 20 to 30% above the current level of water use1.
  • This increase in water demand is leading to a reduction of renewable water resources of 24% per capita in Europe2
  • Around 30% of the European population lives in areas with permanent water stress and up to 70% live in areas with seasonal water stress during summer3.
  • Europe’s aquatic ecosystems are severely degraded: only 17% of protected river, lake, alluvial, and riparian habitats are in good conservation status and 90% of protected wetland habitats are classified as poor or bad4.
  • Globally, 85% of wetlands have been lost in the last 300 years, with more than 50% lost since 19905. This is particularly critical as wetlands play an important role in filtering water and removing pollutants, as well as providing shelter to wildlife and capturing carbon.

 

This situation entails severe risks for the world’s population. 

  • For the last decade, the World Economic Forum has placed water-related risks among the world’s top five in its annual Global Risks Report. 
  • Water-related disasters have also dominated the list of disasters over the past 50 years and account for 70% of all deaths related to natural disasters6.
  • Nearly 95% of infrastructure loss and damage reported between 2010 to 2019 were due to water-related disasters7
  • More frequent and intensive flooding has cost lives and livelihoods across Europe, while at the same time, more than 50% of the continent has, in recent years, been affected by extreme drought conditions, which also breed a range of negative social, economic and human outcomes8.

A situation driven by a combination of factors

The deterioration of the natural water cycle stems from a confluence of factors: growing urbanisation, growing populations, increased consumption, poor management, pollution, lack of or damaged infrastructure, and climate change.  

Agriculture was responsible for 59% of total freshwater use in Europe in 20179, while industrial and domestic uses are the main drivers of increasing water demand. Indeed, as economies industrialise, populations urbanise and water supply and sanitation systems expand. 

Additionally, rising temperatures and more extreme weather patterns are causing more droughts and flooding. Climate variability is also bringing more uncertainty as to the availability, predictability and geographical distribution of water. Water and climate change are inextricably linked. From unpredictable rainfall patterns to shrinking ice sheets, rising sea levels, floods and droughts – most impacts of climate change come down to water (UN Water).