Executives of major groups recently wrote to the European Commission asking for more clarity on the PPWR before it comes into force in August 2026. The public debate focused on lobbying, on industrial interests, on resistance to change.
That framing is reductive. On the ground, there is also a genuine operational issue. An issue that packaging teams are living through right now, without anyone giving them a clear answer. Plastic shrink film is the most concrete example.
What Annex V says, and what it does not say
The PPWR lists, in its Annex V, the packaging formats banned from 1 January 2030. Among them is the plastic shrink film used to group bottles, cans and pots for retail sale.
So far, so legible. Where it gets complicated: the same text provides for an exemption for grouped packaging “necessary for handling”. This wording is in the regulation. It is intentional. And it comes with no operational definition.
A question still unanswered to this day: is a six-pack of water bottles held together by a plastic film “necessary for handling”? A banded multipack of cans in a supermarket? The answer governs investments of several million euros in packaging lines. It does not yet exist officially.
The European Commission published guidance on 30 March 2026, with an FAQ. That guidance cleared up a few questions on the definitions of roles and on PFAS. On shrink film, it defers to a later clarification. The announced date: February 2027.
That is three years before the ban takes effect. And after most of the industrial investment decisions for 2030 should have been taken.
What teams have to decide now
On the ground, this uncertainty is not a regulatory curiosity. It is a real decision problem. Adapting a packaging line to remove shrink film involves several trade-offs at once.
Replacement format
Wraparound cardboard, repositionable glue, clips, paper banding. Each option has different machine constraints and different performance in terms of strength, throughput and cost.
Line throughput
Plastic film is fast and cheap per unit. The alternatives change throughput, sometimes significantly depending on the format. Switching systems can reduce a line’s productivity during the run-in phase.
CAPEX and return on investment
Changing the grouping system on an existing line represents a real investment. Some lines cannot be adapted without complete replacement. The ROI calculation depends directly on the regulatory clarification.
Final recyclability of the secondary packaging
Cardboard improves the recyclability of the secondary packaging but sometimes changes the overall composition of the sales unit, with impacts on other environmental indicators and on EPR contributions.
These decisions are not easily reversible. A line modified in 2026 or 2027 to remove shrink film, if the 2027 clarification concludes that this format falls within the exemption, will have cost CAPEX needlessly. Waiting until 2027 to decide means pushing the compliance work back into very tight timeframes.
Deciding on an investment in a packaging line without knowing whether the regulatory framework will move in the meantime: that is exactly what packaging R&D teams are living through in 2026.
What it reveals about the construction of the PPWR text
Shrink film is not an isolated case. It is one example among a dozen operational ambiguities still open in the PPWR text. The structural reason is known: the regulation works in two stages.
The objectives and bans are in the main text, applicable in August 2026. The precise criteria that make it possible to know whether you are affected or not arrive in delegated acts published progressively between 2026 and 2030. It is a deliberate mechanism, designed to let the Commission adapt the technical details without reopening the regulation.
The timetable of expected clarifications:
| Date | Expected clarification |
|---|---|
| February 2027 | Definition of the Annex V exemption on shrink film |
| Early 2028 | Precise criteria for recyclability classes A to E |
| End of 2026 | Methodology for calculating recycled content |
A regulation applicable in August 2026 whose operational criteria will be published between 2027 and 2030. This is not a fundamental criticism of the PPWR. The regulation’s environmental objectives are coherent. But the mechanism of massive delegation creates real legal uncertainty for those who have to invest now to be compliant in 2030.
Practical recommendations for packaging teams
Pending the 2027 clarification, two stances are defensible.
Anticipate the restriction
Launch studies of alternatives (cardboard, glue, clips) now for the most exposed formats. Do not wait for the clarification to qualify the technical options. The aim: to be ready to decide quickly as soon as the clarification is available, without starting the technical work from scratch.
Document the reasoning
If the company considers that its use falls within the “necessary for handling” exemption, document that reasoning now. Gather the technical arguments: pack integrity, transport safety, the functional impossibility of alternatives. In the event of an inspection or dispute, this documentation will be the first thing requested.
In both cases, do not wait until 2027 to start working on the subject. Packaging development timeframes are 18 to 36 months. The 2027 clarification is not a starting point. It is a decision point.
This article is part of our series on the operational ambiguities of the PPWR. Other grey areas are analysed in our guides by department: Packaging and R&D, Legal and Compliance, Procurement.
Sources: Regulation (EU) 2025/40, Annex V and Article 25. European Commission guidance of 30 March 2026. Letter from 138 executives to the Commission, April 2026. Content provided for information purposes only; it does not constitute legal advice.
Cover photo: by Soluplast