PPWR: why a “stop the clock” makes sense

A request that can work

For ProFood, the most credible path is not to ask for a general stop of the entire PPWR. It is more defensible to request a targeted “stop the clock”: suspend/postpone the Article 25 and Annex V bans until the Commission has (i) completed a comparative, performance-based impact assessment covering end-of-life, food protection and food waste, alternatives and costs, including (a) what the market would switch to and whether this would mean more imports, and (b) whether the rules can be checked and enforced equally for EU and imported packaging and (ii) published implementable Article 25(6) Guidelines (due by 12 February 2027 which should be though alsobased on the above assessment).

Core principle

The PPWR is fundamentally designed to accelerate the transition towards a circular economy, by promoting recycling, use of secondary raw materials and reducing lifecycle impacts. Any implementation measure should therefore be assessed against its contribution to circularity, not only material substitution.