Europe’s sustainability agenda is not losing relevance. But when new rules lack clear timelines, common standards and predictable enforcement, they risk creating uncertainty for businesses and weakening trust in the EU’s ability to deliver its environmental ambitions.
Implementation gaps in the Packaging and Packaging Waste Regulation
The EU’s Packaging and Packaging Waste Regulation, or PPWR, marks one month of application across the European Union today. The Regulation is an important part of Europe’s circular economy agenda, establishing common rules intended to reduce packaging waste and make packaging more circular. Yet this anniversary should prompt reflection as much as celebration.
The challenge is not that Europe lacks ambition. The challenge is that, in some areas, the practical tools needed to implement ambitious legislation are not fully in place when the rules begin to apply. This can create uncertainty for companies, national authorities and investors, while also risking inconsistent implementation across the Single Market.
The PPWR illustrates this problem clearly. Although it is a directly applicable EU Regulation, many crucial details still depend on future delegated and implementing acts. These are additional measures through which the European Commission sets technical requirements, common methods and practical procedures.
At the time of its adoption, Austria abstained from the Council vote in December 2024, stating that the text “does not, however, fully meet” the objective of establishing clear and enforceable rules. More recently, two months before the PPWR began to apply, Czechia, Bulgaria, Italy, Latvia, Poland, Romania, Slovakia and Slovenia called on the Commission to publish an urgent, consolidated timetable for the outstanding measures. They raised concerns about fragmented labelling requirements, the lack of clear methods for testing PFAS in food-contact packaging, and missing compliance methodologies.
PFAS are often called “forever chemicals” because they persist in the environment. The PPWR introduces restrictions on their use in food contact packaging, but companies want a clear and harmonised way to test for them throughout the value chain.
The Commission has sought to address these concerns through guidance and frequently asked questions. Its latest update, published on 3 August, referred to work involving industry, civil society and Member State authorities to develop a harmonised testing protocol for PFAS in food-contact packaging. However, work on the protocol is still ongoing.
For companies, particularly those operating across several countries, this leaves a practical question: how should they demonstrate compliance today if the common method is not yet finalised?
The Commission has also indicated that national market-surveillance authorities should warn businesses and allow them a reasonable period to correct problems before imposing sanctions for obligations that started applying in August 2026. This is a pragmatic approach. But it also raises further questions. What is a reasonable period? Will authorities apply this approach consistently across the Union? And can non-binding guidance provide enough certainty where legal obligations already apply?
The Methane Regulation: enforcement deferred, obligations unchanged
The PPWR is not the only file raising these questions. Similar concerns have emerged around the EU Methane Regulation. In July 2026, the Commission recommended that Member States should not apply penalties to importers for certain obligations between 2027 and 2029, except in cases of fraudulent breaches. Instead, national authorities should monitor and encourage compliance during this period.
The recommendation followed calls from Member States, MEPs and the gas, LNG and oil industries for a targeted postponement. In a note of 25 June, twelve Member States argued that some obligations were not yet feasible because verification protocols, accreditation systems and certification capacity were not operational.
The underlying obligations, however, remain legally in force. Germany warned that suspending enforcement without changing the legislation could leave companies exposed to legal risk. Industry representatives have similarly called for a binding EU-level postponement, arguing that non-binding Commission recommendations and national discretion cannot guarantee legal certainty or consistent application.
Environmental organisations take a different view. They warn that delaying penalties could weaken the EU’s climate agenda under the banner of competitiveness. The Commission has maintained that its recommendations enable pragmatic implementation without reopening the Regulation.
Both sides raise legitimate concerns. Europe cannot build a successful green transition if legislation creates avoidable uncertainty or differs significantly between Member States. At the same time, implementation challenges should be addressed in ways that preserve the Regulation’s environmental objectives and ensure they can be delivered effectively in practice.
Towards implementation that matches the ambition
Another challenging file, the EU Deforestation Regulation, provides a relevant reminder. Its implementation has been postponed twice and accompanied by simplification efforts, yet questions over workability have not fully disappeared. Delaying requirements can offer breathing space, but it does not resolve the underlying need for clarity, capacity and realistic implementation.
Europe’s green credibility will depend not only on the targets it sets, but on whether it can make those targets work in practice. Guidance can be useful, but where legal uncertainty is significant, it may not be enough. Brussels, working with industry, Member States and civil society, should ensure that implementation is as credible as the ambition behind it.
