Under PPWR, the classification of certain industrial packaging formats remains an area of ongoing interpretation and debate. Formats such as IBCs, drums and canisters frequently serve multiple functions simultaneously: transport, storage, handling and product containment.

That ambiguity has direct implications for reuse obligations, reporting requirements and compliance strategies.

A consistent theme emerging from the discussion was the need for pragmatic classification methodologies before fragmented interpretations become embedded across member states and supply chains.

This is not just a legal interpretation issue — it is an operational alignment challenge with potentially significant socio-economic implications.

The challenge is not simply legal interpretation. It is operational consistency. If certain industrial formats are classified as transport packaging and become subject to reuse obligations that are not operationally feasible, companies may ultimately be forced to redesign packaging systems entirely — with downstream impacts across filling operations, logistics networks, and supply-chain economics.

Without shared conventions, companies risk:

• inconsistent declarations,
• duplicate compliance burdens,
• conflicting customer expectations,
• unnecessary administrative complexity,
• and avoidable disruption across industrial value chains.

3) Conformity and documentation must remain risk-based and operationally realistic

Documentation and conformity requirements are also becoming a priority area as the first PPWR obligations become enforceable in August 2026.

A key clarification emerging from the roundtable was that the Declaration of Conformity (DoC) should not be interpreted as an exhaustive technical file. Rather, it functions as the front-facing declaration supported by technical documentation held within the supply chain.

At the same time, ambiguity remains around ownership and responsibility for documentation relating to substances of concern — including adherence to PFAS and BPA limits — particularly where responsibilities sit between raw material suppliers, packaging suppliers, and downstream users.

Managing those documentation expectations will be critical to avoiding unnecessary administrative burdens and inconsistent compliance approaches across global packaging networks.

4) PPWR is becoming a data and systems challenge, not just a packaging challenge

Data is rapidly becoming both a compliance bottleneck and a strategic differentiator.

By 2026 and beyond, organizations will increasingly need to manage detailed packaging information across global supplier networks, including non-EU suppliers with limited direct regulatory exposure.

For many organizations — particularly SMEs — the capability gap to provide dedicated resources to PPWR implementation may become more significant than the material challenge itself.

At the same time, digital product passports and improved traceability frameworks also create an opportunity to build more transparent and standardized recyclability and recycled-content systems across the market.

The companies that invest early in packaging data governance will likely gain a significant implementation advantage as methodologies mature.

The “what” is defined. The “how” is still being written.

One of the clearest themes emerging from the roundtable was that PPWR implementation will not be shaped by regulation alone. Many of the practical frameworks are still being debated today — from reuse calculations and LCA criteria to packaging classification, grouping approaches, and data governance — will ultimately be influenced by how the industry operationalizes them in practice.

As a result, the companies moving fastest are not necessarily those waiting for complete regulatory certainty, but those already:

• engaging in methodology discussions,
• building evidence-based implementation models,
• aligning interpretations across stakeholders,
• educating customers and suppliers,
• and identifying where operational realities need to be better reflected in future guidance.

While the targets set the direction of travel, many of the methodologies and practical interpretations that will determine how PPWR works in practice are still evolving. This is where collaboration between industry, associations, and regulators will become increasingly important.

The industry must work together with a focus on bringing forward operational experience, environmental evidence, and pragmatic implementation models that can help policymakers refine methodologies, calibrate requirements where necessary, and translate policy ambition into workable systems at scale.

That is now the defining challenge and opportunity for the packaging industry.