Five European industry associations are urging the European Commission not to reopen the Single-Use Plastics Directive, warning that an early revision could increase legal uncertainty across the packaging value chain. The joint statement has been signed by EUROPEN, Plastics Europe, European Plastics Converters, European Plastic Films and AIM, the European Brands Association.

The organisations acknowledge that the Directive must deliver measurable environmental improvements. However, they argue that revising the legislation before its existing provisions have been fully implemented would make it difficult to judge whether the current framework is working as intended.

The signatories say that implementation, enforcement and reporting should be improved before policymakers consider reopening the Directive itself.

The Single-Use Plastics Directive was introduced to reduce the environmental impact of selected plastic products, particularly items commonly found in marine litter. It includes measures such as consumption reduction targets, product restrictions, marking requirements, collection obligations and extended producer responsibility provisions.

For packaging producers and brand owners, the Directive has already required significant changes to materials, formats, labelling and compliance systems. The associations warn that reopening the legal text now could create overlaps or contradictions with other EU rules, including the Packaging and Packaging Waste Regulation and national EPR legislation.

According to the joint statement, the evidence currently available is not strong or consistent enough to justify a revision. An initial implementation report was published in April 2026, but the associations describe it as incomplete. They also point to the absence of a harmonised reporting approach, which makes it difficult to compare results between Member States.

This lack of comparable data is a major concern. If countries measure consumption, collection or environmental impact in different ways, policymakers may struggle to identify whether differences in performance are caused by the legislation, national implementation choices or variations in waste management infrastructure.

The associations also argue that a meaningful impact assessment cannot yet be completed because several provisions of the Directive are still not fully operational. Reviewing the law before those measures have taken effect could lead to new obligations being introduced without a clear understanding of the costs, benefits or unintended consequences.

• Incomplete implementation makes the Directive’s overall effectiveness difficult to assess.
• Different national reporting methods limit comparisons between Member States.
• Regulatory overlaps could create conflicting requirements for packaging companies.
• Uneven enforcement places different compliance burdens on businesses across the EU.
• Gold-plating can result in national rules that go beyond the Directive’s original requirements.

Regulatory fragmentation is already affecting companies that sell packaging and packaged goods across several European markets. The signatories say national transposition has produced different interpretations, enforcement practices and administrative requirements. This can force businesses to redesign packs, change labels or maintain separate compliance processes for individual countries.

Such complexity is particularly challenging for small and medium-sized companies, which may lack the regulatory resources of multinational groups. Even larger companies face additional costs when products that are technically identical must be handled differently depending on the market in which they are sold.

The debate also comes as the packaging industry prepares for major changes under the Packaging and Packaging Waste Regulation. New recyclability, recycled-content, reuse and waste-prevention requirements are already expected to demand substantial investment. Industry groups fear that reopening the Single-Use Plastics Directive at the same time could produce duplication and reduce the predictability needed for long-term packaging decisions.

The associations are not calling for environmental ambition to be reduced. Instead, they want the Commission to focus on consistent implementation, comparable data and enforcement of the existing rules. They argue that a future review should be based on complete evidence and a clear understanding of how the Directive interacts with other EU legislation.

For the packaging sector, the statement highlights the importance of regulatory stability. Companies need sufficient certainty to invest in recyclable materials, reuse systems, collection infrastructure and product redesign. Frequent or overlapping rule changes can delay those investments by making future compliance requirements harder to predict.

The Commission will therefore face a balancing act: maintaining pressure for environmental progress while avoiding unnecessary legal complexity. The industry’s position is that the Directive should first be allowed to operate fully and consistently before any decision is made to rewrite it.

Image suggestion: European packaging and plastics representatives reviewing regulatory documents in Brussels, with recyclable food and beverage packaging displayed beside EU flags.