Our comments are limited to the reporting obligations set out in the draft for businesses (Article 2, Annex II). In our view, it is particularly important that the reporting obligations for producers under Article 44(7), (8) and (10) PPWR are not regulated in isolation, but rather in conjunction with other, existing reporting obligations, e.g.
IIK
IK Industrievereinigung Kunststoffverpackungen
Industry association · Germany · EU Transparency Register 630544211586-49not in register snapshot
This register number is the organization’s own declaration on its submission. It is not in the 14 Oct 2026 snapshot of the EU Transparency Register, so we neither link to it nor use it to identify this organization.
5
positions filed
in the 665 files tracked
4
legislative files
of 665 tracked
5
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
IK Industrievereinigung Kunststoffverpackungen filed 5 positions between 6 Aug 2020 and 10 Sept 2026, across 4 of the 665 legislative files tracked here, attaching a full position paper 5 times.
2020 · 1 filed2023 · 1 filed2026 · 3 filed
What they argued
For us, the German plastic packaging manufacturers, the proposed regulation offers an opportunity for the sustainable transformation of the entire packaging industry. Our members have invested in the recyclability of their products and stand ready with innovative solutions that combine high material efficiency with high recyclability and the use of recycled materials.
IK represents the plastic converting industry in Germany in the field of plastic packaging production with about 300 member companies, mostly SMEs. The branch produces a revenue of 15 bn Euro and employs about 90,000 people. We welcome the European Commission's goals of climate neutrality and a circular economy as laid down in the Green Deal.
The SUPD of 2019 was an attempt to demonstrate the EU's ability to act in the face of appalling images of littered beaches, predominantly in Asia and Africa. Seven years later, it is clear that this approach - at least in relation to plastic packaging - has largely failed: the amount of single-use plastic products has not decreased.
The new EU regulation 2025/40 for Packaging and Packaging Waste (PPWR) is putting considerable pressure on the complex industrial and commercial supply chains in the EU. The environmental omnibus is an opportunity to simplify the PPWR regarding industrial and commercial packaging without questioning the environmental targets of the regulation.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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