News and Statements

UKRPEC Statement following the discussion of the consolidated version of the draft law
“On Packaging and Packaging Waste” in the Competent Committee of the Verkhovna
Rada.

The Ukrainian Packaging and Environmental Coalition took part in a series of thematic online
meetings held in September-October at the initiative of the Verkhovna Rada Committee on
Environmental Policy and Nature Management.
The discussions focused on developing a consolidated version of the Draft Law of Ukraine “On
Packaging and Packaging Waste” in the context of aligning national legislation with the legal
field of the European Union.

The events were co-organized by the NGO “Pragma” and the project “United for the
Community”, implemented by ISAR Yednannia with financial support from the European Union.

A key focus of the discussion was the integration of the requirements of the EU Packaging and
Packaging Waste Regulation 2025/40 (PPWR) into the updated version of the draft law.

Participants examined the main issues related to the introduction of the European model of
packaging waste management in Ukraine: extended producer responsibility (EPR), functioning
of organizations EPR, recycling targets by packaging types and categories, deposit systems,
packaging reuse and refill systems. The meetings also addressed cooperation between EPRs
and local authorities, as well as EU requirements for packaging and labeling.

It is expected that the proposals and comments expressed during the discussions will be taken
into account in preparing the new version of the Draft Law “On Packaging and Packaging
Waste.”

Representatives of the parliamentary committee noted that the updated draft will be published
and reviewed at a committee meeting in December, and shortly thereafter the Parliament should
vote on it in the first reading.

UKRPEC’s position

Based on the outcomes of the discussions, the Coalition — acting as an authorized
representative of the industry — formulated the following key positions:

  1. Adaptation period. Implementing the Regulation’s requirements in Ukraine will require
    a lengthy transition period. EU countries have been working on integrating EPR
    principles and the circular economy for decades — and even for them, the new rules
    remain a serious challenge. Ukraine is currently at the starting point of this process, so
    meeting some of the requirements is objectively impossible at this stage.
  2. Packaging characteristics. New rules regarding packaging properties and the
    materials used for packaging must be discussed and agreed upon with domestic
    manufacturers. Without this, there is a real risk that certain segments of Ukrainian
    industry could halt production. (UKRPEC is currently working to establish effective
    communication channels between packaging producers and policymakers.)
  3. Realistic recycling targets. At the initial stage of reform, recycling targets should not
    exceed 10%. (This view was fully supported by all meeting participants.)
  4. Legal uncertainty of the EPR system. Current Ukrainian law does not define the term
    “extended producer responsibility (EPR) system/scheme” (as required by the EU Waste
    Framework Directive — Directive 2008/98/EC, Article 3, Paragraph 21). Without such a
    provision, it is impossible to fully transfer responsibilities for packaging waste
    management from local governments to the organization EPR. Its absence also prevents
    producers from legally including waste management costs in product pricing. This legal
    gap must be eliminated.
  5. Threshold for establishing an EPR. The right to establish a separate EPR should
    belong to producers who collectively place at least 30% of packaging on the market.
    Reducing the threshold (e.g., to 5%, as some participants proposed) would lead to
    excessive market fragmentation and the emergence of dozens of small PROs unable to
    invest effectively in separate collection infrastructure. It would also increase the risk of
    secondary trading of collected materials. The threshold proposed by the Coalition would
    limit the number of PROs in Ukraine to no more than 1-3.
  6. Single PRO for all types of packaging waste. Establishing separate PROs for different
    types of packaging is unacceptable. This approach — unprecedented globally — would
    make performance monitoring and reporting impossible and would shift the focus toward
    only the most profitable packaging types. As a result, a significant share of household
    packaging waste would remain outside the EPR system due to lack of economic appeal.
    Under such conditions, building a single efficient national EPR system is impossible.
  7. Cooperation with local authorities. PROs must be required to sign agreements with
    local governments. This ensures that the system covers not only commercially attractive
    packaging waste, but also household waste. A similar provision already exists in the Law
    of Ukraine “On Waste Management.” It is also necessary to ensure that recycling targets
    reflect specific obligations for household waste management.
  8. Unified separate collection system under EPR. No other economic entities should
    collect packaging waste without coordination with the PRO. Without such a rule, the
    EPR system would lose control over key waste streams. The most valuable materials —
    essential for financing the national collection and sorting infrastructure — may be
    diverted into shadow schemes operated by entities outside the EPR system. Ultimately,
    significant volumes of packaging waste would fall beyond the management and
    oversight of the system.
  9. Deposit system. This is a supporting tool that should be introduced only after the EPR
    system is fully operational and recycling rates reach at least 45%. Premature
    implementation could slow the development of the EPR system and is economically
    unjustified in current conditions, as it covers only limited volumes and types of waste —
    primarily PET bottles and aluminum cans.
  10. Legalization of the packaging waste collection sector. The reform must be
    accompanied by the legalization of independent waste collection activities. This would
    formalize the work of thousands currently operating in the sector, create new jobs,
    increase transparency, and ensure proper labor conditions and social protection.

The series of online meetings became an important stage in the joint efforts of public
institutions, the expert community and business representatives to reform the packaging waste
management system in Ukraine — based on the European principles of the circular economy.

The Ukrainian Packaging and Environmental Coalition expresses its gratitude to the Committee
of the Verkhovna Rada of Ukraine on Environmental Policy and Nature Management for the
open discussion format and constructive cooperation. UKRPEC looks forward to continuing this
productive dialogue in the process of preparing the final version of the draft law and expects
that the position of the key stakeholders of the reform — producers of packaging and packaged
goods — will be duly taken into consideration by lawmakers.

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