The Packaging and Packaging Waste Regulation proposed by the European Commission, which aims to tackle packaging waste and promote circularity, has frequently been the target of criticism for its perceived complexity and ambiguity. In this article, Maija Pohjakallio, Metsä Group’s VP of Climate and Circular Economy, and Jarkko Tuominen, VP of Projects at Metsä Spring, give their views on these potential shortcomings – and offer some solutions.


The European Commission’s proposal for the Packaging and Packaging Waste Regulation (PPWR) was published with the noble goal of promoting circularity and reducing packaging’s environmental impact. Given that packaging accounts for 40% of the 353 million tonnes of global plastic waste, an amount that doubled between 2000 and 2019, the issue is clearly pressing, and the time to act is now.

However, as we have watched the progress develop over recent months, it has become apparent that the proposal’s complexity and ambiguity are more of a cause for concern than a pathway to progress. So where is the PPWR proposal falling short, and what can be done to prevent its ever-shifting goalposts from resulting in an own goal for innovation and the environment?

Confusion reigns supreme

The general goals of the PPWR proposal, to increase recycling and reuse, and reduce the amount of packaging waste are well-intentioned and much-needed. However, the PPWR’s definitions and confusing grading of materials and packaging solutions currently leave manufacturers in the dark as to where their products fall in the present, never mind potential future materials classifications. This is particularly problematic for sustainable materials innovators and especially so for startups.

With long product development cycles and the European Commission’s proposals subject to changes, it’s a massive risk for young companies lacking resources to keep investing in product development in a changing environment.

Many viable sustainable packaging materials currently exist, and with clearer legislation, more innovations could potentially be just around the corner. However, it’s simply too risky for companies to invest in the further development of sustainable solutions when they cannot guarantee that their products will be allowed under the legislation’s unclear future.

The unfortunate outcome may be that many of the world’s most promising solutions to one of the planet’s most pressing problems may never see the light of day, or be unable to attract sufficient investment to scale up and go to market as viable solutions.

Unrealistic and imbalanced views on reuse

At present, the PPWR’s proposal’s bans and mandatory reuse targets for the HORECA (hotels, restaurants, and cafés) and transport packaging sectors appear ambitious, and reuse is emphasised over recycling.

While the proposal is admirably aimed at reducing packaging waste, the pathway to achieving circularity is not singular. The environmental impacts of different packaging solutions depend on the systems and contexts in which they are utilised, which is a factor the proposed regulations appear to overlook.

The European Commission’s impact assessment is also thrown into question. Product safety is non-negotiable in food packaging, and this aspect has not been highlighted enough. Scientists have recently discovered that recycled and reused food contact plastics can be vectors for spreading chemicals of concern. Furthermore, the environmental impacts of reuse are highly dependent on the actual number of times the packaging is reused, and what resources are needed in washing and transportation.

The bias toward reuse is problematic, for example, in the case of restaurants, where reuse is not always a feasible option in comparison to recyclable packaging. The net result will push us back towards conventional plastics and fossil-based materials in order to comply with the ambitious reuse targets. It has been estimated that the 2030 mandatory reuse targets proposed by PPWR will increase plastic packaging waste by “up to 300%” for dine-in consumption and “up to 1500%” for takeaway.

Furthermore, reuse in the restaurant sector provides additional challenges for businesses and consumers. For example, reusable packaging requires washing, a process that consumes significant amounts of energy, and may even require further facilities to be built on-site in order to wash and prepare items for reuse. The reuse targets also rely on human behaviour complying with the targets.

The recycling rate of fibre-based packaging in the EU is high (> 80%) and can be increased further by developing and harmonising the waste collection infrastructure. The PPWR proposal introduces performance classes for recyclability, which create a basis for producer responsibility fees- the higher the class, the lower the fee. This is a good incentive to develop and improve recycling.

Freedom to innovate can be hampered

Done correctly, reuse and recycling should be considered as complementary, and not contrasting solutions to the common goal of circularity. Legislation needs to allow the best direction to be taken for each use case. There also needs to be predictability and clarity in the regulations.

The path from ideas to industrial scale in novel technologies and sustainable materials is long. This should be taken better into account in the EU policy framework, which should promote the market entry of sustainable innovations.

New biomaterials are needed in order to reduce fossil-based reliance, which means that innovation must be at the forefront of the EU’s direction, rather than stifling startups through ambiguity and uncertainty. For both environmental and political reasons, Europe must address its dependence not only on energy imports, but also on fossil-based materials.

Therefore, innovations are crucial in the development of a more sustainable future. The PPWR proposal is now in the hands of the European Parliament and Council. We hope that the EU member states and MEPs will take our insights into consideration and improve the proposal accordingly.

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