After the European Council announced its ‘general approach’ for upcoming negotiations with the European Parliament surrounding the Packaging and Packaging Waste Directive, UNESDA, the European Container Glass Federation (FEVE), European Bioplastics (EUBP), the Permanent Materials Alliance, and Zero Waste Europe have expressed their reservations about its mandatory collection and recycling targets, additions and removals of measures to and from the draft text, and more.


UNESDA backs the mandatory implementation of deposit and return systems (DRS), yet it expresses its disappointment that the text put in place by the Council has lowered the European Commission’s collection rate target of 90% and the European Parliament’s proposal of 85% down to 78%. DRS are instrumental to the pursuit of a circular economy for beverage packaging, according to UNESDA – highlighting that Member States that have already embraced DRS often report collection rates up to 95%.

Latvia, Lithuania, Slovakia, Malta, and other countries that have recently implemented DRS have also recorded collection rates of up to 90%. Such figures are, in UNESDA’s eyes, proof of the system’s true potential.

The general approach also fails to acknowledge the complementarity of reuse and recycling. UNESDA approves of reusable packaging as one solution to reach reuse and refill targets and combat packaging and packaging waste reduction, but suggests that failing to support existing recycling efforts will do more harm than good.

In response, it suggests the introduction of exemption mechanisms from reuse and refill targets to make certain that reusable models are only applied when they are more environmentally beneficial than recycling.

Nicholas Hodac, director general of UNESDA, comments: “Even though Member States secured the obligation for the mandatory rollout of DRS, lowering the collection threshold granting an exemption from the DRS obligation is clearly a step back in the efforts to improve the collection of beverage packaging in the EU.

“It is truly disappointing to see that Member States missed the opportunity to acknowledge the complementarity of reuse and recycling by failing to support the creation of exemption mechanisms. While reuse can help achieve a circular economy, it doesn’t always bring positive environmental outcomes and that’s why exemptions are needed.

“We are also disappointed by Member States’ lack of support for a mechanism that would enable closed-loop recycling whenever it makes sense. A priority access right to food-grade recyclates would provide beverage manufacturers with reliable access to recycled materials, enabling them to achieve the EU’s mandatory recycled content targets and their own voluntary commitments.”


The European Container Glass Federation believes that the European Council has ‘failed to recognize the contribution that circular packaging can make to competitiveness and sustainable growth’ – this is attributed in part to the general approach’s reported lack of equal distribution of effort between all materials to cut down on packaging waste.

“We are deeply concerned that, although Member States acknowledged the risk of material substitution, the overall packaging waste reduction targets based only on weight will inadvertently encourage a shift from circular materials like glass to lighter but less recyclable or reusable materials,” says Adeline Farrelly, secretary general of FEVE.

Furthermore, Member States are not thought to have fully acknowledged packaging design or the importance of respecting Intellectual Property Rights for unique designs.

“On top of its health and environmental benefits, the characteristics of glass in terms of design, transparency, shapes, colours and versatility often make glass an integral part of a product. So restricting packaging design disproportionately means that all products will look similar. Brands will lose one of the most important tools to convey their identity to consumers, and to stand out on the shelves.”

FEVE criticizes the ‘diluted’ recyclability measures in the general approach, with Farrelly stating: “Not all recycling has the same environmental value. The introduction of recyclability performance grades rewarding packaging that can be recycled multiple times and that can feed into a closed material loop would have been a major milestone.

“We regret that Member States missed the chance to incentivise packaging that is infinitely recyclable and which can remain productive in a Circular economy over and over again.”

Like UNESDA, it also believes that separate collection targets must be wider in scale, accusing the approach of limiting its scope to a small proportion of packaging formats covered by DRS.

“Mandatory separate collection targets for all packaging materials will reduce waste much more effectively,” Farrelly concludes. “It will also ease the burden on taxpayers and a country’s waste management costs.”

European Bioplastics

Meanwhile, European Bioplastics is critical of the lack of coverage for bioplastics in the general approach.

Roberto Ferrigno, head of EU Affairs at EUBP, says: “Member States appeared today to be split on quite a number of key issues, which will be problematic for the implementation of such a complex regulation, if the consequential shortcomings aren’t fixed during the trilogues.

“It is a weak General Approach, barely recognising the value of a very short number of compostable applications and hindering biobased innovative solutions. Disagreement among governments, and derogations on several important measures will result in further fragmentation of the internal market.”

“EUBP supports the European Parliament’s proposal for a Regulation on Packaging and Packaging Waste,” comments EUBP managing director Hasso von Pogrell. “We call on the Member States and the incoming Belgian Presidency to work in close cooperation with the Parliament, which has been showing clear leadership on the file.”

Permanent Materials Alliance

The Permanent Material Alliance – a coalition consisting of FEVE, the Association of European Producers of Steel for Packaging (APEAL), European Aluminium, and Metal Packaging Europe – describes the recyclability provisions as a ‘missed opportunity to showcase high ambition in advancing the circular economy and positioning the European Union as a global leader in sustainable practices’.

Steve Claus, secretary general of APEAL, elaborates: “Ambitious recyclability performance grades, including strong qualitative recyclability criteria, would have been a great step forward to a truly EU Circular Economy, ensuring that packaging that can be recycled multiple times and can feed a closed material loop scheme is duly recognised at the top of the recycling hierarchy.”

Metal Packaging Europe’s CEO, Krassimira Kazashka, underlined the company’s views on foregrounding high-quality recycling in efforts to enhance recyclability for economic operators; “We welcome the efforts to define high-quality recycling. However, Member States missed the opportunity to adopt an ambitious definition of high-quality recycling that would incentivise materials that can withstand multiple recycling loops without any change to their main material properties.”

A lack of separate collection targets for all materials was scrutinized by Maarten Labberton, director Packaging Group of European Aluminium: “High-quality recycling of packaging materials highly depends on the availability of efficient separate collection and sorting systems for packaging waste. We regret that the Council did not support a separate collection target of 90% for all packaging materials.”

Adeline Farrelly claims that glass and steel already undergo high rates of collection, sorting, and recycling into new loops, with the Alliance suggesting that aluminium, glass, and steel offer respective recycling rate of 73%, 80.1%, and 78.5%. Farrelly comments: “We very much regret that Member States acknowledged the risk of material substitution but maintained overall packaging waste reduction targets that will incentivise a shift away from fully circular materials (Permanent Materials) to difficult to recycle packaging materials.”

The Permanent Materials Alliance stresses that co-legislators within the EU should work together to raise the PPWR’s recycling targets in order to streamline the path to a circular economy, protect the environment, and boost resource retention.

Zero Waste Europe

Last but by no means least, Zero Waste Europe states its view that the Council’s general approach improves upon the Parliament’s ‘backwards position’ and sets up a ‘strong foundation’ for negotiations in the upcoming trialogues. However, it still describes the new approach as ‘watered down’.

In regards to reuse provisions, it accuses Member States Italy and Finland of ‘undermining reuse and waste prevention measures in the PPWR’ with a non-paper released after the PPWR’s vote in the Parliament. Subsequently, the Spanish Presidency accepted further derogations on the subject.

Zero Waste Europe connects this to the removal of reuse targets for wine and the reintroduction of exemptions for cardboard in the general approach. The organization also claims that the restrictions on fresh fruit and vegetable packaging to exclusively plastic is ‘limiting’.

“We appreciate the Council’s achievement of a more favourable arrangement for reuse provisions compared to the Parliament, maintaining most of the targets for takeaway, beverage, and transport packaging in their general approach,” states Raphaëlle Catté, Policy & Research Support. “However, due to opposition led by Italy and Finland, the Presidency had to grant additional exemptions to reuse provisions.

“With the welcome inclusion of open formulations in the targets, using terms like “at least,” Member States which are already implementing ambitious reuse measures won’t be required to revert to disposable packaging.”

Dorota Napierska, Toxic-Free Circular Economy policy officer, continues: “The Council’s compromise text introduces crucial measures, including clear identification of substances of concern on packaging labels and comprehensive assessments of their impact on reuse, recycling, and chemical safety. While enhancing transparency, we urge immediate bold actions, especially for hazardous substances like PFAS and bisphenols, to safeguard human health and address packaging’s vital role in everyday life.”

Chemical Recycling and Plastic-to-Fuels policy officer Lauriane Veillard continues: “It is encouraging that the Council acknowledges the differences between recycling technologies, notably regarding energy requirements and greenhouse gas emissions. However, it fails to take into account that the overall environmental impact of recycling goes beyond GHG [greenhouse gas] emissions – something which was recognised by the Parliament in its position.”

Going forward, Zero Waste Europe calls for ‘swift action’ to solidify a deal ahead of European parliamentary elections in 2024.

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