The European Parliament’s Committee on Environment (ENVI) has amended the Packaging and Packaging Waste Regulation (PPWR) with additional crackdowns on plastic pollution, fossil fuel dependency, ‘forever chemicals’ in food packaging, and more – but UNESDA is critical of its stance on reusable packaging and the potential impact on harmonization and the Single Market.

MEPs have adopted their position on a proposed regulation encompassing the entire packaging life cycle, from raw materials to final disposal. It saw fifty-six votes in favour, twenty-three against, and five abstentions, and the full house is scheduled to vote on its negotiating mandate during the second November 2023 plenary session.

Specific waste reduction targets for plastic packaging – 10% by 2030, 15% by 2035, and 20% by 2030 – are envisioned by MEPs, with minimum percentages of recycled content to be mandated by packaging type with 2030 and 2040 targets. For example, the PPWR has placed the amount of post-consumer plastic waste per unit of packaging required for single-use plastic beverage bottles and contact-sensitive packaging made predominantly of PET at 30% by 1st January 2030.

Any plastic carrier bags weighing below 15 microns that are not required for hygiene reasons or as primary packaging to prevent waste in loose food are set to be banned. The PPWR proposal already states that ‘very lightweight’ plastic carrier bags can be implemented in Member States equipped with suitable collection schemes and waste treatment infrastructure, provided that the bags are made of compostable, biodegradable plastic polymers that can be processed at bio-waste treatment facilities.

The Commission is expected to evaluate the possibility of proposing targets and sustainability criteria for bio-based plastic by the end of 2025. Such materials are expected to help drive down the plastic economy’s reliance on fossil fuels.

Bisphenol A, PFAS substances, and other “forever chemicals” that are added to food-contact packaging – often to make paper and cardboard food packaging resistant to fire or water – are also expected to be banned. These substances have been associated with various negative effects on human health.

On this note, rapporteur Frédérique Ries (Renew, BE), commented: “The Environment Committee has sent out a strong message in favour of a complete overhaul of the European packaging and packaging waste market. There can be no effective recycling or reuse policy without safe packaging, which is why the ban on intentionally added harmful chemicals is a major victory for the health of European consumers.

“We have also ensured that environmental ambition meets industrial reality, with a report focusing on innovation and providing for a derogation for enterprises with fewer than ten employees.”

In line with the PPWR’s expectation that all packaging is designed to be recycled by January 2030 and recycled at scale by January 2035, the Commission plans to adopt criteria to define terms like “designed for recycling” and “recyclable at scale”. Meanwhile, online service providers will be held to the same Extended Producer Responsibility obligations as producers.

MEPs also aspire to distinguish between and clarify requirements for packaging to be reused or refilled. Reusables should be defined by a minimum number of times that the packaging can be reused, they argue, the specifics of which will be defined at a later stage.

Final distributors for beverage and takeaway food in the HORECA sector are expected to allow consumers to bring their own container as a reusable packaging solution.

However, UNESDA has spoken out on behalf of the European soft drinks sector in opposition to ENVI’s vote on the compromise amendment (CA 10) on reuse and refill. The organization hoped that an exemption mechanism to the reuse and refill targets – available to operators that meet certain environmental and waste management criteria – would be approved.

‘Substantial’ investments have been made into existing circular systems, the organization points out. It now fears that these will be affected by the new rules, as will the complementary relationship between reuse, refill, and recycling.

UNESDA believes that reuse and refill are valuable assets in reducing packaging and packaging waste, but that they ‘should only be implemented where and when it makes sense from an environmental, economic, and consumer perspective’. It argues against the increase of reuse and refill targets without conducting further impact assessment and posits that allowing Member States to exceed these targets ‘is not the right approach’.

Doing so is thought to contradict the European Commission’s goal of harmonization and risk fragmenting the EU Single Market, with varieties between national targets threatening Europe’s competitiveness, posing difficulties in implementing targets, and creating roadblocks between business and their reporting obligations.

On the other hand, ENVI’s new rules also call for 90% of materials used in packaging – plastic, wood, ferrous metals, aluminium, glass, paper, and cardboard – to be collected separately by 2029. The PPWR already mandates that deposit return schemes (DRS) are established for single-use plastic and metal beverage containers of up to three litres in size by 1st January of the same year.

UNESDA believes the 90% target to be a ‘necessary step towards enhancing packaging circularity’ and approves of widespread adoption of DRS in Europe. This system is thought to prevent food-contact packaging from being downcycled into non-food applications – when accompanied by a mechanism of priority access to certain feedstocks for recycling.

Therefore, UNESDA requests that MEPs and Member States back its call for a priority access right to allow beverage producers access to the necessary recycled materials to meet mandatory recycled content targets.

“We welcome the very strong stance taken by MEPs in favour of circularity by promoting closed-loop recycling of beverage bottles and a wider rollout of Deposit and Return Systems (DRS),” UNESDA’s director general, Nicholas Hodac, commented. “However, it is alarming to see MEPs support higher reuse targets without any further impact assessment and to give Member States the flexibility to go even beyond these increased targets.

“Is the EU serious about pushing for a patchwork of national targets that will have devastating consequences on Europe’s competitiveness? The EU should not set targets without any evidence justifying them.”

UNESDA underlines its commitment to working with both MEPs and Member States ‘to make the EU PPWR more pragmatic and realistic and to enable the industry to achieve fully circular beverage packaging.’

Last year, a joint letter from European packaging industry players discouraged the implementation of circular economy initiatives on a national scale and called for an integrated Single Market, and a single circular economy, across the European continent.

Another joint letter from over 120 packaging industry associations has expressed that co-legislators can achieve the environmental and economic objectives of the Packaging and Packaging Waste Regulation by preventing the erosion of its internal market legal basis.

Additionally, The Brewers of Europe has shared its own criticisms of the PPWR, namely its ‘disproportionate’ focus on beer packaging and alleged threat to the EU Single Market.

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Also, if you’re interested in packaging sustainability, you will want to attend our Sustainable Packaging Summit in Amsterdam on 14-15 November. The Summit brings together leaders and pioneers from across the industry to align strategically, learn, network, and create a critical mass to accelerate change. You can learn more by clicking here, and you can buy a ticket to attend here.