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Following the Committee on Environment (ENVI)’s vote on Compromise Amendments to the Packaging and Packaging Waste Directive, organizations from across the packaging value chain have made their voices heard – expressing a range of views on its targets, bans, and legislative adjustments regarding single-use plastics, reusable packaging, and more.

On Tuesday, the Committee convened to vote on the amendments, with their rejection by the EPP and ECR parties followed by the late tabling of their own amendments delaying the process. The rapporteur, MEP Frédérique Ries, oversaw the final tally of fifty-six in favour of the bill, twenty-three against, and five abstentions.

Recycling targets

Perhaps the biggest point of contention in the industry’s response thus far comes in the pursuit of more ambitious recycling targets. United under the Permanent Material Alliance, the Association of European Producers of Steel for Packaging (APEAL), European Aluminium, the European Container Glass Federation (FEVE), and Metal Packaging Europe express their satisfaction with ENVI’s approach, which is thought to align with the potential for aluminium, glass, and steel to be recycled indefinitely in closed material loop schemes.

“Recyclability performance grades now introduced in the PPWR are a great step forward to a truly EU Circular Economy,” commented Alexis Van Maercke, secretary general of APEAL. “These grades, a first of their kind, will reward packaging that can be recycled multiple times and that can feed into a closed material loop scheme.”

Adeline Farrelly, secretary general of FEVE, added: “We are glad to see that the ENVI Committee adopted packaging waste reduction targets to mitigate against the risk of substitution of fully circular materials (Permanent Materials) by difficult-to-recycle packaging materials. Aluminium, glass and steel largely prevent waste generation as they are today already collected, sorted and undergo high-quality endless recycling into new loops.”

Nevertheless, coalition members highlighted what they felt was an incomplete definition of ‘high-quality recycling’ – i.e., a closed-loop process – and, in turn, a limitation of the materials’ full potential.

“The introduction of a definition for ‘high-quality recycling’ is surely a very important move,” said Sarah Cuvellier, deputy CEO of Metal Packaging Europe. “However, we believe that the ENVI Committee could have been more ambitious by emphasizing materials’ ability to withstand multiple recycling loops without any change to their main material properties.

“An ambitious definition of ‘high quality recycling’ would stimulate the manufacturers of packaging to increase the design for recycling of their packaging and further boost their effective and efficient recycling.”

Maarten Labberton, director Packaging Group of European Aluminium, continued: “High quality recycling of packaging materials highly depends on the availability of efficient separate collection and sorting systems for packaging waste. A timely and ambitious approach which encourages the separate collection of packaging waste in all EU Member States is a must. We fully support the separate collection target of 90% endorsed by the ENVI Committee.”

Cepi agrees with the enforcement of a 90% collection target, citing a reported recycling rate of 82.5% for paper packaging – a figure that already exceeds the targets put in place for 2025. Increasing the rate would apparently require the separate collection of paper and board across Europe, which the vote aims to facilitate.

However, its call to recycle packaging in a closed product loop is not thought to apply to paper and board, as these products can be recycled together into the same or similar product applications. This requirement is described by Cepi as an ‘unnecessary barrier to paper recycling without bringing any benefits to its quality’.

Therefore, Cepi instead calls for a material loop and suggests that the quality of recycled materials, alongside their potential to substitute primary raw materials, would have served as ‘a better point of reference’. A market for secondary raw materials already exists in the paper and board industry, the organization states, with around 75% of paper-based packaging is currently said to be made from recycled materials.

A minimum quota for recycled content in new products has been embraced by Lauriane Veillard, Chemical Recycling and Plastic-to-Fuels Policy officer at Zero Waste Europe. It is said that the measure “ builds on the Commission’s proposal and goes a step further by considering the environmental impact of recycling process, thus bringing environmental requirements into the circular economy agenda.”

However, it is suggested that the same consideration has not been shown for contact-sensitive packaging. Virginia Janssens, managing director at Plastics Europe, expresses that the company is “particularly disappointed” by a reduction in recycled content targets, describing it as a “missed opportunity to encourage the necessary investment” that will “undermine the development of the market for recycled plastic packaging in Europe.”

Various bans and reduction targets are accused of being ‘arbitrary’ and singling out plastic packaging without an accompanying impact assessment. Plastics Europe fears that a full ban goes against the Directive’s environmental goals and pre-existing circularity investments from the plastics industry by stifling recycling processes for shrink wraps, collation films, and other plastics packaging for fresh products and grouped packaging – all of which are ‘essential’ in protecting and transporting products.

“Whilst politically attractive to some stakeholders, arbitrary bans are not the answer,” Janssens continues. “They will only encourage the substitution of plastics with other materials without any proven environmental advantages and will not solve the issue of single-use packaging.

“We instead call for an ambitious proposal that creates the positive investment climate enabling the European plastics system to continue its sustainability journey.”

Allowing for the use of bio-based virgin plastics in recycled content targets has been met with a mixed response. Veillard stresses that “the requirement to meet recycled content targets is strongly undermined by the possibility to use bio-based plastic. There is no point in integrating circular thinking into packaging production if half of the targets can be fulfilled by using virgin plastic.”

On the other hand, Plastics Europe maintains that the vote has ‘weakened the ambition’ to create a market for recycled plastic material and fails to adequately incentivize the adoption of bio-based plastics. It criticizes the new measures for utilizing bioplastics only as a means of ‘dilut[ing] the targets for recycled content’ and pushes for separate, parallel targets for these materials, as they are believed to bring down greenhouse gas emissions and reduce reliance on fossil-based feedstock during production processes.

Reuse and single-use bans

Single-use packaging will be restricted on the European market in a bid to cut down on packaging waste. This seeks to cut down on packaging waste, avoid unnecessary packaging, and enable an uptake in reuse.

ECOS made a statement on Twitter (X) to share its reservations about the ‘watered down’ compromises put forth for the takeaway sector in the new rules, emphasizing that the final text must address reuse targets.

Programme manager Mathias Falkenberg said that “a shift to reusable packaging is still in Europe’s future”, but “we must increase our uptake of reusable packaging to reverse the trend of increasing packaging waste” as the measures put in place are “not as ambitious as we need across the board.”

Cepi shares its view that recyclable and reusable packaging options complement each other – pointing out that paper packaging is already sourced from renewable content and widely recycled. Rather than applying a set of rules designed for fossil-based materials – and, according to Cepi, lacking in proof of its environmental performance – to a renewable material, the organization suggests a circular model.

“It is not too late for the Parliament, as the Institution representing the voice of EU citizens, to acknowledge all the benefits of the EU so efficiently recycling a material that is renewable, and sustainably sourced and managed,” says Jori Ringman, director general at Cepi. “This is already a world class recycling system, the result of billions of euros of private but also public investment. We should not aim to break what works, but to make it better.”

In Zero Waste Europe’s view, the proposition that 50% of large household appliance packaging should be reusable – including that made of cardboard and/or distributed from online platforms – is a significant step forward.

“For the first time in European packaging legislation, prevention and reuse are given a chance,” says director-founder Joan Marc Simon. “The ENVI Committee’s decision allows for systemic solutions which can deliver on the ultimate purpose of this revision: reduce packaging waste.”

Conversely, Plastics Europe thinks that reuse models could have an adverse effect on transport packaging and questions the true achievability of reuse targets in the transport sector.

“Unfortunately, today’s vote means that by 2030 flexible plastics films essential for transporting foods within, or between, EU Member States risk being banned entirely if the ENVI vote is confirmed in the final legislation,” says Janssens. “This will result in supply chain disruptions, higher costs for transporters and ultimately consumers, and will negatively impact transportation safety.”

FoodDrinkEurope is also critical of rising reuse targets in conjunction with the rejection of an exemption mechanism for reuse targets and a lack of impact assessment. If Member States achieving an 85% recycling rate or above were allowed to derogate reuse targets, the company believes that enterprises could ‘choose what they can do best’ rather than spreading resources between recycling and reuse targets and potentially hindering their success rate across the board.

As well as this, the European Commission’s impact assessment has come under fire for failing to mention safeguarding for food and safety hygiene in reuse targets – an oversight that, according to FoodDrinkEurope, is not amended in the new rules.

Design, aesthetics, and the market

Plastics Europe is supportive of the Design for Recycling criteria’s ability to assess the recyclability of packaging, as well as the recycling requirements developed in tandem with relevant stakeholders. On another note, though, FoodDrinkEurope cautions that it is unsure whether there is enough recycled material on the market to meet recycled content targets for 2030, or whether what is available is affordable.

The company felt that the amendments should have implemented a reuse clause for these targets and reviewed their viability before the first deadline. Director general Dirk Jacobs stated that their true feasibility “remains to be seen” and insists that “it will also be important to ensure that national governments don’t start going beyond the proposed reuse targets, and in doing so, jeopardise the integrity of the Single Market, Europe’s most valuable asset.”

Additionally, FEVE is concerned about the ability to protect Intellectual Property Rights under the new legislation, resulting in homogenous packaging designs, loss of individual brand identity, and a decrease in commercial value.

“We fear this will result in standardized packaging and the gradual demise of brand differentiation,” Farrelly explains. “We are committed to ensuring that glass packaging solutions, agreed with our customers, are designed with the minimal necessary weight and volume.

“However, we believe this measure restricts creative designs and iconic shapes of bottles often reflecting cultural heritage products to be placed on the market in future. This will massively dent the economic value these products bring to Europe and beyond.”

Overall response

Rethink Plastic feels that the Compromise Amendments are ‘lukewarm’ and cautions that ENVI’s stance could ‘not only reduce the environmental ambition of the regulation’ but ‘undermine its future enforcement as well’. It urges MEPs to fix reported ‘loopholes’ in its new approach – gesturing towards the initial Commission proposal and the current Spanish Presidency compromise text as examples of more consistent and effective legislation.

Marco Musso, senior policy officer for Circular Economy at the European Environmental Bureau, argues that “the final text supported by the ENVI Committee is weaker than the original proposal as a result of unprecedented levels of lobbying from the biggest polluters in the single-use packaging industry.”

Policy manager for Circular Economy Jean-Pierre Schweitzer supports this view; “The long list of derogations and exemptions introduced in the compromises risks repeating the shortcomings of the current packaging directive whose vague and unenforceable requirements failed to limit the uncontrolled growth of packaging waste. The European Parliament Plenary must deliver a solid set of rules to reduce waste, restrict unnecessary packaging and promote reusable packaging solutions, not a patchwork of loopholes to meet lobbying requests.”

“The average lifetime of a packaging item does not exceed 20 minutes before it is thrown into a bin,” states Ioana Popescu, coordinator at Rethink Plastic. “Decision-makers should harness their regulatory power to drive ambition and support the mainstreaming of existing, proven solutions such as restrictions on certain types of packaging as well as reuse systems to reduce record-high amounts of packaging waste. Allowing business-as-usual practices to continue fuels the triple climate, biodiversity and pollution crisis.”

Zero Waste Europe has referred to the revisions as a ‘relief for policymakers’, describing the compromise as ‘less than perfect, but any further dilution would only serve the interests of the single-use sector.’

Head of Policy Aline Maigret comments: “While the text has been considerably diluted from the Commission’s original proposal, we believe this represents the best outcome we can attain at this point in time. Zero Waste Europe welcomes the adoption of the Rapporteur’s compromise amendments today, and commend MEP Ries for upholding the integrity of this bill.

“There were many challenges from opposing parties, as well as an unprecedented level of corporate lobbying. We eagerly anticipate the upcoming plenary vote in November for this crucial environmental bill.”

UNESDA has also “welcome[d] 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”, but opposes the measures that it believes will create “a patchwork of national targets that will have devastating consequences on Europe’s competitiveness”.

Industry players across the packaging value chain also responded to revisions made to the EU’s Packaging and Packaging Waste Directive last year, which were described as ‘arbitrary’.

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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.