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Following a provisional agreement between the European Parliament and Council on the Packaging and Packaging Waste Regulation, the packaging industry has made its stance known – praising action against ‘forever chemicals’ and eventual reviews of biobased plastic content, yet criticizing the removal of reuse targets for takeaway food and lobbying for single-use paper.

The positives

Carla Worth, policy lead at Common Seas, describes the Regulation’s efforts to combat plastic waste as a “historic move”.

“Whilst the legislation still has some final hurdles, this is nevertheless a moment to celebrate,” she says. “The world produces 141 million tonnes of plastic packaging a year and we need to turn the tide before it’s too late.

“With effective plastic bans, paired with active Extended Producer Responsibility and Deposit Return Schemes, the EU can lead the world forward in the fight against plastic pollution.

“With our collective sights set on Ottowa and INC4, huge milestones like this are receiving comparatively less attention. However, the European Union is setting an important precedent by focusing on upstream interventions, such as bans and reduction and reuse targets – all of which will help turn the tide on plastic waste production.

“The solutions we need to end plastic pollution are in our hands - now is the time to use them.”

The Rethink Plastic Alliance “applauds stricter provisions” when it comes to substances of concern and PFAS, or ‘forever chemicals’, in food packaging. It anticipates that a mandatory future report examining the presence of substances of concern in packaging will shed light on the impact PFAS have on circularity, chemical safety, and human and environmental health.

Approving of the deal’s ban on PFAS in food packaging, Zero Waste Europe’s Toxic-Free Circular Economy policy officer, Dorota Napierska, comments: “We are truly relieved to see policymakers taking action on these harmful and extremely persistent chemicals through the PPWR.

“This means recognizing the urgency of phasing out PFAS from food packaging and prioritizing consumers’ health. This will hopefully also send a clear message to food packaging manufacturers that all other substances of concern that we currently find in food packaging should also be eliminated in the coming years.”

European Bioplastics also approves of the new measures, which include a review of the development of biobased plastic packaging three years after the Regulation enters into force – and, from this, introducing sustainability requirements for biobased content in plastic packaging.

Head of EU Affairs Robert Ferrigno stated: “While we wait to see the details of the agreement and evaluate its impact on the biobased and compostable plastics market, we commend the legislators for acknowledging the role of compostable applications and biobased innovative packaging solutions in achieving packaging waste prevention, reaching recycling targets and their contribution towards a fully circular economy.

“In the coming months, EUBP will engage with EU decision-makers and stakeholders to set an appropriate framework for the potential upcoming targets and sustainability criteria for biobased feedstock in plastic packaging. We will also be vigilant to ensure that the many exemptions granted to Member States do not prevent an EU level playing field for economic operators.”

Our own brand director, Tim Sykes, shared his own input on the revisions as a whole; “At first reading, yesterday’s PPWR agreement appears a reasonable set of trade-offs between competing goals: a strong endorsement of reuse while taking steps to avoid damaging the circular economy in single-use packaging materials.”

Nevertheless, the new measures have not come without their criticism, and Sykes adds that there are “lots of wider implications for those with more detailed knowledge to unpack – as we’ll be doing at the Sustainable Packaging Summit later this year.”


The Rethink Plastic Alliance asserts that binding packaging reduction targets for Member States – 5% by 2030, 10% by 2035, and 15% by 2040 – will help cut down on the rise of packaging waste within the EU. It also suggests the establishment of reuse targets for beverage and transport packaging, among other sectors.

Various industry players have criticized the new measures, believing they do not go far enough in driving reuse. Zero Waste Europe’s head of policy, Aline Maigret, states: “We needed stronger action on waste reduction and reuse packaging systems, instead we got a dizzying amount of regulatory loopholes for single-use packaging. It is environmentally and economically absurd.

“The European Parliament has launched an investigation into the flagrant disregard for due process exhibited by the demagogues of the single-use sector, which should tell you everything you need to know.”

In a LinkedIn post, the New European Reuse Alliance (New ERA) described the new measures as “concerning” and “very disappointing for the reuse and refill industry” – noting the removal of reuse targets for takeaway packaging and the implementation of a general derogation to meet reuse targets if certain recycling rates are achieved. In the company’s view, these measures “go in the opposite direction of the PPWR’s objectives of reducing packaging waste and promoting reuse and refill”.

Zero Waste Europe is similarly critical, describing the measures as “another win for the paper industry lobbyists, since this sector has largely shifted to single-use paper-based packaging, especially after the adoption of the Single-Use Plastics Directive.”

Packaging & Reuse policy officer Larissa Copello comments: “It’s unsettling how the paper-based packaging lobbyists managed to get a ‘free-ride’ in the PPWR by escaping from market restrictions and some of the reuse targets at the expense of the environment and the public interest. When it comes time to implementing the PPWR, we hope it won’t lead to regrettable material substitution, and instead encourage real packaging waste reduction through well-designed reuse systems.”

Cardboard and paper

On a related note, the Rethink Plastic Alliance feels that the Commission’s initial proposal has been “watered down by a plethora of exemptions and derogations”, including restrictions for unnecessary packaging that only focuses on single-use plastics and not single-use formats in general.

Indeed, the Alliance condemns the exclusion of cardboard packaging from reuse targets for transport. It blames the measure’s introduction on “unprecedented pressures from single-use paper lobbies” and fears it will simply replace the excess of waste plastic with an excess of waste paper – thus failing to change wasteful behaviours and impacting the effectiveness of the Regulation, as well as putting additional pressure on forests.

Sergio Baffoni, senior packaging paper campaigner at Environmental Paper Network, commented: “McDonald’s and the paper packaging industry managed to distort and empty a regulation born to reduce single-use packaging, which now is promoting it, at the cost of the global forests and climate. Lobbyists are now celebrating, but consumers will continue to be flooded by increasing amounts of waste in their own homes – just this time made from paper.”

Paul Foulkes-Arellano, founder of Circuthon Consulting, was also critical. He stated that the new rules “failed to outlaw cardboard fast-food cartons and coffee cups or force consumers to use reusable containers. This marked a victory for single-use throwaway paper packaging manufacturers who have waged a fierce campaign against the regulation since it was first proposed by the European Commission in 2022. Legislators have buckled.”

“This is a step in the right direction, but a much larger leap is needed,” says Valeria Botta, head of Circular Economy & Nature at the Environmental Coalition on Standards, in a similar statement. “The reality is that growing unnecessary packaging and overpackaging is a waste of resources – and recycling alone is just not enough.

“We need more support for reuse and refill options to use less material and prevent waste.”

While an agreement has been made to rule out the incineration and landfilling of recyclable packaging, Zero Waste Europe asserts that it is currently unclear whether this only refers to packaging waste collected separately or includes mixed streams. Its solution is to enforce mixed waste sorting before incineration and landfilling.

Tricky politics

Dr. Martin Engelmann, managing director at the IK Plastic Packaging Industry Association, explains that the Commission has not yet agreed to the compromise. This means it could still veto the decision – and the final agreement must be checked by lawyers, which could delay the conclusion of the negotiations past the expected end date of June 2024.

He says that the current parliament could still vote on the provisional compromise during its last week of session at the end of April, but believes the newly elected parliament will make the final decision, likely at the start of 2025.

As the European elections approach, multiple industry players have encouraged the European Parliament to ratify the compromise and the Commission to sign the agreement promptly, preventing the process from being delayed and the text from being altered down the line.

Furthermore, the Commission originally proposed that industry players in Europe should only be able to source their recyclate from waste generated in the EU. Engelmann argues that this would be in violation of international World Trade Organization rules – “because, for example, a US manufacturer of biscuits would first have to import recycled materials from the EU in order to then be able to market the biscuits with packaging in the EU.

“For the Commission, changing this regulation is a must. However, there are definitely supporters of such protectionist measures in Parliament and among the member states.”

In conclusion, he cautions against ‘hasty action’, stating: “The PPWR is too important to ignore. What the economy needs above all is legal and planning security in order to be able to invest in the circular economy.

“On the one hand, it is painful to have to wait another year for the law. On the other hand, the time gained should be seen as an opportunity to make clear and, above all, legally secure regulations.”

Zero Waste Europe’s Chemical Recycling & Plastic-to-Fuels Policy Officer, Lauriane Veillard, expresses related concerns. She states that “the absence of the European Commission’s support for the final text due to the issue of imported recycled plastic is worrying as it is of utmost importance that recycled materials are of the same quality and meet the same requirements wherever they are produced, to protect true circularity principles in the EU.

“This gap in support means that implementation and controls will, here again, gain primacy as we know that they are currently not sufficiently established.”

Also, EUROPEN secretary general Francesca Stevens praises the deal for “strik[ing] a balance between ambitious environmental goals and the practical realities of implementation within the packaging sector” – yet adds that “we remain concerned about the potential for further market fragmentation, which could jeopardize the seamless operation of the Single Market and impeding our collective progress towards circularity.”

Additional detail on the Regulation’s development throughout 2023 and the packaging industry’s response can be found in a guide compiled by Packaging Europe.

Previously, a joint industry statement warned against the text’s references to ‘state-run producer responsibility organizations’, believing that leaving any legal loopholes open could threaten the EU’s recycling targets and decarbonization goals.

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