As 2023 draws to a close, the packaging industry is looking at a whole new legislative landscape compared to the start of the year. To help us all wrap our heads around its development, we have compiled every story we’ve published on the Packaging and Packaging Waste Regulation (PPWR) so far into one article.

All the way back in November 2022, a draft of what was then a Packaging and Packaging Waste Regulation was leaked – and, in due course, brought forth as a proposal by the European Commission. Set to replace the existing Directive, it aimed to mandate recyclability for all packaging, minimize substances of concern (e.g. harmful chemicals), and improve the information available to consumers by setting labelling requirements.

It set restrictions on certain kinds of single-use packaging and required economic operators to minimize the amount of packaging they used, as well as laying down binding reuse targets. Packaging was to be collected, sorted, and recycled to a high standard, and waste management provisions and extended producer responsibility schemes were to be introduced – all without compromising pre-existing systems.

We entered the New Year with the promise that the proposals would be presented to the EU Parliament, the EU Council, and all twenty-seven Member States to come to a consensus, with the possibility of further revisions throughout the year. Let’s take a look at all the updates and conversations we’ve had since.


February was a month filled to the brim with discussion. In one of our earliest stories this year, the Alliance for Beverage Cartons and the Environment (ACE) called for the inclusion of a 90% mandatory collection target to ensure that all beverage cartons can be recycled at scale by 2035, as per the new rules. Although the proposed legislation established a 10% recycled content target for contact-sensitive packaging by 2030 – a figure that rose to 50% by 2040 – ACE did not believe that enough high-quality recyclate was yet available to reach these goals.

It warned that pursuing such ambitious targets anyway would worsen the market availability of recycled materials and raised the alternative of introducing an equivalent target for biobased and renewable plastics, thus relieving demand without reverting to unsustainable materials.

Meanwhile, the New European Reusable Alliance (New ERA) was forming. It welcomed the proposal’s efforts to uplift reuse and refill and include targets for some products and markets; however, the Alliance also pushed for policymakers to set their sights higher, based on the demonstrated best practice examples.

Oriol Segarra, secretary of New ERA and CEO of Bumerang, said at the time: “The proposal represents a great opportunity for establishing the conditions for the uptake of reusable packaging and accelerating the development of the infrastructure needed to build robust, cost-effective and environmentally sound reuse systems.”

Upon being welcomed as the new president of the Association of European Producers of Steel for Packaging (APEAL), Luc Brantjes, sales director, Packaging at Tata Steel Netherlands, expanded on the organization’s view.

“To properly achieve a circular economy in this time frame, packaging should not only be designed so that it is economically recyclable, but also be effectively and efficiently recycled at scale by 2030,” he explained. “This should include the introduction of minimum recyclability criteria for all packaging put on the market, ensuring a level-playing field across all materials.

“As such, I am pleased that mandatory recycled content targets are proposed to boost the uptake of certain recyclates with low demand, and not for materials such as steel which are already highly recycled, and significantly, where demand for scrap already exceeds supply.”

Matt Tudball, senior editor, Recycling at ICIS, was concerned that uncertainty in the legal text would impact future investment in sustainability-minded developments like reuse systems or chemical recycling.

He reported that, at the annual Petcore conference, representatives from the European Commission failed to shed further light on the status of chemical recycling. Marco ten Bruggencate, president of Plastics Europe and Dow’s commercial vice president Packaging & Specialty Plastics EMEA, feared that Dow could not make a final investment decision on a €300 million European plant in September if chemically-recycled materials did not count towards mandatory targets.

Additionally, Tudball observed that the European Commission did not seem to be responding to the “increasingly frustrated” industry players calling for revisions to the legislative measures, and argued that “speed may be presenting greater challenges to implementation when it comes to revisions of current regulations, giving the industry little time to understand and prepare for some huge changes that will impact it significantly.”

Isabell Schmidt and Martin Engelmann of the IK German Plastic Packaging Association proceeded to go into great detail with their own view on potential legislative improvements. In their eyes, the draft had potential to facilitate sustainable transformation, but contained “considerable economic and ecological risks for misguided decisions, which should be corrected in the legislative process”.

One critique was directed at the reported discrimination against plastics in Articles 22 and 26. Schmidt and Engelmann raised examples of reuse quotas applying only to plastic packaging, with no clear justification as to their reasoning and no similar equivalents for other materials.

Such action was feared to create “loopholes” that would enable “evasive behaviour” surrounding non-regulated single-use packaging made of alternate materials. To prevent this, Schmidt and Engelmann recommended that indiscriminate single-use packaging bans and reuse requirements should be enforced across products and segments, with no distinctions made between packaging formats or materials.

They continued to assert that the PPWR should negate the “growing patchwork” of national bans and rules by creating a harmonized framework – which, in their view, would streamline a transition into an EU-wide circular economy with economies of scale and protective measures for the internal market.

A target had also been set in the then-current draft to lower packaging waste consumption per capita by 15% by 2040 compared to 2018. Schmidt and Engelmann hoped that efforts to lightweight and reduce the volume of packaging designs, meet restrictions on empty space in outer, transport, and e-commerce packaging, and preserve the functionality of the pack throughout all these changes should help achieve this goal.


We opened March with our ‘Get ready for the new Packaging and Packaging Waste Regulation’ webinar, featuring a panel of experts from Dow, Mars, and Amcor (it is available to watch on demand here.) The conversation revolved around the implications of the legislation for players in the plastic packaging industry, how the necessary alterations would reflect on packaging itself, and what could be done to get ready for the enforcement of the new rules.

This was followed by a statement from a coalition representing the European hospitality and beverage industry and its packaging value chain. It asserted that the impact assessment conducted by the European Commission was “not robust enough and need[ed] further clarification”, including tangible evidence that the measures would actually have the positive impacts they claimed to.

Although it agreed with the concept of a transition into reuse schemes, it was sceptical of the Regulation’s lack of acknowledgement for consumer engagement, or the steps that could be taken to increase positive perceptions of such systems.

As well as aligning with previous criticisms surrounding the speed at which the Regulation was to be enforced, the coalition hit back at the “one size fits all” approach to enforcing reuse laws for every Member State, sector, product category, and system at once. Concerns were raised that this method would stall or completely stop investments in recycling technologies, even in instances where single-use solutions would better serve the fight against packaging waste.

Nor was this approach thought to be backed up by the appropriate facts and figures, but instead by “unfounded EU aggregated numbers” that were not broken down by country, product category, or reuse solution. Figures calculated by PwC and Carbon Trust contradicted the estimated costs and carbon savings associated with circular reuse systems such as deposit return schemes (DRS) and refillables, which brought into question the reliability of the Commission’s figures.

Another statement from Copa-Cogeca, Freshfel Europe, and Europatat condemned the PPWR’s ban on packaging for fruit and vegetables weighing less than 1.5kg. The measure was thought to go against existing life cycle analyses and material uses, with the companies listing decreased shelf life, hygiene risks, and increased food waste amongst the potential setbacks.

Instead of broader bans, the statement underlined the value of reducing unnecessary packaging, transitioning into recycled, degradable, and compostable materials in the appropriate contexts, and improving the collection, sorting, and recycling management of packaging on a national basis. More nuanced incentives and strategies life ecological labelling were also recommended.

On top of these suggestions, another cross-sectoral statement directed the European Commission and Member States towards mass balance – an approach already used to trace material characteristics across the sustainable forestry and fair-trade cocoa and chocolate value chains – as a method of developing harmonized calculating rules for implementing recycled content into plastics across the EU.

The signatories encouraged policymakers to lay out a clear timeline of when and how a mass balance chain of custody would be enforced in the pursuit of EU climate targets. They advised the establishment of a fuel-use exempt, harmonized calculation and verification method with third-party verification and certification, which they believed would ensure consumer trust alongside compatibility with chemical recycling routes.

Taking on a mass balance chain of custody in 2023 was expected to give Member States room to plan, finance, secure permits, and build the necessary recycling units and infrastructure to meet targets for recycled content in plastics by 2030 or 2040.


MEPs from The Alliance of Liberals and Democrats for Europe (ALDE) were unsure of the mandated implementation of reusable materials in dine-in restaurants, which could apparently worsen both water waste and carbon emissions.

Amongst a panel of experts from the public and private sectors, Johan Aurik, chairman Emeritus at Kearney, asserted that basing legislation in evidence is an important factor in taking meaningful steps towards sustainability and protecting investment in relevant infrastructure. He warned that many of the SMEs set to be impacted by the proposals are independent and lack the resources to enforce the rules effectively, which could cause a 1500% increase in plastic waste and, factoring in the required logistics, a surge in carbon emissions.

“It is very important that there is specificity,” he said. “The right metrics and the right set of solutions that allow flexibility in this sector in a successful way.

“Make legislation that is written so different paths can be achieved, and chosen by different industries, different sectors, and different markets. There must be scalable solutions to invest in long-term.”

Similarly, four industry leaders shared their viewpoints on the legislative revisions with Packaging Europe.

Joan Marc Simón, director of Zero Waste Europe, explained the company’s view that the PPWR should be material-neutral and work towards maximum circularity for packaging in Europe. In its then-current form, the proposals were said to target materials with the highest carbon footprint, such as single-use glass, without bridging the gap between material safety and circularity.

“The new legislation is right to address the alarming trend of growing packaging waste generation and plastic pollution by focusing on prevention and reuse and making sure quality recycling becomes a reality,” Simón stated. “The prevention and reuse targets set the foundations for reversing the current trend and they should be strengthened, not weakened. The current proposal is completely off the climate Paris Agreement with most materials overshooting the available carbon budget.

“Whether packaging is reusable or single-use, the new legislation should ensure that both options are as performant as possible. For that to happen reuse targets should be complemented with the right criteria and requirements for the new infrastructure to be built in an inclusive manner.

“In order to ensure a minimum degree of circularity, single-use packaging should be collected at a minimum of 90% rate, have high recycled content, be safe to use and recycle, and have an acceptable carbon footprint.”

Tracy Sutton, lead consultant and founder of Root, added: “I also have a few questions around criteria like recyclability. Because if we’re defining that by things being recyclable at scale with state-of-the-art recycling, that’s quite a high bar.

“The questions for me are: what percentage of Europe has got state-of-the-art recycling, and how is that going to relate to the definitions that the Directive puts out, versus what the consumer or user is seeing? So I think the definitions that get confirmed will be quite important.”

The Ellen MacArthur Foundation’s senior policy manager, Carsten Wachholz, approved of the introduction of reuse obligations for some transport and beverage packaging and held out hope for such rules to reach other sectors, e.g. home and personal care products, in the future.

From EUROPEN’s perspective, secretary general Francesca Siciliano Stevens emphasized that the packaging industry has already taken steps towards enhanced recyclability and wished for the European Commission to include such work in its Design for Recycling guidelines.

“Collection is also very important,” she added. “It is clear that without some mandatory collection and collection targets we will not see recyclability happen at scale. I don’t think that this has kicked in yet in the minds of legislators, because unless we seriously step up collection, we might not see a lot of packaging on the market by 2025.

“And this is where the Proposal doesn’t do much. It doesn’t introduce mandatory collection targets for the different packaging formats, when in some of these formats collection is essentially nowhere. This is where legislators and the environmental community have been absent so far.”


May ushered in a series of strong opinions surrounding the PPWR. A joint letter signed by over 120 packaging industry associations cautioned that packaging bans, reuse and recycled content targets, and labelling requirements had caused roadblocks in the internal market, threatened economies of scale, and diverted both investments and R&D. To unlock free movement for packaging material and packaged goods across the continent, the signatories claimed, a robust single market is necessary.

A strong secondary market was also recommended as a means of boosting circularity and economies of scale, thus assisting in Europe’s green transition and global competitiveness. However, the signatories warned against a fragmented Union market and a ‘patchwork’ of national packaging legislations, fearing that they would cause further strain.

On the other hand, a joint statement from 185 investors with combined assets of US$10 trillion called upon industry players to rally around plastic reduction policies like the PPWR rather than lobbying against it, with Arthur van Mansvelt, senior engagement specialist at Achmea Investment Management, describing prevention and reuse as “their chance to be part of the solution”.

Nevertheless, the Renewable Carbon Initiative (RCI) published a position paper promoting a complementary renewable content target into the PPWR. In theory, this would involve bio- and CO2-based feedstocks being used in packaging and increase the potential of both biomass and direct carbon capture and utilization.

In turn, RCI envisioned a decline in greenhouse gas emissions and additional options for packaging producers as they seek out more sustainable solutions. Further support from policy and framework conditions were encouraged to drive depolymerization, gasification, pyrolysis, and other advanced recycling processes – thus closing the polymer, monomer, and molecular loops left open by mechanical recycling processes.

Still, it was generally positive about mandating the compostability of very lightweight plastic carrier bags, sticky labels for fruit and vegetables, and certain types of tea and coffee packaging in biowaste treatment facilities. RCI connects this ambition with scientific research into the “true environmental effects” of biodegradation and composting and recommends its inclusion in EU legislation.


In June, we spoke to Metsä Group’s vice president of Climate and Circular Economy, Maija Pohjakallio, and Jarkko Tuominen, vice president of Projects at Metsä Spring, about their general view on the PPWR revisions.

In their experience, manufacturers were becoming confused by the definitions and grading of materials and packaging solutions, which posed a particular threat to start-ups. They explained that newer, smaller companies were at greater risk if they kept investing in product development in a rapidly evolving legal landscape, given the uncertainty that their products would even align with the final text.

While they commended the proposal’s focus on lowering packaging waste, Pohjakallio and Tuominen were not so confident on its prioritization on reuse over recycling. There is no one-size-fits-all solution to circularity, they emphasized, and in their opinion, the proposal did not acknowledge this nuance.

For instance, the blanket enforcement of reusable packaging in restaurants was expected to drive manufacturers back to using conventional, fossil-based materials to meet reuse targets. Reusable packaging also necessitates additional energy use for washing processes, they added, which could then require the construction of washing and preparation facilities on-site – and, ultimately, the payoff for these investments depends on consumer compliance.


July saw Packaging Europe publish an article bringing together Reloop, Zero Waste Europe, and The European Container Glass Federation (FEVE)’s viewpoints on glass reusables, as well as collection, sorting, and recycling systems for single-use glass. It raised fears that, if the PPWR draft was set into motion in its current form, there would be a sharp rise in single-use glass that would not be adequately recycled, since the material was exempt from the mandated treatments for metal and plastic beverage packaging.

To prevent this from happening, a “gradual shift” from single-use glass into reusable alternatives was suggested. Reloop and Zero Waste Europe proposed material-specific waste prevention sub-targets with a focus on preventing excessive glass production and encouraging reuse.

New design standards should also be introduced for glass, the companies stated. This would involve at least 65% of the content of the packaging place on a Member State’s market between 2030 and 2039 constituting recycled material, with the figure rising to 85% from 2040.

Conversely, FEVE was critical of Reloop and Zero Waste Europe’s assertion that the PPWR draft gave glass a “free pass” and argued that European glass manufacturing already operates under a circular packaging model. It felt that closed-loop recycling, food quality preservation, and the migration of substances from food-contact materials were not considered in the other companies’ recommended measures.

Instead, FEVE’s suggestions involved a 90% collection rate, 100% recyclability for all glass packaging on the EU market by 2030, and the implementation of reusable packaging as a complementary solution to single-use.


By August, the European Parliament’s vote on the PPWR on September 20th was on the horizon. Neil Osment, managing director at NOA, noted that European politicians were focusing on the reuse of both plastic and paper packaging as a means of reducing production in an energy-efficient way – but he posited that this was not necessarily the reality.

Corrugated packaging is simply not durable enough to withstand many cycles, he explained, and its recyclability is already well-established. Over three-quarters of all corrugated board used in Europe is said to be produced from recycled paper and board.

Where plastic is concerned, Osment pointed out that reusable solutions like returnable containers required water at high temperatures, and thus energy, after every use – raising questions around its true CO2 or water savings.

He added that reusable systems “require massive initial investment in container stocks, washing, collection, storage, transport and distribution facilities” – which must always be replenished to keep the container ‘pool’ at optimum capacity – and points to a real-world attempt to introduce DRS in Scotland. As it was eventually withdrawn by the government, leading brand owners have made financial claims for the millions of pounds they invested in reuse bottling lines.

Therefore, Osment concluded that cost was contributing to reluctance from brand owners to back the PPWR. In his view, the ripple effect of the new legislation will not be felt until the 2026-2027 period, yet companies might be expected to make large investments upfront to align with their expectations.


A free White Paper from Smithers ran through the expected changes of the impact of the PPWR on the packaging value chain. It noted the disparity between increases in recovered packaging waste in the then-current draft text – 50% for both plastic and aluminium, 70% for both ferrous materials and glass, and 75% for paper and cardboard by 2025 alone.

The differences were attributed to the economic factors making metal, fibre, and glass recovery an attractive decision, while polymers have historically been more expensive to collect. Furthermore, converting post-consumer resins into new packaging faces many technical hurdles, including resin purity, colour, and processing performance; while Europe does have a growing market for rPET at present, other polyolefin materials are more difficult to decontaminate.

Corresponding with Osment’s line of thinking, Smithers noted that brand owners are pursuing a transition into paper, and it expected the PPWR to feed this ambition. Yet it drew attention to the removal of two initial suggestions – a 10% reuse and refill target for takeaway food packaging in the HORECA sector, and a 20% equivalent for HORECA beverage packaging – from the amended text in April 2023, citing the difficulties of demonstrating the environmental benefits of reuse in that particular space.

Following this, PepsiCo Europe’s chief sustainability officer, Archana Jagannathan, argued that at-home refillable bottling solutions had been overlooked in the legislation. She acknowledged that all reuse models played a part in lowering emissions and packaging waste, but refill-at-home models cut down on the energy and resources required – as well as the length of time a refill loop takes – by allowing consumers to do most of the work from their own homes.

Alena Maran, director of Strategy & Sustainability for Avery Dennison LPM, urged the European Commission to incentivize sorting and recycling facilities to invest in state-of-the-art technologies, boosting price competitiveness when compared to virgin or imported recycled materials. In doing so, she hoped that recyclate quality within European borders would improve.

She stressed that Design for Recycling guidelines should focus less on banning packaging characteristics and more on a product’s end-performance. All EcoDesign guidelines should centre around science-based testing protocols, she continued, which must be developed collaboratively to ensure that they achieve the desired environmental outcome.


Reloop, the Ellen MacArthur Foundation, Zero Waste Europe, TOMRA, and other signatories of a position paper indicated that, while the PPWR’s stance on reusable packaging and the logistics of its rollout were perceived as unclear, its inclusion of reuse targets could be beneficial.

According to the signatories, developments in recycling are making efforts to catch up with increased packaging use but are not contributing to its reduction; and recycling is not a silver bullet in decreasing Europe’s material and carbon footprints in line with its environmental and climate goals.

In addition, they asserted that switching out one single-use material for another does not inherently lead to circularity.

Reuse at scale was offered up as a potential solution, as it would theoretically maintain the value of packaging for a longer period of time and prevent a direct correlation between material extraction and long-term carbon emissions.

A clear definition for reusable packaging designs – for instance, a minimum number of reuse cycles – was underlined as an essential facet of this transition. The signatories also suggested that manufacturers and final distributors should be held to obligations to offer and take back reusable packaging across the value chain, alongside high, long-term, and mandated targets to encourage investment and development.

It was recommended that reuse systems be backed with transparent reporting to allow for reflection and continuous improvement. They should also be complemented by refillable packaging, the paper said, although there should be a clear distinction for models included under target and minimum criteria metrics.

It was anticipated that a transition into reuse would create 600,000 jobs within the EU economy, reduce reliance on imported natural resources, lower the costs of consumer goods.

In a comment piece, Professor Fabio Licciardello from the University of Modena – also a member of the Italian Scientific Group for Food Packaging (GSICA) – was less optimistic, warning that the PPWR’s reuse targets could become a threat to food safety and result in surging rates of food waste. He underlined his opinion that reusable beverage packaging utilizing aseptic technology would help overcome these roadblocks.

Without the appropriate safety measures, he claimed that reusable packaging could have adverse effects on shelf life, human health, and the environment. To name one example, studies have indicated that reusing plastic bottles runs the risk of contamination from chemicals, food, and microbes, as well as flavour and quality alterations in the product.

He added that overcoming the health risks requires expensive and abrasive sanitization procedures and refrigerated storage, while the environmental benefits of one reuse cycle for a glass bottle are cancelled out when transport and cleaning are factored in.

Licciardello concluded that single-use aseptic packs achieve the desired food safety measures while reducing food waste, negating the need for refrigeration, and unlocking recyclability where the necessary infrastructure exists.

Then came a significant breakthrough for the PPWR – the European Parliament’s Committee on Environment (ENVI) amended the draft text with new Compromise Amendments. Amongst its new proposals were waste reduction targets for plastic packaging; 10% by 2030, 15% by 2035, and 20% by 2030. Minimum recycled content percentages were also expected to be mandated by packaging type with targets for 2030 and 2040.

If they are not required as primary packaging for waste prevention or hygiene reasons, plastic carrier bags lighter than 15 microns are set to be banned in loose food applications. So-called “forever chemicals” like bisphenol A and PFAS substances, often utilized for fire or water resistance in fibre-based packaging, are also expected to be outlawed, and defining criteria for terms like “designed for recycling” and “recyclable at scale” are to be introduced.

90% of materials used in packaging – plastic, wood, ferrous metals, aluminium, glass, paper, and cardboard – should also be collected separately by 2029, according to the amendments.

The industry’s response was immediate and varied. The Permanent Materials Alliance felt that the rules enabled closed material loops for the ‘infinitely recyclable’ aluminium, glass, and steel materials, and Cepi supported the introduction of high collection targets – yet both felt that the amendments’ definition of ‘high-quality recycling’ impeded on the full potential of their respective materials.

Many of the bans and reduction targets were described as “arbitrary” and accused of unfairly targeting plastic packaging. Plastics Europe argued that pre-existing recycling processes for flexible plastics, which play a valuable role in product protection and transportation, would be impacted by the suggested legislation.

Moreover, UNESDA Soft Drinks Europe expressed its disappointment that an exemption mechanism had still not been introduced for reuse and refill targets. It felt that existing steps towards circular systems, the investments made to take them, and the complementarity of reuse, refill and recycling would be rendered useless if the new rules are passed.

FoodDrinkEurope took a similar stance, adding that the proposed rules were still missing any acknowledgement of food safety in reuse schemes. Discussions were also taking place around the physical and financial accessibility of recycled materials to successfully meet 2030 targets; as well as the impact of the new legislation on Intellectual Property Rights and on-pack brand identity.


In the lead-up to the plenary vote on the PPWR, UNESDA was one of many European organizations to sign a joint letter promoting the complementarity of reusable and single-use packaging. Their specific concern lay with Article 26, in which Member States could progress beyond the proposed reuse targets without any justification needed. This admission was thought to contradict the overall goal of harmonization and allow for the creation of fragmentary national targets that posed a threat to the EU Single Market – and, in turn, the enforcement of the Regulation as a whole.

Apparently, no impact assessment has been conducted to justify exceeding EU targets, and Member States are not allowed to opt into single-use packaging, even in circumstances wherein recycling would benefit the environment or waste management.

However, the letter commended the Compromise Amendments for distinguishing between circumstances wherein reusable and refillable packaging solutions would and would not be environmentally beneficial, and for recognizing that economic operators should have alternative options if they can prove single-use packaging would improve sustainability.

It suggested the use of a life cycle assessment, recycling rate, or collection rate as proof of viability to justify exemption from reuse targets and asked the Environmental Committee to reject proposals that would increase reuse targets above the levels proposed by the European Commission. Plenary amendments were also suggested as a means of proposing mechanisms that would ensure complementarity between reusable and single-use recyclable packaging.

A week prior to the plenary vote, representatives from the natural mineral water and soft drink industries pushed for policymakers to enforce a priority access right to recyclates. In their eyes, this would prevent what they felt to be unfair competition between industry players and ensure that the appropriate amount of recycled materials are allocated to the sectors most in need of them.

Currently, only recycled PET is authorized as a food-contact material within the EU. The drinks industry maintained that it could not meet mandatory recycled content targets with limited and unstable access to food-safe materials, especially with the prevalence of downcycled plastic.

Returning with another comment piece, Neil Osment suggested that updates to the PPWR was beginning to favour paper-based packaging. He attributed this change to “extensive lobbying by brand owners and retailers” – yet he was pessimistic about the speed at which the legislation would take effect.

“To make PPWR even workable it has been split into sub-projects,” he warned; “in reality, it could be three to ten years until PPWR makes itself felt throughout Europe.

As Ivana Sobolíková, Impact Strategy Specialist at MIWA Technologies, ran us through the persistent disagreements between reuse and recycling, Natural Mineral Waters Europe (NMWE), Minderoo Foundation, Reloop, UNESDA, and Zero Waste Europe warned against overturning compulsory DRS. In a joint letter, they stated that recent initiates into deposit return schemes – Latvia, Slovakia, and Malta, to name a few – had reported collection rates as high as 90%, and the figure is said to increase to 95% in countries with well-established systems.

On the other hand, they warned that countries like France, whose 60% PET bottle collection rate falls short of the EU Single-Use Plastics Directive’s 77% target for 2025, could miss the PPWR’s targets if DRS do not become mandatory. Only nations that can prove similar collection rates for Extended Producer Responsibility schemes should be exempt, they argued.

At this point, the European Parliament adopted its position on the PPWR in a plenary vote, and NMWE expressed its disappointment that its hopes for mandatory DRS had been dashed.

Krassimira Kazashka, CEO of Metal Packaging Europe, added that “the European Parliament missed the opportunity to have a more robust definition incentivizing materials that can withstand multiple recycling loops without any change to their main material properties, stimulates design for recycling and further boosts effective and efficient recycling.”

Similarly, Raphaëlle Catté, Policy & Research Support at Zero Waste Europe, commented: “By favouring recycling over reuse, the new derogations in Articles 22 and 26 question the whole foundation of EU waste law, namely the waste hierarchy.

“Recycling will not stop the waste problem, even with robust systems. It is worrying that not only right and far-right parties, but MEPs from all backgrounds yielded to lobbyist arguments.”

Not everybody took such a critical stance. In the words of UNESDA director general Nicholas Hodac: “While we still have concerns regarding the increased targets without further impact assessment, we are pleased with MEPs’ support for systems enabling refill and the creation of mechanisms that will enable the complementarity of reuse and recycling. This will ensure reusable packaging is introduced where and when it makes the most sense from an environmental perspective.”

Flexible Packaging Europe commended the Regulation for clarifying its deadlines for recyclability requirements and declaring food-contact flexible transport packaging exempt from reuse targets. The latter move is expected to cut down on food waste, emissions, and contamination.

Yet the organization pointed out that sorting waste that is not collected in separate streams remains voluntary, which leaves various types of packaging at risk of ending up in landfill, incinerators, or the natural environment. It also joined EUROPEN in defending the EU Single Market and cautioning once again that harmonization across the continent will be weakened if Member States are allowed to set their own national measures.

Roberto Ferrigno, head of EU Affairs at European Bioplastics (EUBP), was also hesitant to embrace the Parliament’s stance due to its potential impacts on his own sector.

“We regret that the role of biobased plastics in achieving the targets of recycled content was not supported,” he said. “EUBP believes biobased plastics can and will, if enabled, contribute to the transition towards a circular economy, by storing and repurposing carbon dioxide.”

Packaging Europe got stuck into the discussions, too. Tim Sykes sat down with Avery Dennison policy specialists Emilie Bartolini and Alena Maran in a podcast to hear what they had to say about the PPWR’s potential challenges and opportunities, and how companies can ‘PPWR-proof’ themselves before the legislation is enforced.

At the Sustainable Packaging Summit 2023, we brought together Maran and Francesca Siciliano Stevens; Feliks Bezati, global circular packaging director at Mars; Packaging Europe Ambassador and VGV Corporate managing director Bruno Van Gompel; Sophia Chrysopoulou, EU Public Affairs and Government Relations director at The Coca-Cola Company; Tahmid Chowdhury from the Cambridge Institute for Sustainability Leadership; and Wolfgang Trunk, DG Environment, European Commission – all united on one stage to discuss European legislation.

Although there was general agreement on the importance of harmonized rules, discussions held at the Summit reiterated concerns around threats to a Single Market, high recyclate prices stalling investment and innovation, and limitations caused by strict Design for Recycling rules.


In the final month of the year, Returnity Innovations CEO Mike Newman spoke to Packaging Europe about a potential alternative to the prevalent recycling versus reuse debate – how the PPWR would affect consumers. He claimed that the average Joe would have to make significant behavioural changes for the new legislation to be truly effective.

In his words: “I’d be much more optimistic if we’d started with those harder questions, like will consumers change their behaviour, and if so, why? Why will they start properly recycling - or follow through on reuse - when they didn’t previously?

How much will it cost retailers and consumers to facilitate that behaviour change? How quickly will we see consumers follow through on this behaviour change such that we are actually reducing packaging impact?”

Eight signatories from Europe’s reusable and refillable packaging industry supported the General Approach, describing the current draft of the PPWR as an “insufficient response” to the waste crisis that is “full of derogations and reduced aspirations”. The joint letter posited that ambitious reuse targets would bring Europe closer to environmental and economic progress, with the continent hoped to share its waste management solutions with the rest of the world.

With its reliance on global supply chains lowering and local economies supported, this approach is expected to help Europe lower inventory and waste management costs, increase its energy savings, and lower price sensitivity as resource costs rise.

Over 100 associations in the European packaging industry also called upon EU Member States to preserve the Single Market and prevent supply chain disruption. EUROPEN reiterated that nation-specific laws could prevent packaging materials from travelling freely across borders and have a negative impact on the economy.

Yet the highlight of December was the European Council introducing a ‘general approach’ on a PPWR proposal, which will serve as a mandate for negotiations with the European Parliament next year. It is intended to match the scope of the original draft by covering all packaging materials and waste – in the latter case, it aims to remain indiscriminate of origin, ranging from industrial to household waste.

Among its many mandates, it clarifies that packaging is considered recyclable when it is designed for material recycling and its components can be separately collected, sorted, and recycled at scale. Defining criteria have been introduced for reusable packaging, too, including a minimum number or trips or rotations required for a pack to be considered reusable. Cardboard is allocated a lower minimum number of rotations due to its material properties and is exempt from new requirements.

With the exception of protected packaging designs, manufacturers and importers will be required to minimize the weight and volume of their packaging.

Based on 2018 targets, new goals have been introduced for minimum recycled content in plastic packaging. Waste must decline by 5% by 2030, 10% by 2035, and 15% by 2040, and these targets are set to be reviewed eight years after the regulation enters into force.

New reuse and refill targets have also been introduced for 2030 and 2040, varying between large household appliances, takeaway food and beverage packaging, alcoholic and non-alcoholic beverages (with the exception of wine), transport packaging (excluding packaging for dangerous goods or large-scale equipment and flexible packaging making direct contact with food), and grouped packaging.

In order to meet a 90% separate collection target for metal beverage containers and single-use plastic bottles by 2029, Member States are urged to establish deposit return systems. However, if a DRS system existed before the regulation enters into force and achieves the 90% target prior to the deadline, or if a Member State reaches a separate collection rate higher than 78% in 2026, they will be exempt from this rule.

Controversially, Member States will be able to set their own prevention measures for packaging waste that exceed these minimum targets and lay out their own exemptions for single-use plastic restrictions under certain circumstances, including for organic fruit and vegetables.

Labels and on-pack information are now subject to stricter rules when informing consumers of a pack’s material composition and its appropriate disposal at end-of-life, although the approach maintains a level of flexibility to acknowledge existing labelling systems amongst certain Member States.

The regulation’s date of application has been extended to eighteen months after its entry into force.

After the announcement, the packaging industry had its say once more. The Council’s exemptions to the 90% separate collection target came under fire from several industry players, with many hoping that enhanced collection processes would have increased access to high-quality recyclate.

According to UNESDA, the general approach continues to treat reuse and recycling as separate, non-complementary processes. While it was supportive of reusable packaging as one of several pathways towards achieving EU targets and cutting down on packaging waste, it continued to push for exemption mechanisms for reuse and refill targets.

“Not all recycling has the same environmental value,” added FEVE’s Adeline Farrelly. “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.”

FEVE also criticized the measures for their inequal distribution of effort between packaging materials to reduce packaging waste. Reportedly, they overlooked “the contribution that circular packaging can make to competitiveness and sustainable growth” and do not adequately address packaging design or Intellectual Property Rights.

Robert Ferrigno from EUBP described the measures as “a weak General Approach, barely recognising the value of a very short number of compostable applications and hindering biobased innovative solutions.” In his view, split opinions between Member States and decreasing ambition in the text itself would lead to fragmentation in the internal market and challenge the implementation of the PPWR.

Its recyclability provisions were a “missed opportunity to showcase high ambition in advancing the circular economy and positioning the European Union as a global leader in sustainable practices,” according to the Permanent Materials Alliance. The organization believes that, in their current form, the overall packaging waste reduction targets are driving the industry towards hard-to-recycle packaging materials rather than so-called ‘permanent materials’ like aluminium or glass.

On a more optimistic level, Zero Waste Europe stated that the Council’s approach was a “strong foundation” for negotiations in the upcoming trialogues compared to the Parliament’s position. Nevertheless, it still described the approach as “watered down” and accuses political players from Finland and Italy for influencing the removal of reuse targets for wine packaging and the reintroduction of exemptions for cardboard.

“It is encouraging that the Council acknowledges the differences between recycling technologies, notably regarding energy requirements and greenhouse gas emissions,” said Lauriane Veillard, Chemical Recycling and Plastic-to-Fuels policy officer. “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.”

And, in our final update for 2023, the Brewers of Europe sought a level playing field for alcoholic beverage packaging. It accuses the general approach of being “discriminatory” and failing to facilitate fair treatment between competing products, arguing that there is “no reason” for beer to be subject to reuse and DRS expectations when wines and spirits are not.

Instead, it calls for a fair regulatory framework that benefits all alcoholic beverage producers equally – suggesting that, even though the European Council has agreed to a negotiating mandate by a qualified majority, the legislation still can and should be changed in the lead-up to the trialogues.

That brings us to the present, where we look ahead to negotiations between the Parliament, the Council, and the Commission in January. As always, we will bring you updates as they come!

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