Packaging is a growing source of waste. It is also one of the major users of virgin materials. The European Commission hopes to solve this problem by revising the Packaging and Packaging Waste Directive (EU Packaging & Packaging Waste Directive, PPWD).
The average European produces almost 180 kg of CO2 packaging waste per year. Packaging is a major consumer of virgin materials, accounting for 40% of the plastic and 50% of the paper used in the EU. Unless action is taken, packaging waste in the EU will increase by a further 19% and plastic packaging waste will increase by 46% by 2030.
Here comes the new packaging and packaging waste regulation, which the European Commission sees as an important tool to address this growing problem. The Packaging and Packaging Waste Regulation, also known as the Packaging Directive (PPWD), is a set of rules implemented by the European Union (EU) to manage packaging and packaging waste in an environmentally friendly manner. The EU first adopted this standard in 1994 and has since updated it to include more ambitious recycling and waste reduction targets. The latest update to the Directive is the adoption of the Single-Use Plastics Directive which includes specific measures to reduce the environmental impact of certain single-use plastic products. As of July 3, 2021, the EU no longer allows certain single-use plastic items to enter the markets of member states, such as tableware, plates, straws, stirrers, cotton swabs, food and beverage containers made of expanded polystyrene, and products made of oxygen-degradable plastics. The Directive requires Member States to take action to curb the consumption of these products, for example through consumption reduction targets, design requirements and labeling requirements. The directive also requires member states to implement extended producer responsibility for certain single-use plastic products.
Revision of PPWD
But the EU wants to go further. In the wake of the European Green Deal and in the new Circular Economy Action Plan, the European Commission has committed itself to some ambitious targets. For example, establishing requirements to ensure that by 2030 all packaging on the EU market can be reused or recycled in an economically reasonable manner. Therefore, the Commission chose to revise the current PPWD. first, the European Commission decided that the best way to address the legislative challenge was to develop regulations rather than issue directives. The difference is easy to explain: a directive defines the objectives to be achieved by EU member states and allows flexibility in the way these objectives are achieved, while a regulation is directly applicable and entirely mandatory, aiming at the uniform application of EU law throughout the EU.
Until February 1, 2023, the proposal was still under public discussion. Subsequently, the draft was submitted to the European Parliament and the European Council for consideration. The next step in the legislative process is underway. Due to the complexity of the dossier, the legislative work of the joint legislators is expected to be quite lengthy and may even take more than a year to complete.
The committee identified three highly relevant issues that impede the packaging cycle:
1. low level of recyclable packaging 2. high and increasing amount of packaging waste 3. low level of recycled content
The proposal therefore introduces a number of new rules for packaging sold in the EU, in particular for its:
1. recycling capacity 2. reusability 3. size 4. absorption of recycled content
"We generate half a kilogram of packaging waste per person per day. Under the new rules, we are proposing key steps to make sustainable packaging the norm in the EU," said Virginijus Sinkevič ius, Commissioner for Environment, Sea and Fisheries. " We will create the right conditions for the implementation of circular economy principles - reduce, reuse, recycle. More sustainable packaging and bioplastics are about new business opportunities in the green and digital transformation, about innovation and new skills, local jobs and consumer savings.
The proposal would also end confusion over which packaging belongs in which recycling bin. All packaging will be labeled to indicate what it is made of and where it should be placed in the waste stream. The same labels will be placed on waste collection containers. The same symbols will be used throughout the EU.
Recyclability
The following requirements:
1. Designed for recycling (from January 1, 2030)
2. Separate collection exists
3. Have the capacity for large-scale recycling (from January 1, 2035)
4. has the potential to be recycled in such a way that the secondary feedstock obtained is of sufficient quality to replace the primary feedstock.
Secondary legislation will be needed to translate the above into practical examples. For example, the recycling-oriented design has not been specified. In addition, the Commission wants to establish a so-called recycling performance system. Packaging will be graded from A to E according to its recyclability, with E indicating non-recyclable and therefore banned from the EU market.
Reusability
PPWD's proposal expects all packaging placed on the EU market to be designed and used to maximize reuse. Specific reuse targets will apply to the foodservice and e-commerce sectors and will also affect transport packaging.
Retailers who bring reusable packaging to market must ensure that a reusable packaging system is available. For example, consumer packaging for alcoholic and non-alcoholic beverages (excluding wine) must meet a reusability target of 10%, rising to 25% by 2040. Stricter regulations will apply to food takeaway packaging, which will have to meet a reusability target of 40% by 2040.
For transport packaging, the goal of 100% reusability will apply to the transport of products.
1. Within a member country
2. Between different locations of the same enterprise or between the enterprise and its affiliates or partners
This applies to pallets, boxes (excluding cardboard pallets), plastic boxes, medium-sized bulk containers, drums and cans of all sizes and materials, including flexible formats, used to transport packaging for products first placed on the market through e-commerce, and will be 10% from January 2030 and 50% from January 2040.
Package Size
In terms of weight and volume, each packaging unit must be reduced to its minimum size. The empty compartment ratio (the difference between the total volume of the grouped, shipping or e-commerce packaging and the volume of the internal sales packaging) does not exceed 40%.
Recycled Content
Plastic parts in packaging need to contain a certain amount of recycled content.
As of January 1, 2030:
1.10% for contact-sensitive plastic packaging made from materials other than PET, except for disposable plastic (super) beverage bottles
2.30% for contact-sensitive plastic packaging with PET as the main component
3. 30% for super bottles
4. 35% for other plastic packaging
As of January 1, 2040:
1.50% for contact sensitive plastic packaging, except super beverage bottles
2. 65% for super bottles
3. 65% for other plastic packaging
The Commission expects to establish, by December 31, 2026, a methodology for calculating and validating the percentage of recovered content per unit of plastic packaging recovered from post-consumer plastic waste, and the format of the corresponding technical documentation.
This plastics and plastics recycling industry is very supportive of the so-called mass balance approach.
In the mass balance method during the production process, the recycled material is mixed with the virgin material and a percentage of the recycled content is allocated to the resulting output based on the percentage of recycled material used in the production process. This approach allows manufacturers to use recycled materials in their products without the need to physically separate and track recycled materials throughout the manufacturing process.
Restrictions on the use of packaging formats
The PPWD proposal prohibits the following types of disposable packaging:
1. Packages of fresh fruits and vegetables less than 1.5 kg
2. Packaging of food and beverages filled and consumed in hotels and restaurants
3. Cosmetics, hygiene products and toiletries for small hotel packaging (liquid packaging less than 50 ml, non-liquid packaging less than 100 g)
4. Single-portion or single-serving packaging for condiments, preserves, sauces, coffee creamers, sugar and spices in the food and beverage industry.
Response from the waste management industry
The waste management industry has generally reacted positively to the European Commission's proposal. Higher recycling targets may bring new business opportunities to the industry, including the development of new recycling technologies and the expansion of recycling infrastructure.
In addition, the proposed regulations could encourage the use of more sustainable packaging materials, such as reusable and biodegradable materials. This may reduce the use of single-use plastics and other materials that are difficult to recycle.
However, some stakeholders expressed concerns about the cost and feasibility of achieving the proposed recycling targets, particularly in countries with low recycling rates. Other concerns were raised about potential trade-offs between recycling and other waste management options (e.g., energy from waste and landfills).
In general, the waste management industry recognizes the need for a more sustainable approach to managing packaging waste and supports the proposed regulations to facilitate this goal. However, there is still some debate and discussion about the details of the proposed regulations and how they will be implemented in practice.
