Packaging and Packaging Waste Regulations (PPWR)

The European Packaging and Packaging Waste Directive (94/62/EC) was amended in 2018 to become the Packaging and Packaging Waste Regulation (2018/852). The aim  was to harmonise national measures regarding the management of packaging and packaging waste, to protect the environment, and also to ensure the internal market functions well. By updating the existing ‘directive’ to a ‘regulation’, the legislation gives less leeway for member states to interpret the measures and should result in a more harmonised approach to managing packaging waste across Europe.

This is in line with the aims of the European Green Deal, which aims to set the EU on the path to a green transition, with the ultimate goal of reaching climate neutrality by 2050.

The regulation contains a raft of measures and targets for packaging and packaging waste that become more stringent over time, giving the industry time to invest in new infrastructure and develop new products and techniques. It is envisaged that this will have a wide-ranging effect on the industry and be transformational.

For British companies this is important because under the terms of the Windsor Framework, PPWR will be brought into Northern Irish law eventually, so any goods sold there will need to comply.  In addition to this, the EU remains the UK’s major trade partner and therefore all UK packaging used to protect UK goods which are exported to the EU will have to conform to these new requirements.
 

What are the main provisions within the PPWR?

As well as providing for Extended Producer Responsibility (EPR) and Deposit Return Schemes (DRS) to be implemented in member states, it also sets targets and limits in a number of areas including:

• Packaging waste reduction targets at member state level.
• Mandatory reuse targets for selected packaging groups.
• Restricting over-packaging and certain forms of unnecessary packaging and supporting reuse and refill systems.
• Establishing criteria for design for recycling to be applied to all packaging.
• Setting minimum inclusion rates for recycled content in plastic packaging.
• Harmonised labelling of packaging and waste bins to facilitate correct consumer disposal of packaging waste.

These targets will initially be set for 2030 but will increase up to 2050.
 

What does this mean for the plastics industry?

To meet the targets required, the packaging industry will need to develop new products, techniques, and systems to cope with the inclusion of recycled content, design for recyclability guidelines, and reuse targets. This is especially true for products that currently do not meet the requirement because of technical restrictions, legal regulations or manufacturing issues.

Availability of recycled materials also may cause issues as the infrastructure is not yet in place to handle the volumes of recycled plastic needed to meet the targets. Changes in regulations by the European Food Safety Authority, making provision for novel technologies, may go some way in relieving the pressure on the use of mechanically recycled materials for direct food contact use.

Reuse systems require the cooperation of many different companies and the users themselves to be effective.  At present there are several examples of reuse of packaging with limited scope but few that are operated on a national scale. A change of approach is needed to achieve significant advances in this area. There are some products (including stretch wrap and coffee pods) where it is difficult to envisage reuse with currently available technologies and others (such as EPS fish boxes) where there are hygiene and food safety implications.

Reduction targets may lead to transferring packaging materials to alternatives that may not have as good environmental credentials as plastic, and ultimately lead to more harm to the environment. Reduction targets can be helped by lightweighting but ultimately can lead to a reduction in shelf life and product spoilage. When we consider that the product inside a pack is normally many times more polluting than the plastic itself, this can be a retrograde step and have unintended consequences.

Not all plastic packaging can be designed for recyclability, especially those where high barriers are required (i.e. food and industrial chemicals). Punishing packaging formats where there are no viable alternatives, or alternatives where the environmental outcome is worse, will lead to increased pollution.
 

In conclusion...

The BPF agrees with the general aims of the legislation but some of the targets and provisions will have unintended consequences that can lead to environmental outcomes that do not meet its intentions.

Targets on reuse are very challenging for the industry to achieve, especially as it requires consortia of many different companies and users to make it work at scale. Also, any reuse system needs to demonstrate the environmental benefits of its operation over the single use system it will replace.

Incorporating recycled content is vital to achieve a circular economy for plastics. Increasing its inclusion in packaging requires a good flow of high-quality recycled materials to enable converters to create packaging that is suitable for its intended purpose. This will require significant investment in new recycling infrastructure, chemical recycling (and mass balance accounting) for difficult-to-recycle products, and the early approval of novel technologies by EFSA.

Packaging reduction targets could very easily lead to unintended consequences, either by increasing product waste or encouraging a shift to other materials that have an increased environmental impact. Reduction is also counter intuitive when applied to single materials, as markets are growing, and food safety, for example, is a major priority.

For the regulations to work optimally, it requires the cooperation of the consumer. Efforts to communicate and educate are paramount in engaging with consumers and should be a priority.

Design for recyclability guidelines must be based on science, and not disadvantage packaging formats where there are no viable alternatives, or the alternatives will increase environmental damage. PPWR also needs to work in harmony with EPR and DRS systems in all nations, ensuring they lead to protection of the environment and the internal market.

The overly plastic-focused approach of the legislation (i.e., recycled content targets only apply to plastic packaging, not other materials) needs to be tempered and results should be judged upon the best environmental outcomes, rather than perceived public opinion, to ensure the best outcome for the planet and future generations..

 

Published 3 April 2024

Updated 29 April 2024