Ever since they were announced late last year, the EU’s proposed revisions to its Packaging and Packaging Waste Directive have caused intense debate within the industry.
Here we have assembled four viewpoints from leading industry insiders, with the aim of representing different perspectives on the issue.
The interesting bits for me relate to some of the challenges our clients are facing in terms of what we call the “regulation race” – i.e. the differences between what’s happening at the EU level and at the country level. So it’s safe to say that brands are finding it difficult to develop global – or even European – approaches to things when there are lots of different timelines in place.
It’s safe to say that there are some operational crossovers between how we look at the infrastructure and investments related to single-use, versus understanding whether or not floorspace needs to be used for a dishwasher or a reverse vending machine, for example.
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. Tracy Sutton, lead consultant and founder of Root (Speaking at a Sustainable Packaging Summit live event)
We believe the new PPWR should be material-neutral and aim at maximizing the circularity of the European packaging system. However, the current proposal positively discriminates against materials with the highest carbon footprint such as single-use glass and doesn’t provide the necessary bridge between the safety of materials 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. 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. Joan Marc Simón, Director of Zero Waste Europe
The Commission’s proposals provide a strong starting point for establishing EU-wide rules to ensure that all packaging put on the European market must be recyclable in practice and at scale and contain significant recycled content. The Ellen MacArthur Foundation welcomes the introduction, for the first time, of reuse obligations for some transport and beverage packaging.
We hope to see these extended to other sectors such as home and personal care products in the future. We call on EU Member States and the European Parliament to further strengthen the legislative framework promoting circular economy solutions for packaging.
This regulation has the potential to drive a step change in scaling reuse and improve the volume, quality and economics of plastic recycling. It also provides the opportunity to harmonise approaches to address other important issues across the EU. This includes restricting excessive packaging, advancing deposit return systems, as well as improving the performance of Extended Producer Responsibility schemes. Carsten Wachholz, Senior Policy Manager at the Ellen MacArthur Foundation
On recyclability specifically, a lot of work has been underway for a long time already. We’re looking for recognition of that work, and hope that it will be reflected in the Design for Recycling guidelines that will be developed by the European Commission.
Collection is also very important. 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. Francesca Siciliano Stevens, Secretary General at EUROPEN (Speaking at a Sustainable Packaging Summit live event)
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