Leaked document on new Packaging and Packaging Waste Regulation (PPWR) shows questionable and counterproductive measures


19 November 2022


Packaging Organisations question the true sustainability of EU’s legislative revisions and point to their potential to risks of harming packaging producers, suppliers and users in industry, logistics and retail.

As a reaction to the content of the leaked document EUROPEN - and the dvi being member of EUROPEN - released together with several other Packaging Organisations a joint statement questioning the true sustainability of EU’s legislative revisions and pointing out a number of counterproductive measures planned. We express our concern that they are not based on sufficient evidence and may lead to greater environmental impacts.

We call on the European Commission to address these critical issues and remain at your disposal for further dialogue so that the proposed Regulation is future-proof and delivers a regulatory environment that supports the European industry on its journey towards a fully circular economy.

Background

On November 30th the European Commission will pass the second bundle of the Circular Economy Package. The content has it all - from "Green Claims" to bio plastics and microplastic to the sustainable consumption of goods (right to repair) and more. Also part of the Circular Economy Package II: The new Packaging and Packaging Waste Directive (PPWR) that will become a Packaging and Packaging Waste Regulation (PPWR). The details of the new PPWR became known through a leaked document that we were able to read being a member of EUROPEN (The European Organization for Packaging and the Environment).

Some of our concerns mentioned in the joint statement are:

  • The current approach will lead to a regulatory environment that will be unworkable at best and crippling for whole sectors of the European industry at worst.

  • Despite our efforts, most of our key recommendations for ensuring food and products are adequately protected have not been taken on board. We therefore question whether the proposal is consistent with the ‘Better Regulation’ imperatives.

  • By dismissing the key role of recycling to achieve packaging circularity, it would paradoxically serve to make it harder to convert waste into viable, secondary raw materials that can be used in the market, setting back the cause of recycling while jeopardising millions of jobs and billions of euros of investments.

  • The proposal risks harming packaging producers, of all materials, as well as their suppliers and their users, in industry, logistics and retail. We call for defining a framework for the rapid adoption of clear Design for Recycling guidelines, to be updated regularly with the involvement of the value chain experts for the different packaging materials.

  • The proposed mandatory recycled content targets for plastic packaging fail to take account of bottlenecks that affect the availability, quality and cost of recycled plastics.

  • The proposed arbitrary product to pack ratio for specific products does not take into account the packaging’s safety and functionality.

  • Arbitrary bans and unrealistic and discriminatory targets that are not supported by scientific and empirical evidence do not create the positive investment climate needed to support the transition and lets industry question if continuing to invest in this legislative setting is at all sustainable.

Source: Deutsches Verpackungs Institut