June 5. 2023. 5:20

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Packaging sustainability needs infrastructure and a strong Single Market

The revision of Europe’s packaging legislation can be a game-changer to advance packaging sustainability across the EU.

The revision of Europe’s packaging legislation can be a game-changer to advance packaging sustainability across the EU.

The packaging industry fully supports the ambitious goals of the EU Green Deal and Circular Economy Action Plan. Massive investments are being made in material innovation, recyclability and reusability of packaging. The direction of travel is clear and our industry is fully on board with this transition.

Ambitious goals alone will not suffice though. They must be matched with a regulatory framework that sets the ground for the systemic change needed to enable the uptake and scaling-up of sustainable packaging.

In its proposal for a Packaging and Packaging Waste Regulation (PPWR), the European Commission has rightly identified that, for a circular economy in packaging to become a reality, we need stronger harmonisation of the regulatory environment. Over the last few years, we have witnessed the increased fragmentation of the Single Market for packaging and packaged goods. Diverging national measures translate into market barriers, which in turn undermine economies of scale and stifle investment in innovation.

The Single Market is our biggest asset in achieving the climate and environmental transition and it is important that we build one circular economy comprising all Member States, not twenty-seven mini-circular economies. We stand fully behind the Commission’s proposal to strengthen harmonisation by transforming the existing Directive into a Regulation and preserving the existing internal market legal basis in its entirety.

Stronger harmonisation is key also when it comes to stepping up Member States’ ability to meet their waste management obligations. Many governments are joining forces in favour of an environmental legal basis on the grounds that they want to go beyond EU targets. Yet two-thirds of Member States are expected to fall short of their recycling targets in 2025. This is alarming. We are fully committed to delivering the continuous improvements in packaging design needed to ensure recyclability by 2030, as proposed by the Commission, but industry efforts alone will not be enough if we also want to meet the twin goal of recyclability at scale by 2035.

Waste management systems and infrastructure must be scaled up significantly to deliver effective packaging waste collection, sorting and recycling in all Member States. This is a job for public authorities, not industry alone. As a priority, mandatory collection obligations must be strengthened, so that packaging waste is recycled in practice and at scale. The upcoming revision of the Waste Framework Directive will no longer address this critical issue, so it is essential that provisions are put in place in the PPWR to ensure that packaging waste does not end up in incineration plants but is separately collected and directed towards clearly defined waste streams for recycling.

Alongside recyclability, continuous efforts are underway in the packaging industry to reduce packaging and increase reuse, without forgetting that the ultimate goal is to have packaging that is fit for purpose. Waste prevention and reuse goals can support these efforts, but packaging must protect consumer health and safety as well as the products themselves. Recognising the purpose of packaging is key to understanding which solutions make more sense for each use and context. The proposed restrictions on the use of certain packaging formats overlook the essential role that packaging plays in resilient food systems and in preventing food waste and cross-contamination.

Similarly, the proposed reuse targets should have been thoroughly assessed under real-life conditions and based on scientific evidence with respect to their climate and environmental footprint as well as hygiene, health and food safety requirements. The huge investments needed to develop the required reuse infrastructure, from sanitisation to distribution and take-back systems, should also have been thoroughly assessed to determine the size of the required investments. As pointed out by several Environment Ministers during their recent exchange of views on the PPWR, the impact assessment accompanying the Commission’s proposal lacks sufficient data and analysis for a thorough assessment of the proposed targets.

Together with the framework conditions – from Single Market to adequate waste management systems and infrastructure – for the PPWR to succeed we, therefore, need to remember that packaging cannot be considered in isolation from the packaged product. Coherence with other EU policy goals, such as the EU Green Deal or the Farm to Fork Strategy, is essential to ensure that policy and regulatory decisions are all moving in the same direction with the ultimate goals of reducing climate emissions and preventing waste.

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