Recycle or reuse? The packaging dilemma at the European PPWR challenge 

ppwr EU regulation

It is spelled PPWR, it reads Packaging & Packaging Waste Regulation. And we can summarize it like this: “Recycling is good, but it is not enough to reach the green targets we set ourselves in the EU. Consequently, the strategy of organizations and companies needs to shift towards reusable, rather than recyclable, packaging.” 

A concept that appeals to the general public because it is easy to relate to the principles of environmental sustainability that drive the Green New Deal. But is this actually the case? 

Let us go in order and seek clarity, beyond easy slogans. 

Packaging waste: a real problem

As the PPWR states. “Packaging uses large quantities of virgin materials (40 % of the plastic and 50 % of the paper used in the European Union) and accounts for 36 % of municipal solid waste. These are impressive numbers. Without action, the EU would see a further 19 % increase in packaging waste by 2030, and for plastic packaging waste even a 46 % increase. It is therefore understandable that the document describes them as ‘a major obstacle to achieving a low-carbon circular economy’. It is even more understandable that it seeks to reverse the course. The text states that recycling is not considered sufficient because ‘recyclable packaging is often not valorised, partly due to inadequate or non-existent infrastructure’; not to mention that this increases ‘greenhouse gas emissions and pollution’. For these reasons, the EU wants to change its strategy: instead of focusing on how to treat waste, it wants to prevent it from being produced. The targets are ambitious: -29% of packaging waste production by 2030; from 2030 to 2040 a further reduction is envisaged, up to a total of -37% of packaging waste.

But… how to do it? And what does it imply for companies in the supply chain?

Let’s focus on the Regulation’s text. 

PPWR Packaging Regulation: what it is and what it provides for

First of all, it is a regulation and not a directive: the directive, let us remember, sets targets and a timeframe in which to achieve them; it will then be up to the individual EU countries to decide what measures to take to achieve them (as was the case with the directive on single-use plastics). The regulation, on the other hand, is a binding legal act, which must be applied in its entirety in all EU member states. It therefore leaves little room for manoeuvre on its enforceability. 

The European Commission presented it on 22 November 2022, immediately generating lively debate and even some controversy. The goal is ambitious: the 

drastic reduction of packaging waste. By 2040, each Member State will have to reduce it by 15 % compared to 2018. To achieve this, the regulation provides for several points, we summarize the main ones here: 

  • Ban on disposable packaging: goodbye disposable plates, glasses and cutlery in restaurants and bars, fruit and vegetable containers, refillable bottles in hotel courtesy kits, perfume samples, etc;
  • Principle we could call ‘Reyclable by Design‘: by 2030 all packaging must be designed to be recyclable, with minimum percentages already set between 65% and 70%. Their weight and volume will have to be reduced to a minimum. 
  • Extended Producer Responsibility (EPR): producers are held responsible for the entire life cycle of the products they place on the market, from their design to the end of their life cycle (including waste collection and recycling); this also implies an economic responsibility for the disposal of packaging;
  • Obligation for plastic packaging to contain a percentage of post-consumer recycled plastic (percentages vary according to polymers and their uses);
  • Labelling: must contain information on the materials of which the packaging is made, its reusability and the percentage of recycled content, with uniform EU-wide designations and codes. 
  • Reuse: the distribution chain, especially the retail chain, will have to be rethought to favor reusable packaging, perhaps owned by the buyer. We could pick up Chinese take-away dumplings in the tupperware we brought from home, or go to the supermarket to get cereals and pour them from a dispenser directly into our containers (as already happens in some grocery shops);
  • Refill: similar to the previous point. When you buy a product with its packaging, it makes sense for that packaging to be refillable, i.e.: that you can return to the shop with that packaging and have it refilled. Again, under the lens are takeaways, food delivery and also vending machines. But the mind also flies to cosmetics, perfumes and many other products. 
  • Deposit and Return Systems (DRS): creation of deposit and return systems, especially for plastic bottles and cans. In short, the old ‘returnable vacuum’ is back.

We could go on and on: the PPWR document runs to 104 pages, but we will stop here (you can find it at this link)

We only anticipate that the strict proposal provides for some exceptions, in particular with regard to pharmaceutical packaging, which, for example, is exempted from the recycled content requirement in primary packaging (24). There are also exceptions to protect micro-businesses. But these exceptions do not undermine the basic principles. Nor does the controversy that followed. 

New EU Packaging Regulation: the negotiating position after the controversy

In fact, the most virtuous countries on the recycling front (including Italy) have seen it as a failure to recognise their commitment on the environmental front and fear the impact the regulation could have on jobs in the supply chain.

Others, on the other hand, pointed to the lack of realism and the difficulty of implementation, especially with regard to the logistical dimension: it is quite different to organize the transport and distribution of cereal boxes or bulk cereals. 

In the end, Strasbourg opted for a negotiating position: on 22 November, important derogations were voted on that mitigate the most controversial parts. In particular: 

  • virtuous states that demonstrate that they have achieved a collection rate of 85% of a certain type of packaging will be exempted from the reuse targets;
  • reuse is made conditional on a ‘Life Cycle Assessment’ (LCA), a set of requirements that will determine whether reuse is indeed the most environmentally friendly solution for that type of packaging;
  • certain disposable packaging, such as sugar sachets and fruit trays, were exempted and further exemptions were introduced for certain products (such as milk and alcohol), for typical food products and small businesses. 

The ball is in the Environment Council’s court on December 18, to decide whether to ratify the text approved by EU Parliament. If not, it will have to return to the discussion to reach a new compromise. 

However, the direction has been set, and is very clear: the European market wants to become a global benchmark for combining ecology and consumer habits. And packaging plays a key role in this strategy.

Aluminium packaging: since always, sustainable ‘by Design’

In this context, aluminium packaging becomes a strategic ally for companies: it is 100% recyclable without losing its original qualities and the recycling process saves 95 per cent of energy compared to production from raw material. Moreover, it is immediately identifiable by end consumers, who can already recognise it as a ‘green’ product. Moreover, in Italy there is a solid organization for the recovery and recycling of post-production and post-consumer aluminium: in 2022 in Italy 73.6% of aluminium packaging placed on the market was recycled. A figure that far exceeds the European target of 60% by 2030.

Many large retail companies are rediscovering aluminium, particularly cosmetics companies, which are also exploiting its irresistible vintage effect. 

And the pharmaceutical supply chain? Although ‘graced’ by the PWRR, it has for years been debating the issue of the sustainability of its processes, which is becoming increasingly topical. The aluminium tube, a great ‘classic’ of pharmaceutical packaging, proves to be a valuable ally in this respect too. 

Combining consumer habits and sustainability is possible. But to really succeed, it is essential to act on a concrete basis. 

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