This opinion piece is part one of Lykke Advice’s new series exploring topics considered keystones toward a greener path in the context of European legislation and policy.
Environmental policies have been focusing on packaging for many years for good reasons. Worldwide, more than 80 billion garments are created each year by the apparel industry, around 2 trillion drinks containers are made and sold each year, and many of these are shipped and packed numerous times. Packaging waste per EU resident was around 178.1 kilograms in 2019. Without a doubt, most packaging is disposed of as waste in landfills and incinerators. The need to address this emergency is reflected in the European Green Deal unveiled in 2019, introducing as a priority the revision of the rules set by the Packaging and Packaging Waste Directive (PPWD). The upcoming revision of the legislation will cover both packaging design establishing requirements for recycled content, and packaging waste management. This revision aims to contribute to the pledge made by Commission that “all packaging on the EU market is recyclable or reusable in an economically viable way by 2030”. The revision is expected to be published in the autumn, possibly October.
Objectives of the PPWD
The Directive’s dual goal is to constantly enhance packaging’s environmental performance and protection including efficient management of packaging waste, while also facilitating the well functioning of the EU Internal Market. The last amendment of the legislation was focused on the prevention of the production of packaging waste and promoting the reuse and recycling of packaging. The current EU rules also outline specific packaging recycling targets for the EU Member States. By 2025, 65% of all packaging must be recycled and 70% by 2030. The targets include plastic, wood, ferrous metals, aluminum, glass, and paper cardboard. Additionally, it includes the packaging Essential Requirements, which set forth design specifications for a variety of packaging materials and packaged items to reduce packaging waste. Packaging that complies with the EU producer responsibility schemes will always be allowed to circulate freely in the EU.
The revision of the PPWD: what’s new?
The review’s scope has been widened to include actions to decrease (over)packing and packaging waste in addition to efforts to enhance package design for reuse and high-quality recycling. The new revision is expected to contribute to reaching the objectives of the Green Deal, the Circular Economy Action Plan, and Strategy for Plastic ensuring that by 2030 “all packaging on the EU market is reusable or recyclable in an economically viable way” and “all plastics packaging placed on the market can be reused or recycled in a cost-effective manner”. Therefore, this revision is more important than ever. According to McKinsey, “improved packaging could deliver 5 million tonnes of GHG emissions savings” assuming material mix improvements. This revised legislation represents a key opportunity to further scale up the circularity of the EU economy and achieve the climate-neutral objective by 2050.
The reality of packaging products in numbers
The use of recycled materials is central in the upcoming revision. However, the Commission is still facing the critical issue of insufficient recycling facilities. On the one hand, for steel, paper-cardboard, and glass products, recycling rates already exceed the Commission objectives. On the other hand, for plastics, there are still some delays in recycling rates. In 2019 only 41% of plastic waste was recycled in the EU. For instance, between 2009 and 2019, the volume of plastic packaging garbage generated per resident grew by 24 percent (+6.7 kilogram). The positive side is that over the same time period, the volume of plastic packaging trash recycled increased by 50% (+4.7 kg).
Even if recycling has improved in recent years, the recycling facilities have limits and remain one of the main sustainability bottlenecks of the Commission. The revised PPWD objectives are ambitious, but can recycling rates increase any further to meet 100% of the demand for packaging? For most packaging, the answer is yes, except for plastics. Improving the separation and sorting of plastic waste highly depends on individual behavior.
Introducing key concepts such as reusability and renewability could go beyond the limits of recycling that currently exists and stop distracting society from the real problem of “take and throw-away” culture. Sustainability packaging assessments are still being conducted by the Commission, and reflections are being made about which sustainability factors need to be included such as durability, toxicity, recyclability, reusability, and renewability.
The industries are responding well to the upcoming revision but have expressed some concerns during the inception impact assessment on the review of the requirements for packaging and packaging waste. Most of them are asking for a clear definition of the key concept such as overpacking, recycled content, recycled packaging, and high-quality recycling and agree that the waste hierarchy should be effectively reflected in the essential requirements. Also, some disagreements have been expressed regarding the mandatory recycled content targets. Some advocate that it should only be imposed when the recycling value chain is dysfunctioning especially for plastic products, some advocate for harmonized targets for all packaging products. A lot of criticisms are also being made about the availability of recycled materials like PET and the lack of quality collection facilities. How to increase the collection system? Is deposit refund systems an effective way to achieve high separate collection? As the Commission has a lot of feedback and ideas to consider for its upcoming proposal, shareholders will be watching closely the legislation process, which could heavily affect how they operate.
To be achievable, the upcoming revision of the Packaging and Packaging Waste Directive needs to be based on scientific evidence, to ensure that each packaging produced is best suited for the environment and the consumer, preventing resource depletion, product, food, and packaging waste. To be realistic, the revision needs to support the industries in their sustainable and circular packaging transition including the increase in reuse, renewable, and recycling activities, while contributing to the development of new sorting, collection, and recycling technologies.
Lykke Advice is a boutique consultancy with experience guiding companies and associations through the latest developments in European Institutions and ensuring your voice is heard in the legislative process. If you wish to learn more about European sustainability policy, the EU Circular Economy Action Plan, or other topics, then do not hesitate to get in touch.