Companies with producer responsibility already preparing for the changes in the PPWR

What are the main changes that the introduction of the PPWR will bring to your operations?

Juhana Pilkama, Valio: The PPWR will support the work we have been doing for more than ten years to develop environmentally friendly packaging. Even though we are already on the right track, there are still changes to be made. Our goals already cover reducing packaging materials, using packaging that is suitable for recycling as well as using recycled and renewable materials in our packaging whenever possible. However, the Regulation’s requirements on the use of recycled plastic presents challenges related to food safety and the availability of materials.
The biggest challenge is that the full details of the PPWR are not yet available, only the delegated acts and other clarifying instructions will determine what the new requirements really mean. The transition periods are also too short from the food industry’s point of view. We have products that can have a shelf life of up to three years, so we should already be able to test the functionality of new packaging materials in production as well as the shelf life of the product until the best before date.
There are also ambiguities about the reuse obligations for beverage containers and transport packaging. For example, we need more detailed instructions on which drinks should be packed in reusable packaging.
The extensive documentation requirements included in the new Regulation represent a significant change and will introduce an unnecessary administrative burden and additional costs. Unfortunately, all this increased red tape will not contribute to Europe’s competitiveness.

Hannele Dahl-Nevalainen, Kesko: Data is becoming increasingly important. We will need more detailed packaging data to meet the requirements stipulated under the PPWR. For example, the reporting of packaging data will be more detailed, the definition of recyclability will change and the reuse of packaging will be included in reporting in a new way.
The definition of a manufacturer of packaging will change in August next year in the middle of the reporting year and in the middle of the month. The change will affect producer responsibility obligations, and any related changes will mean more work. The cost of managing packaging operations is increasing.
The requirements to reuse packaging will cause big changes in shops. After we receive more accurate interpretations of the rules, we will still have a lot of work to do on how to implement the changes in shops. For example, the future of the bottle return system is still unclear, as some bottles will have to be returned for reuse in their original form. All bottles are crushed under the current system. We are currently in discussion about the possibility of an exemption, which would allow us to maintain the current system. Additionally, the Regulation stipulates that ten per cent of the shop floor area in shops larger than 400 square metres should be reserved for refilling packages. These changes will cause a huge amount of work and problems in shops.

Mari Mattsson, HKFoods: The changes brought about by the PPWR are extensive and will result in a huge increase in documentation. Labelling requirements will become stricter when all types of packaging must include a clear indication of their recyclability and material composition. To comply with these will require changes in the selection of packaging materials and production processes. The obligation to use recyclable packaging and recycled raw materials will pose challenges, especially for the food industry, as packaging must continue to meet high hygiene and food safety standards. We cannot replace existing materials by simply choosing something else from the shelf, as materials used in food packaging must be approved by the European Food Safety Authority (ESFA). This will have a particular impact on the introduction of secondary raw materials, requiring more rounds of approval and, potentially, significant time and resources. The requirement that all packaging be recyclable from 2030 onwards will have a major impact on materials, machinery, equipment and, possibly, logistics packaging. If the definition of recyclable packaging is only made available in 2028, we will not have time to make all the necessary investments before the deadline.

How have you prepared/are you preparing for the changes?

Juhana Pilkama, Valio: We have surveyed the current situation and compiled a list of the changes required on the basis of available information. We have also started to carry out shelf-life tests on materials that we believe will meet the new requirements. We hope that we are right about the materials.

Hannele Dahl-Nevalainen, Kesko: We have set up a project team with members representing all Kesko’s business areas. We have engaged stakeholders from all across the company in the preparation and trained our staff and suppliers on the PPWR requirements. We have already collected more detailed packaging data from our suppliers and fed it into the new packaging data PIM system. We have also set up a reusable packaging project involving the entire packaging value chain ahead of time.

Mari Mattsson, HKFoods: We have known about the introduction of the PPWR for a long time, so we have already been testing recyclable packaging options for many years. We have familiarised ourselves with their technical readiness, development and machine runnability and have conducted risk assessments of all elements that affect the functionality of a material.
We are also involved in the activities of the Finnish and European standardisation organisations (SFS and CEN) and actively participate in the activities and working groups of various stakeholder and interest groups both in Finland and the EU. These collaborative activities allow us to comment on drafts, on which the final decisions are made, as early as possible.

What have you learned along the way (challenges/opportunities)?

Juhana Pilkama, HKFoods: The harmonisation of packaging legislation across Europe is, in principle, a good thing. After all, the goal is to prevent packaging waste by reducing unnecessary packaging and strengthen the circular economy, thus reducing consumption of natural resources. The challenge for us as a food industry operator is that the Regulation has been drafted too broadly. It should be much more specific.
A number of Omnibus projects aimed at simplifying regulations have also been introduced recently, which are welcome in themselves. However, their impact on long-term operations and future predictability is problematic. It is impossible to make the required investments if legal requirements are uncertain or constantly changing. These investments are substantial and require stability and clarity of future rules.

Hannele Dahl-Nevalainen, Kesko: The PPWR aims to curb the increase of packaging waste and preserve limited natural resources. This is a commendable aim. We are preparing for the Regulation in close cooperation with our staff and suppliers, as well as the entire packaging value chain. Collaboration is the only way to meet the requirements.
The challenge is the uncertainty over the interpretation of the Regulation. While the EU has promised interpretations, they have been a long time coming. There will be very little time for implementation. The retail industry has wide-ranging responsibilities, but we do not pack products ourselves, so there are many companies that we work with. The schedule is tight, and elements such as recycling labels must be available on all own-brand packaging within a few years.
The Regulation is complex and extensive, all in all, and the guidelines must be interpreted on an ongoing basis. There will also be more changes to implement as the requirements increase.

Mari Mattsson, HKFoods: The PPWR’s objectives, such as the promotion of the circular economy, reduction of packaging waste and development of more sustainable packaging solutions, are laudable, but the Regulation does not take sufficient account of the functionality of packaging. The recyclability criteria drafted by the Commission define the characteristics packaging must have to be recycled efficiently. Functionality must be included in the evaluation criteria: the focus should not be just on how packaging can be used after it has been recycled. The carbon footprint of our meat products comes mainly from the production of raw materials, especially in primary production, and the contribution of packaging to the carbon footprint is small, only about two to five per cent. The fate of advanced packaging materials used to pack food with a short shelf life, such as nylon, will remain uncertain until the Design for Recycling Guidelines included in the PPWR are published, estimated to take place in 2028. The transition period from publication to implementation will only be 24 months, which is too short a period for the food industry, in which hygiene and product safety are always the priority. Advanced packaging materials used in applications such as vacuum packaging and bags have helped the food industry reduce plastic content in packaging over the years. If these are no longer allowed in the future, the shelf life of products will be compromised.
In the best-case scenario, our current packaging will still be allowed after 2030 or will only require minor changes. At worst, though, good and necessary products may disappear from the market, as the Design for Recycling Guidelines may prohibit their packaging from being placed on the market. Uncertainty about the final content of the Regulation is worrying because it has far-reaching implications.
Of course, the PPWR also creates opportunities. It has the potential to promote a well-functioning circular economy, which we here at HKFoods and the food industry in general are also aiming to realise. It is also good that it allows us to accelerate the innovation of materials that are easier to recycle so that we are not caught up in old technologies.