The EU Packaging and Packaging Waste Regulation – will the objectives overshadow impact assessments?

In November, the European Commission published its proposal for the new Packaging and Packaging Waste Regulation. The Regulation aims to reduce the waste load from packaging: every EU citizen produces 180 kilograms of packaging waste every year. In terms of virgin raw materials, 40% of plastic and 50% of paper used in the EU are for packaging. Half of all marine litter is packaging waste. Although the amount of waste that is recycled has increased over the past ten years, the total amount of packaging waste produced has increased by more than 20%. It is clear that we must address packaging and packaging waste, and the transition to a circular economy offers solutions to this challenge.

The draft proposal sets precise targets for the recycling of packaging, packaging reuse, the amount of recycled material in plastic packaging and the ratio of empty space in packaging. While the objective of reducing waste is of course welcome, the means are a cause for concern.

What is commendable about the draft is the EU-wide harmonisation of legislation on packaging as well as packaging and recycling labelling. This will guarantee a level playing field for businesses. Reusing material flows will be made easier by harmonised packaging and recycling labels. The alternative to shared regulations would be a patchwork of national regulation and targets in different countries, which would clearly have a detrimental effect on the packaging sector.

However, there are also reasons to be concerned about the proposal. The need for a comprehensive impact assessment of the actions seems to have been overshadowed by the objectives.

However, there are also reasons to be concerned about the proposal. The need for a comprehensive impact assessment of the actions seems to have been overshadowed by the objectives. Strict requirements can, at worst, lead to a situation in which it is impossible to achieve any real environmental benefits.

One example is the case of reusable packaging – it is not entirely clear whether its environmental impact is lower than that of fibre packaging that is ecological and easy to recycle. Cleaning reusable packaging requires water, energy and chemicals, and transporting empty packaging produces emissions, which is particularly significant in countries that span large distances. It is also often made from fossil-based raw materials. France, for example, has already introduced reusable packaging, and there are signs that it may not remain in circulation for as long as specified in targets. There is also a question over whether it is possible to ensure safety and hygiene standards for reusable packaging and packaging made from recycled plastic.

The requirement that a certain proportion of material in packaging must be recycled plastic is also challenging, as similar requirements have been imposed on other sectors through various regulations. It is unclear whether the proposal takes into account the growing demand for recycled material and whether there is sufficient supply. It might be more appropriate for the requirement to be company specific, or at least product group specific, and fulfilled on an annual basis. This could be the most sensible approach economically as well as ecologically.

The proposal is currently being commented on by Member States and stakeholders. It is to be hoped that the final directive strikes a careful balance between environmental impact and objectives.

Leena Virkki
Advisor, Sustainable Development
Technology Industries of Finland