On November 30, 2022, The European Commission (EC) published a proposal for the revision of the EU legislation on packaging and packaging waste. The overarching objectives of the proposal are to reduce the negative environmental impacts of packaging and packaging waste, while improving the functioning of the internal market. Specifically, the Commission would like to (i) reduce the generation of packaging waste, (ii) promote a circular economy for packaging in a cost-effective manner, and (iii) promote the use of recycled content in packaging. They provide three options for working towards these goals, favoring an option which sets out mandatory targets for waste reduction, re-use for certain sectors, and minimum recycled content in plastic packaging for the 27 EU Member States to enable. 

Member States will be required to reduce packaging waste (per capita) by 5% by 2030, increasing to 10% by 2035, and 15% by 2040 compared with 2018. And by 2029 countries must create deposit return schemes for metal and single-use plastic beverage containers. By the end of 2025, 65% (by weight) of all packaging waste should be recycled including 50% of plastic, 50% of aluminum, 70% of glass, and 75% of paper and board. 

The proposal also outlines minimum food packaging reuse and refill targets to achieve by 2030: 

  • 10% of non-alcoholic beverages, 25% by 2040  
  • 20% of hot and cold take-away beverage containers, 80% by 2040 
  • 10% from consumer-facing businesses such as restaurants and cafes, 25% by 2040  
  • 5% of wine bottles, excepting sparkling wine, 15% by 2040  

The proposal is based on an impact assessment of the current packaging and packaging waste directive that detected three main issues to address: growing packaging waste generation, barriers to packaging recycling and re-use, and low recycling quality in plastic packaging and use of secondary raw materials. Concerning recycling, the EC writes “shortcomings in the current regulatory framework hamper the profitability of recycling activities and weigh on the investment in technology and supply logistics needed to ensure that packaging is collected, sorted and recycled at a high-quality level.”  

The impact assessment compiled all possible measures for analysis, based on three studies by external consultants, stakeholder workshops, an online public consultation, and targeted interviews. Over 800 organizations contributed to the consultation. Many stakeholders called for a new regulatory framework for packaging, as well as further harmonization of existing rules and a common approach to define packaging recyclability. Industry representatives emphasized the need for a stable and harmonized legal framework, while civil society representatives called for the effective implementation of the waste hierarchy in the packaging value chain “with measures incentivizing packaging waste prevention and re-use.” 

Ensuring that re-use systems for packaging are in place will fall under the purview of the packaging value chain rather than regulators. The proposed targets for waste reduction and reuse in the EU have been criticized by many in the packaging industry. According to reporting from Euractiv, manufacturers have expressed concerns that the targets are “not realistic” and could even “be counterproductive” by undermining existing recycling schemes. UNESDA, which represents the soft drinks industry, has said that the draft reuse targets pose an “existential threat to beverage industries and effective existing recycling systems.” Manufacturers of paper-based packaging and cardboard have also called for an exemption from reuse targets.  

While there are concerns from industry members about the reuse targets, the paper and glass packaging industries in Europe have already achieved or are close to the proposed recycling targets (FPF reported). Civil society organizations and industry groups have published reports and case studies on reuse, highlighting how businesses can work towards broader adoption of reuse systems (FPF reported also here and here). At the Food Packaging Forum’s 2022 workshop, Tobias Bielenstein of the Cooperative of the German Mineral Water Companies (Genossenschaft Deutscher Brunnen) shared how drinks producers in Germany jointly manage a reuse system that has a nearly universal acceptance rate among the German public – 99.4% of reusable bottles are returned in Germany (FPF reported).     

 

As part of an experiment with newly available tools, this article was written with assistance from GPT-3, OpenAI’s large-scale language-generation model. Upon generating draft language, the author reviewed, edited, added to, and revised the language to suit the style and form of the Food Packaging Forum. 

References 

European Commission (November 30, 2022). “Proposal for a revision of EU legislation on Packaging and Packaging Waste.” 

European Commission (November 30, 2022). “Factsheet – Circular Economy: Packaging and Packaging Waste Regulation.” 

Mark Victory (November 30, 2022). “EU Commission Packaging and Packaging Waste Directive revision will have major consequences for packaging chain.” ICIS 

Kira Taylor (November 17, 2022). “EU’s draft reuse targets for packaging meets barrage of criticism from industry.” Euractiv 

Read more 

Philip Chadwick (December 5, 2022). “European metal and glass bodies voice concern on EU regulations.” Packaging News 

Peter Dennis (December 2, 2022). “European Commission toughens packaging waste rules.” Circular 

Fermin Koop (December 2, 2022). “The EU is cracking down on plastic waste, starting with packaging.” ZME Science 

Philip Chadwick (December 2, 2022). “European Commission outlines plans to revise EU packaging regulations.” Packaging News 

Rachel Arthur (December 1, 2022). “The EU’s packaging regulation plans – and what the beverage industry thinks of them .” Beverage Daily 

Leonie Cater (November 30, 2022). “EU sets out plan to cut back packaging waste.” Politico 

Philip Blenkinsop (November 28, 2022). “EU to propose boosting recycled content and reuse of packaging.” Reuters 

Natasha Foote (November 18, 2022). “MEP: ‘Ideologically driven’ EU packaging law endangers food value chain.” Euractiv 

Leonie Cater (November 10, 2022). “Industry issues warnings over EU reusable packaging push.” Politico 

Peter Harding (November 10, 2022). “Unpacking the new future for sustainable packaging?Euractiv 

Packaging Europe (October 27, 2022). “Beverage associations fear that ‘discriminatory’ EU reuse targets for beverage containers will cause economic and environmental setbacks.”  

Delphine Lévi Alvarès (September 19, 2022). “Europe must set the bar high on packaging reuse systems to curb waste.” Euractiv 

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