European associations say EU packaging legislation could “cripple” industry and jeopardize millions of jobs

15 Nov 2022 --- A group of over 50 European packaging associations across the value chain has released a statement expressing “serious concern” over the European Commission’s revision plans for the Packaging and Packaging Waste Directive (PPWD), which is expected at the end of this month. 

The groups accuse the EC of dismissing the role of recycling in achieving a circular economy and assert the plans – revealed in draft working documents recently – are “unworkable at best and crippling for whole sectors of the European industry at worst.” 

The draft documents show the EC intends to prioritize reuse and refill schemes for plastic packaging, with mandatory reuse targets for beverage bottlers of 20% by 2030 and 75% by 2040. Recently, UNESDA Soft Drinks Europe told PackagingInsights that these requirements could cost industry up to €19 billion (US$19 billion) through wasted recycling infrastructure.

The joint statement, released last week, asserts that if the EC does not alter its plans, the PPWD could “jeopardize millions of jobs and billions of euros of investments precisely at a time when Europe needs resilient and sustainable growth.” 

“For many companies, whether packaging manufacturers or users, especially SMEs, the impact of this proposal is not only unsustainable but also existential,” it reads. 

Mandatory reuse targets could destroy costly recycling infrastructure throughout Europe.Is reuse more sustainable? 
The associations further assert that the proposed refill and reuse targets are not realistic, are disproportionate and could be counterproductive. 

“Reuse and refill are not always the best option from a climate and environmental standpoint, as many third-party certified LCAs studies have demonstrated, for example, because of the additional logistical complexity, in case of long transport distances or wherever recycling and mandatory collection can be efficiently organized,” the statement says. 

In June, a meta-analysis commissioned by the European Paper Packaging Alliance found that single-use paper-based packaging is more environmentally sustainable than reusable formats. However, experts question the reliability of such independent analyses and claim that results always favor the companies or people that commission them.

Nevertheless, packaging associations say that specific instruments, not foreseen in the proposal, are needed to create a framework for the scaling up of refill and reuse beyond niche projects. “To our knowledge, there has been no environmental impact assessment indicating how these targets would help deliver a better environmental outcome,” they say. 

Fragmenting the Single Market?
The association’s statement also says that by focusing on reuse and refill designs, the EC will compromise harmonized legislation in the EU and thus threaten the Single Market. 

“To achieve the 2030 recyclability goal requires concrete and collective efforts which go well beyond the packaging design. They require significant investment in sorting and recycling infrastructure to ensure that packaging is collected in the first place. In the absence of this, we will end up with a disparate Member State performance and a more fragmented Single Market.” 

“Instead of fixed targets, the proposal should set a clear framework to enable mandatory collection and recycling while scaling-up refill and reuse where it makes environmental and ecological sense and can further strengthen the competitiveness of the Single Market,” it continues. 

A focus on improving chemical recycling technologies is also emphasized and should be included in the EC’s targets, say the associations. 

“We want Europe to have circularity rules that set the standard for the rest of the world. Yet, the PPWR as currently drafted will set this process in reverse and may even turn the clock back on aspects of the Green Deal,” they conclude.

By Louis Gore-Langton

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