PPWR unpacked: EU Commission and NGOs debate revised waste management rules

The final legislative steps before the adoption of the revised EU Packaging and Packaging Waste Regulation (PPWR) are set to be concluded by the end of this year. We speak to the European Commission (EC) and EU campaigning organizations, Rethink Plastic, Environmental Paper Network (EPN) and Zero Waste Europe to understand the PPWR’s industry implications.

“The PPWR, as provisionally agreed between the European Parliament (EP) and the European Council in March 2024, sets EU rules on packaging and packaging waste, covering both packaging design and packaging waste management,” an EC spokesperson for the European Green Deal, tells Packaging Insights.

“Among other measures, it obliges member states to set up deposit refund schemes for plastic bottles and metal cans, sets up minimum requirements for such schemes and encourages member states to go beyond the minimum product scope.”

Lauriane Veillard, chemical recycling and plastic-to-fuels policy officer at Zero Waste Europe, says: “The PPWR goes in the right direction by requiring recycled content for plastic packaging, but it should not stop at plastic, but go further with other materials like paper, cardboard and metal.” 

However, she adds: “The positive direction is at the moment unclear, as most of the key instruments like sustainability criteria and the mirroring clause will be defined in secondary legislation.”

Meanwhile, Ioana Popescu, coordinator of the Rethink Plastic alliance, argues that the new regulation lacks ambition.

“Too many derogations and loopholes were introduced during the EP negotiations, particularly relating to unnecessary packaging and reuse, even though these are some of the most effective measures for member states to reach the packaging waste reduction targets,” she says.

Market fragmentation fears 

The EP voted in favor of the PPWR in November of last year. In March, the EP and the European Council reached a provisional agreement on the legislation.

The main elements of the provisional agreement maintain the sustainability requirements proposed by the EC last November.

PPWR sets more ambitious targets on packaging waste and design.The EC spokesperson points to the overview of the PPWR’s rules on packaging and packaging waste, including design and waste management. By the end of 2024, all EU countries are expected to ensure producer responsibility schemes are established for all packaging and that specific recycling targets are followed.

However, Rethink Plastic’s Popescu warns of the possibility of market fragmentation.

“The disparities in materials covered (certain plastic packaging items were covered while paper ones are exempted), as well as derogations based on recycling rates (while there is demonstrated evidence recycling rates are inflated in many countries), the enforcement of the measures as such will lead to further fragmentation of the single market,” she explains.

At this week’s confirmation hearing of the commissioner-designate for Environment, Water Resilience and a Competitive Circular Economy Jessika Roswall, she stated that “circularity is key to combining sustainability and competitiveness, and to reducing our environmental footprint.” 

Implications for PFAS 

According to the council, the proposals set out in the March agreement strengthen the safety requirements for substances in packaging by restricting food contact packaging containing PFASs above a set level. But NGO campaigners disagree.

Dorota Napierska, toxic-free circular economy policy officer at Zero Waste Europe, says: “We know that all kinds of packaging can potentially contain many harmful chemicals, which eventually can also reach out and be a source of direct exposure of consumers. The current provision in the PPWR, requiring that the presence of substances of concern in packaging should be minimized, is quite ‘toothless' in terms of implementation.”

She says that this will be the case “until manufacturers will be obliged to provide information on the actual presence of such substances in the first place by 2030.”

Environmental NGOs call for more stringent rules on “unnecessary packaging” and support reusables.“Last year, Zero Waste Europe issued a briefing explaining that even for food packaging — where safety is believed to be strictly regulated — shortcomings related to the current legislative framework do not allow for adequate control of harmful chemicals and ensure consumer safety.”

Napierska calls for the PPWR to include “strong mechanisms and effective measures for phasing out the most harmful substances as proposed in the Chemicals Strategy for Sustainability.” These include chemicals that cause cancers, gene mutations, affect the reproductive or the endocrine system or that are persistent and bioaccumulative.

Updated recycling targets 

The current recycling target for all packaging is 55%, and is set to become 65% by 2025 and 70% by 2030. 

According to EC data, the highest current recycling targets are on glass and paper and cardboard both at 60%. Glass targets will rise to 70% by 2025 and 75% by 2030. Those on paper and cardboard will reach 75% next year and 85% by the end of the decade. 

Ferrous metals and aluminum targets are currently at 50%, and will rise to 70% next year, excluding aluminum, which will remain at 50%. By 2030 targets will reach 60% for aluminum and 80% for all other ferrous metals. 

The current plastic recycling rate is 25%. It will be doubled by 2025 and is set to reach 55% by 2030. The wood recycling rate is now just 15% and it will reach 25% by 2035 and 30% by 2030. 

Responses to new targets 

On one hand, Commissioner-designate Rowall says that the implementation of targets has “served the EU well” and has “showed us the path where we’re going.”

Activists argue e-commerce and horeca dining in and takeout should receive more focus in the regulation.On the other hand, Popescu and EPN’s Mateus Carvalho say: “While we’re discussing which type of material or packaging should be the target of this regulation, we’re playing the throwaway packaging lobby’s game.”

“Different materials have different environmental footprints, but one of the most determining factors is how many times packaging is reused. This regulation is an opportunity to counter the development we witnessed in the past decades, where reusable or no packaging was replaced by the overconsumption of throwaway packaging nowadays.”

“E-commerce and horeca dining in and takeout should receive more focus in the regulation, as these are some of the segments of packaging that are growing the fastest and thus responsible for the yearly increases in packaging waste.”

Meanwhile, Rethink Plastic’s Popescu emphasizes the important role member states will play in implementing and going beyond the PPWR to ensure the union’s circular economy.

“Member states still have the opportunity to go beyond the limits of the PPWR if it helps them to reach the waste reduction targets for their countries. Producers and retailers can take the initiative of providing better packaging offers by eliminating unnecessary packaging and offering reuse and refill.”

“If structural reuse is implemented, particularly in horeca and takeaway sector, and reuse and refill is widely enabled by retailers and producers, the PPWR’s main objective of reducing packaging waste would be much better served.”