ZWE · Non-governmental organisations, platforms and networks and similar · BE
Šaltinis: Europos Komisijos skelbiami susitikimai, sutapatinti pagal skaidrumo registro numerį. n = 81 susitikimų; x — metai pagal susitikimo datą, y — susitikimų skaičius.
…5 recommendations to reinforce the Packaging and Packaging Waste Directive with prevention and reuse measures The overall production of packaging and generation of packaging waste has been steadily growing over the past 20 years, reaching an impressive 88.4 million tonnes of packaging put on the EU market in 2017 according to recent Eunomia figures. This growth in packaging items sold has been driven by the wide adoption of single use packaging in product supply chains and subsequent distribution to end-users and consumers. These amounts are projected to continue increasing with rising population levels and associated consumption patterns, as well as industry practices with regards to portion sizing and presentation.
…and associated consumption patterns, as well as industry practices with regards to portion sizing and presentation. Data presented in the first stakeholder meeting for the PPWD review demonstrated that the rise in single use packaging has been accompanied by a dramatic drop in refillable and reusable packaging. In the absence of dedicated EU action, production and consumption patterns will continue following a linear model and not help reverse this wasteful trend. While industry efforts have so far focused on the lightweighting and recyclability of packaging at best, this direction of travel fails to serve the objectives of the European Green Deal, including its carbon neutrality targets and new circular economy action plan.
…objectives of the European Green Deal, including its carbon neutrality targets and new circular economy action plan. The following paragraphs outline the Rethink Plastic alliance’s 5 main recommendations to reinforce EU packaging laws with measures helping to reduce the amounts of packaging and packaging waste produced annually in the EU:
…laws with measures helping to reduce the amounts of packaging and packaging waste produced annually in the EU: 1. Cap the overall number of packaging items put on the EU market A circular economy can only function if it remains within planetary boundaries and the ever-growing trend of producing and consuming more is tackled. EU efforts to limit packaging waste generation cannot have an impact if companies are not driven to explore different ways of bringing their products to the consumer through alternative business models, including packaging-free and reusable solutions. An overall limit on the amount of single-use packaging material put on the market, potentially with 5 year review clauses to set higher ambition, could give companies the necessary incentive to opt out of single-use packaging and provide consumers with better solutions to buy the products they need. Rethink Plastic…
Chaussée de Vleurgat 15, 1050, Ixelle, Belgium | www.rethinkplasticalliance.eu Ref. Ares(2020)7835596 - 21/12/2020 2. Introduce specific targets per packaging type Dedicated targets by packaging types can help implement the overall cap on packaging units sold into workable, sector specific targets. This type of policy intervention (in addition to other economic incentives, such as EPR) can help create a level playing field with disposable packaging, as today the latter does not internalise its associated costs. Based on an initial analysis, the below examples seem within reach in the short to medium term: Beverage packaging: Mandatory refill targets in the beverage sector are already in place in some countries. This is the case of breweries in Belgium, where beer bottles are customarily refilled and resold.
…in some countries. This is the case of breweries in Belgium, where beer bottles are customarily refilled and resold. This reuse and refilling system could easily be extended to a wider set of beverages, eventually covering all beverage packaging in the EU. Transport packaging: The environmental benefits of reusable transport packaging over one-time packaging are already known to be significant, and there are many companies implementing these systems, as listed in this report by the Reloop platform. It also 1 showcases significant economic savings to companies after making the switch to reusable transport packaging.
It also 1 showcases significant economic savings to companies after making the switch to reusable transport packaging. Tableware and food-containers: This initiative was already announced in the New Circular Economy Action Plan (p.15), where the Commission communicated its intention to determine the scope of a legislative initiative on reuse to substitute single-use packaging, tableware and cutlery by reusable products in food services. There are already many reusable solutions for the food sector, as described in the Rethink Plastic alliance’s Reusable Solutions Report. The potential role of Green Public Procurement to leverage a 2 move to reusables should be stressed here. E-commerce packaging: E-commerce is expected to become the largest retail channel in the world by 2021, which also means a massive generation of packaging waste unless dedicated measures are taken.
…in the world by 2021, which also means a massive generation of packaging waste unless dedicated measures are taken. Reusable packaging for e-commerce has proven to be a simple solution to this problem. A good example is Repack a closed-loop reusable system 3 that can reduce ecommerce packaging waste by 96% while providing the same consumer experience as the disposable one. For more information read the Zero Waste Europe Case Study. 4 1 Making the Switch: The Business Case for Reusable Packaging. Report by the Reloop Platform. Available at: https://www.reloopplatform.org/wp-content/uploads/2017/10/BusinessCaseReusablePackaging-MAY-181.pdf 2 Reusable Solutions: How Governments can help stop single-use plastic production. Report by the Rethink Plastic Alliance.
Solutions: How Governments can help stop single-use plastic production. Report by the Rethink Plastic Alliance. Available at: https://zerowasteeurope.eu/downloads/reusable-solutions-how-governments-can-help-stop-single-use-plastic-production/ 3 https://www.originalrepack.com/ 4 The Story of RePack, A simple solution to the growing problem of e-commerce waste. Case Study by Zero Waste Europe. Available at: https://zerowasteeurope.eu/downloads/the-story-of-repack-a-simple-solution-to-the-growing-problem-of-e-commerce-waste/ Rethink Plastic alliance | [email protected] | +32 (0)2 736 20 91 Zero Waste Europe, Chaussée de Vleurgat 15, 1050, Ixelle, Belgium | www.rethinkplasticalliance.eu Household products (e.g: detergent/shampoo/shower gel): These products can already be found in a dispenser format at packaging-free shops around Europe.
…gel): These products can already be found in a dispenser format at packaging-free shops around Europe. Dry food products (e.g: pasta, rice, grains, etc.): Likewise, dry foods are the biggest products sold in packaging-free shops. In many cases these products should be locally sourced to avoid environmental impacts coming from long distance transportation. Furthermore, the example of frozen pick and mix piloted by Waitrose demonstrates that bulk sales do no need to be limited to dried goods. 3. Introduce packaging format standards in association with targets The standardisation of certain packaging formats is often referred to as a main driver for the uptake of reusable solutions.
…of certain packaging formats is often referred to as a main driver for the uptake of reusable solutions. Common sizes and typing of various assets such as bottles, containers, crates, boxes, and many other types of packaging can drive the implementation of the necessary system infrastructure to wash, store, track, and redistribute such items, as well as stimulate the development of deposit return systems and packaging free business models. The 5 50 year anniversary of the German Perlenflasche in 2019 provides an iconic example of standardised reusable design for water and soft drinks, which is reused around 50 times. Its standardised reusable plastic crate is also reused up to 100 times.
…soft drinks, which is reused around 50 times. Its standardised reusable plastic crate is also reused up to 100 times. A high level of harmonisation in packaging formats, also called ‘universal’ packaging formats, can help a geographically wide acceptance of such packaging formats as they can be shared among different companies to help avoid transport impacts to return reusable assets to their rightful owner. However, in the absence of associated mandatory sector-specific targets to 6 reach refill and reuse levels, producers will not be incentivised to set up common reuse schemes. This will result in a high risk of competition between different reuse systems which will lead to negative environmental impacts and contribute to consumer confusion. 5 Standards in the time of the European Green Deal: how standards can support the environment.
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Rethink Plastic feedback Roadmap on Reducing Packaging Waste August 2020 Rethink Plastic Alliance welcomes the review of the requirements for packaging and measures to prevent packaging waste. Here we outline our main comments on the inception document. A. Context, Problem definition and Subsidiarity Check Growing levels of packaging waste are problematic both from a climate and a natural resource perspective. Europe already has a disproportionate consumption of natural resources, with a domestic material consumption (DMC) 40% higher than the global average. Furthermore, the climate impact from plastic packaging alone is equivalent to 75 coal fired power plants or 0.34 Gt CO2eq globally. In this way, a transformative agenda to rethink how we deliver products safely to consumers is needed.
CO2eq globally. In this way, a transformative agenda to rethink how we deliver products safely to consumers is needed. Incremental improvements in recycling rates, which remain the focus of policy makers and the packaging sector, will not deliver such a transformation. Waste prevention and reuse, with a strong commitment to the waste hierarchy, must become more prominent in the problem definition. We strongly regret that time was wasted and more emphasis was not put on waste prevention in the scoping study carried out in 2019, further that the proposed investments in the recovery plan focus on investments in recycling. B. Objectives and Policy options We support the three specific objectives outlined in the brief.
…in recycling. B. Objectives and Policy options We support the three specific objectives outlined in the brief. A number of more concrete actions related to packaging waste prevention should be prioritised: ● Pursue the objective of making all packaging reusable or recyclable by 2030, with priority given to prevention and reuse in line with the waste hierarchy. This means that where products can be handled in a sustainable way without packaging or with reusable packaging, it should be prioritised. A new report on packaging free shops has shown 1 that there are a good variety of products that can be safely sold without packaging. ● Set a clear timeline to phase out landfilling and incineration for packaging waste. 1 To access the full report, please contact: [email protected] Ref.
…and incineration for packaging waste. 1 To access the full report, please contact: [email protected] Ref. Ares(2020)4101682 - 04/08/2020 ● Set packaging waste reduction targets based on total number of single use units and kg of packaging per person per year. Specific targets should be set for major materials, 2 product groups and sectors (e.g. transport, food, beverages, e-commerce). Mandatory refill targets in the beverage sector are already in place in some countries (e.g. Germany). ● Implement standard reusable packaging formats for the EU market to create a scalable model for prevention for several major product groups (e.g. for beverages). In France new standard refillable formats supported by a pictogram are expected to be implemented by the end of 2020. ● Scale up deposit refund schemes (DRS) as an essential tool for implementing successful reuse systems.
…end of 2020. ● Scale up deposit refund schemes (DRS) as an essential tool for implementing successful reuse systems. DRS is an established tool to change behaviour, ensure take-back, and prevent environmental leakage. The system is already well-known in the refillable beverage sector, and a large number of reusable DRS are already in place for other types of packaging, including for cups , food containers and e-commerce. For 3 more information see our report on Reusable Solutions and DRS Manifesto. ● Improve data and monitoring of packaging (e.g. based on units as well as weight), establish MS and EU monitoring of packaging reuse, and integrate packaging data into the forthcoming initiative for a “product passport”. ● Identify options for financing waste prevention activities - which in general remain small scale, highly regionalised and bottom up - e.g.
…financing waste prevention activities - which in general remain small scale, highly regionalised and bottom up - e.g. earmarking revenues from EPR systems and cohesion funding. ● Make better use of market based instruments - the proposed own resource instrument on un-recycled plastic packaging would better target virgin plastic. ● Develop a decision-making tree to determine packaging options for the most common products on the market (based on packaging volumes and impact) which prioritises waste hierarchy. ● Provide unbiased science based guidance on critical issues such as food waste prevention, transport emissions and hygiene which are often discussed as limiting factors for waste prevention and reuse.
…transport emissions and hygiene which are often discussed as limiting factors for waste prevention and reuse. ● Explore restrictions for the use of some packaging materials/formats to certain applications, in particular overpackaging and where alternative reusable products or systems are possible or consumer goods can be handled safely without packaging - e.g. for dried goods, fruit and vegetables, e-commerce. ● Leverage both public and corporate procurement as instruments to scale-up reuse in key areas such as food services. 2 Care must be taken that targets drive waste prevention policies rather than simply another move towards light weight and difficult to reuse and recycle materials. 3 Examples: Recup, Billie cup, Cup Club and many more across Europe.
…difficult to reuse and recycle materials. 3 Examples: Recup, Billie cup, Cup Club and many more across Europe. ● Ensure packaging legislation supports the objective of a toxic-free environment with no tolerance to hazardous substances in packaging items, even with regards to recycled content or in compostable packaging. ● When introducing recycled content targets for specific packaging formats, give clear prioritisation to recycling processes yielding outputs that produce polymer materials directly while strictly excluding more carbon-intensive processes yielding simpler molecules (syngas and pyrolysis oil), even if they are used as feedstock for the manufacture of polymers. ● Establish a batch-level mass-balance approach for verification of recycled content, which should be conducted via third party audits and be based on post-consumer waste, only.
…of recycled content, which should be conducted via third party audits and be based on post-consumer waste, only. This is the only type of mass-balance methodology which can ensure the end-product actually contains at least a proportion of the desired product (ie. recycled content in this case), which allows for specific end-use claims to be made. Only content fulfilling such a standard should be counted as recycled according to the EU recycling calculation rules. More details on some of these measures can be found in Rethink Plastic paper 5 recommendations to reinforce the PPWD. C.
…details on some of these measures can be found in Rethink Plastic paper 5 recommendations to reinforce the PPWD. C. Preliminary Assessment of Expected Impacts Careful consideration for the externalities from packaging waste, including aquatic and pollution, biodiversity loss, and toxicity, should be integrated into any calculation of costs and environmental impacts - noting that Life Cycle Analysis including the Product Environmental Footprint are not yet well adapted to do this, and that the JRC’s LCA4plastics methodology still holds considerable shortcomings, especially when it comes to enabling comparison with reusables and despite multiple NGO comments highlighting these issues (here part 1 and here part 2).
…with reusables and despite multiple NGO comments highlighting these issues (here part 1 and here part 2). Assessments of food waste generation should adopt a food systems approach, and be careful not to equate shelf life extension to food waste prevention which are related but not equivalent - noting the general trend towards growing levels of food waste in Europe. Seek science based guidance on hygiene aspects around packaging. Avoid unnecessary waste intensive solutions - such as making sachets for condiments compulsory as was recently adopted in the UK. Furthermore, compostable packaging remains packaging and therefore unnecessary material that is designed to reach the end of life stage much sooner than is the case for reusable solutions.
…material that is designed to reach the end of life stage much sooner than is the case for reusable solutions. Overall the mutually reinforcing socio-economic, health and environmental potential for distributed short supply chains incorporating waste prevention must not be overlooked as a motor for economic recovery. The fragility of depending on single-use packaging and products became pronounced as Covid-19 developed. D. Evidence Base, Data collection and Better Regulation Instruments Resources should be mobilised to secure a broader consultation of stakeholders beyond industry representatives and target stakeholder groups beyond Brussels. Notably, consulting citizens on issues such as overpackaging is very relevant.
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Brussels – March 2023 Rethink Plastic alliance: feedback on the Packaging and Packaging Waste Regulation proposal Introduction The Rethink Plastic alliance welcomes the European Commission proposal for the Packaging and Packaging Waste Regulation (PPWR). Notably, we welcome the proposed waste prevention and reuse targets, as well as the strengthened measures for tackling packaging waste. Ambitious waste prevention targets and well-designed reuse systems can bring significant environmental benefits including reducing emissions as well as resource, energy and chemicals use. Although the proposal goes in the right direction by prioritising prevention and reuse, it falls short on the objective to achieve 100% reusable or recyclable packaging by 2030.
…prevention and reuse, it falls short on the objective to achieve 100% reusable or recyclable packaging by 2030. Also, the proposal offers too many loopholes and exemptions to effectively reverse the trend of growing levels of packaging waste, and it fails to incentivise the elimination of harmful chemicals in packaging. In the upcoming negotiations, it will be crucial to build on the proposal and swiftly adopt a robust framework for the packaging sector if the EU is serious about achieving its Circular Economy and Green Deal goals. We understand the complex context of the negotiations, with strong industry pressure calling for further weakening of the proposal, but it is pivotal to not lose sight of the need for strong binding legislation to drive the circular transition of the packaging sector for the benefit of people and the environment.
…legislation to drive the circular transition of the packaging sector for the benefit of people and the environment. The following outlines the Rethink Plastic alliance’s main recommendations to support the revision of the EU packaging legislation:
…outlines the Rethink Plastic alliance’s main recommendations to support the revision of the EU packaging legislation: 1. No time to waste To stop the continuous growth of packaging waste, the legislative process must be concluded in this parliamentary term. Unfortunately, the publication of the Commission proposal was delayed by over a year compared to what had been announced in the Circular Economy Action Plan1. The proposal also comes after an extensive period of impact assessments and stakeholders consultations (started in 2019), and it is therefore now key to complete this work. Any delays at 1 https://ec.europa.eu/environment/circular-economy/pdf/new_circular_economy_action_plan.pdf 1 Ref. Ares(2023)1684227 - 08/03/2023 this stage would make it difficult to finalise the discussions before the end of this legislature creating further legal uncertainty. The PPWR offers an important…
…on policy makers to prioritise consumer and environmental protection by ensuring a timely adoption of the legislation. 2. Prevention and reuse targets to tackle the waste crisis a. Legal basis: ensure Member States can take the necessary measures to pursue waste prevention We welcome the decision to ensure EU harmonisation on aspects such as the definition of recyclability or the standardisation of reusable packaging and systems. However, in the current proposal we see a contradiction between Article 4 on Free Movement which prevents Member States to develop measures to restrict packaging complying with the regulation, and Article 38.2-5 which mandates Member States to develop waste prevention provisions in order to meet their packaging waste reduction targets.
…mandates Member States to develop waste prevention provisions in order to meet their packaging waste reduction targets. This excessively restricts Member States’ possibilities to achieve waste prevention and to minimise the environmental impact of packaging, pursuant Article 38. “Corporate waste management plans” and “voluntary actions”, as referred to in the Impact Assessment, are unlikely to deliver tangible results2. In absence of stronger harmonised waste prevention measures within the regulation, it must be ensured that more ambitious measures can still be implemented in the Member States, especially those necessary to meet the waste prevention targets and to enable the uptake of reuse.
…the Member States, especially those necessary to meet the waste prevention targets and to enable the uptake of reuse. One solution, given the clear environmental objectives of the regulation, is that Article 191 TFEU (environmental basis) should also be included as a legal basis for this regulation next to Article 114 TFEU (single market), particularly with regard to the provisions of Chapter VII on management of packaging and packaging waste. Alternatively, opening clauses must also be clearly included, wherever necessary, to enable Member States to pursue waste prevention initiatives. b. Waste prevention targets should be more ambitious The targets set in the proposal are an important milestone from a regulatory perspective but are nowhere near ambitious enough.
…set in the proposal are an important milestone from a regulatory perspective but are nowhere near ambitious enough. Reversing at least the 20% increase in packaging volumes that happened over the last decade should be the initial prevention target. In line with climate and resource protection ambitions, packaging volumes must decrease drastically. With the Commission's current targets, limiting packaging waste generated per 2 Executive summary of the Impact assessment (30 Nov. 2022), pag. 27-28 2 capita to a similar level as in 2009 (149.9kg of packaging waste per capita) is not possible before 2040. It is necessary to take countermeasures earlier and to set the ambitious target of achieving a reduction equal to the increase of the last 10 years as early as 2030, meaning a 15% instead of 5% waste prevention target per capita by 2030.
…increase of the last 10 years as early as 2030, meaning a 15% instead of 5% waste prevention target per capita by 2030. In order to avoid driving simple substitutions between single-use applications made of different materials (from heavier to lighter packaging materials), material-specific sub-targets should be set, e.g. for packaging made of plastics, composite material, paper, glass and metal. c. Lack of a weight optimisation approach The overall objective of the legislation should be to reduce the environmental impact of packaging systems. This includes optimising packaging circularity with its weight. The current Essential Requirements for packaging have proven to be ineffective due to their unenforceability. The qualitative criteria, stipulated in Annex II of the Packaging and Packaging Waste Directive, require extensive research to prove cases of non-compliance.
Annex II of the Packaging and Packaging Waste Directive, require extensive research to prove cases of non-compliance. We know that national authorities do not have sufficient capacities to enforce these qualitative requirements, leading to a situation where non-compliance remains unsanctioned. Although the Commission has proposed to limit the qualitative criteria in the performance criteria listed in Annex IV, the enforceability issues remain unresolved in absence of supporting quantitative criteria. As already identified in the preparatory study, there are many packaging formats on the market which are unnecessarily heavy3 - driving resource use and secondary impacts (e.g. transport emissions). Clearer and enforceable rules are thus needed to effectively drive packaging optimisation.
(e.g. transport emissions). Clearer and enforceable rules are thus needed to effectively drive packaging optimisation. We therefore call on the co legislators to include quantitative criteria that ensure the enforceability of the packaging minimisation provisions. A possibility could be to define maximum weights relative to the content and tailored to the packaging material used for certain common types and formats: for example, a glass wine bottle really does not have to weigh more than 350 grams4. Alternatively, the Commission could request the European standardisation organisations to update the harmonised standard for establishing maximum weight limits for certain common packaging types and formats in order to prevent overweighting of packaging.
…maximum weight limits for certain common packaging types and formats in order to prevent overweighting of packaging. Although Article 9 is supposed to set standards for the prevention of unnecessary packaging, the current approach contains loopholes that will strongly undermine its effectiveness. For example, we do not support exemptions for the packaging of products subject to geographical indications of origin. Giving such products a free pass on optimising the sustainability of their packaging for marketing purposes (“including double walls, false bottoms and unnecessary layers”) is contradictory and reduces the impact that stricter packaging minimisation rules could have to reduce the packaging sector’s material footprint. 3. Reuse 4 Ibid.
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Feedback on the EU Packaging Regulation revision Recommendations for an ambitious revision of the Packaging and Packaging Waste Regulation (PPWR) Position Paper April 2023 zerowasteeurope.eu Ref. Ares(2023)2562673 - 11/04/2023 Contents 2 General Recommendations 2 Material neutrality approach needed 4 Sustainability without safety? 5 Topic Specific Recommendations 5 Legal Basis 6 Waste Prevention 6 Reuse 8 Standardisation 8 Deposit Return Schemes 9 Recycled Content 9 Recycling 10 Recyclability 11 Compostability 12 Sorting of mixed waste prior to incineration and disposal 12 Plastic bags Zero Waste Europe welcomes the overall ambition of the European Commission’s to encourage prevention and reuse of waste for the first time for a wide range of packaging types, in line with the waste hierarchy.
…and reuse of waste for the first time for a wide range of packaging types, in line with the waste hierarchy. Up to now, most EU policies have been focusing on managing waste (recycling) rather than avoiding its generation in the first place. That approach led to an ever growing level of packaging waste generation1. The European Commission's first Zero Pollution Monitoring and Outlook report2, together with the European Environment Agency's zero pollution monitoring assessment3, show that current pollution levels are still far too high: over 10% of premature deaths in the EU each year are still related to environmental pollution. This is mainly due to air pollution, but also to exposure to chemicals4, which is likely to be underestimated. The pollution similarly damages biodiversity. Moreover, the presence of hazardous chemicals in products continues to hamper the recycling of materials.
…biodiversity. Moreover, the presence of hazardous chemicals in products continues to hamper the recycling of materials. Therefore, the coming years up to 2030 will be critical in terms of establishing a harmonised regulatory and legislative foundation to reduce long-term chemical risks. For this reason, although the proposal is going in the right direction by prioritising prevention and reuse of packaging, it needs to be more ambitious if the European Commission is willing to achieve the EU Green Deal goals. These recommendations are complementary to the Rethink Plastic Alliance’s position on the PPWR, whose alliance ZWE is part of. 1)General recommendations a) Material neutrality approach needed There is a need to address the boundaries of resource use regarding all packaging materials.
…neutrality approach needed There is a need to address the boundaries of resource use regarding all packaging materials. Our consumption and production habits are clearly exceeding the boundaries of the planet when it comes to all types of resources. In fact, all packaging materials come with their respective impacts. Therefore, to avoid merely substitution of materials (e.g: from single-use plastics to single-use paper/aluminium/glass or from heavier to lighter packaging materials) the proposal needs to address all packaging and packaging waste and from a material neutral perspective. For instance, we recommend that material-specific waste prevention sub-targets are set, e.g. for packaging made of plastics, composite material, paper, glass and metal.
…waste prevention sub-targets are set, e.g. for packaging made of plastics, composite material, paper, glass and metal. We also recommend strengthening the measures, in particular, to the materials below: 4 https://www.eea.europa.eu/publications/zero-pollution/health/chemicals 3 https://www.eea.europa.eu/publications/zero-pollution/ 2 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2022%3A674%3AFIN&qid=1670510444610 1 https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Packaging_waste_statistics Feedback on the EU Packaging Regulation revision 2 (i) Single-use glass is not properly addressed despite its great environmental footprint Single-use glass has been given a noticeable privilege in the Commission's proposal: it is not only left out from mandatory deposit-return schemes (DRS), but the sector of spirit drinks were also discharged from the reuse and refill…
(DRS), but the sector of spirit drinks were also discharged from the reuse and refill targets for the beverage sector. Such privilege for glass packaging is unreasonable given that single-use glass has the highest overall environmental footprint compared to other single-use materials5. Also, its life-cycle and waste management is still far from being circular6. On the other hand, glass is a material with a very high potential for reusability (e.g.: reusable glass bottles easily reach 25-30 rotation cycles) and recyclability if it is inserted in a well-designed closed loop system. Therefore, as a basic premise, glass packaging must be part of a deposit-return system (DRS) to achieve the 90% separate collection target and ideally, it should be part of a reuse system given the materials performs at best being reused, and at its worst being single-use (environmentally speaking).
…system given the materials performs at best being reused, and at its worst being single-use (environmentally speaking). To help ensure material neutrality for packaging, we recommend setting a 90% EU-wide separate collection target for recycling for all beverage packaging by 2040, including plastic bottles, metal cans, glass bottles and other recyclable beverage containers. It is important, however, that this target is accompanied by strong design for recyclability requirements and proven ability to recycle at scale into high quality secondary raw materials (e.g: recycling infrastructure in place).
…proven ability to recycle at scale into high quality secondary raw materials (e.g: recycling infrastructure in place). We believe that setting a 90% separate collection target will not only ensure investments are made into implementing effective mechanisms to ensure 90% is collected (likely through DRS), but also to improve the design of packaging, ensuring the materials collected are re-circulating into closed loops. All beverage containers should be effectively and efficiently reused and/or recycled (at scale), and this target will ensure packaging is back into a closed-loop application7. (ii) Paper packaging - the false ‘renewable’ solution Over the last decade the paper consumption growth in Europe has been driven in its majority by packaging, with half of all paper being now used for packaging8.
…growth in Europe has been driven in its majority by packaging, with half of all paper being now used for packaging8. Paper and cardboard was the main packaging waste material from 2009 to 2020 (32.7 million tonnes in 2020)9. After the adoption of the Single-use Plastics Directive (2019)10 there was also a big shift towards paper packaging, and when the COVID pandemic hit in 2020, there was a boost on online sales and e-commerce packaging relying mostly on paper and cardboard. Riding on this wave, the paper/pulp packaging industry has invested in LCA studies to promote the sustainability of their products, also in view of the revision of the Packaging and Packaging Waste Regulation.
…the sustainability of their products, also in view of the revision of the Packaging and Packaging Waste Regulation. 10 https://eur-lex.europa.eu/eli/dir/2019/904/oj 9https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Packaging_waste_statistics#Generation_and_recycling_per_inhabitant 8 Coelho et al (2020), Sustainability of reusable packaging – current situation & trends– Resources, Conservation & Recycle, Vol 6, quoted in COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for Regulation of the European Parliament and the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020, and repealing Directive 94/62/EC 7 Further information: https://zerowasteeurope.eu/2022/10/blog-post-reuse-before-recycling/ 6 https://zerowasteeurope.eu/library/how-circular-is-glass/ 5…
…the bigger and real picture (from the paper extraction, the impact on land and communities, to its end of life). For instance, it is estimated that products of Nordic forest destruction end up on EU supermarket shelves (mainly for packaging), which is driving a significant biodiversity loss11. In fact, there is a big risk of environmental “burden shifting” as any single-use item comes with its environmental impacts. The only way to solve the environmental crisis altogether (climate, pollution, energy and resource depletion) is by addressing our current production and consumption habits at source and supporting waste prevention and reuse measures. For further information on paper packaging please check FERN’s position paper on the PPWR. (iii) ‘Innovative packaging’ being given extra time to pollute?
…please check FERN’s position paper on the PPWR. (iii) ‘Innovative packaging’ being given extra time to pollute? The concept of “innovative packaging” as currently defined in the Commission’s proposal is problematic as packaging producers would not be required to document on the packaging properties (including on its recyclability) before five years after the first placing on the market. Such a concept would lead to increasing loopholes when it comes to the recycling stage with packaging put on the market without having recycling technologies able to address this ‘innovative’ format, and when no information would have been shared beforehand. Therefore, innovative packaging that is unlikely to drive sufficient demand and consequently is unlikely to create enough volumes to justify building a dedicated collection and recycling infrastructure, should be discouraged.
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Pallet Wrappings and Straps: Exemption from the 100% Reuse Targets under PPWR Response from the Rethink Plastic Alliance to the public consultation on the Commission’s proposal for a Delegated Act to exempt pallet wrappings and straps from the 100% reuse targets in the Packaging and Packaging Waste Regulation (PPWR, or the Regulation) About Rethink Plastic The Rethink Plastic Alliance is a coalition of leading European NGOs advocating for ambitious EU policies to tackle the growing crisis of plastic pollution. It brings together the Center for International Environmental Law (CIEL), ClientEarth, the Environmental Investigation Agency (EIA), the European Environment Bureau (EEB), the European Environmental Citizen’s Organisation for Standardisation (ECOS), Greenpeace, Seas At Risk, Surfrider Foundation Europe, and Zero Waste Europe.
…for Standardisation (ECOS), Greenpeace, Seas At Risk, Surfrider Foundation Europe, and Zero Waste Europe. Together, these organisations represent thousands of active groups, supporters and citizens in every EU member State working towards a future free from plastic pollution. Summary The Rethink Plastic Alliance is opposed to the exemption for pallet wrappings and straps from the 100% reuse target in the PPWR. We point out that the proposed exemption does not fulfill the conditions laid down in the Regulation, nor does it satisfy the criteria of having taken into account the latest scientific and economic data and developments. We also consider it unreasonable and non-transparent that this proposal has been made without publishing all relevant supporting documents and call for their quick publication.
…this proposal has been made without publishing all relevant supporting documents and call for their quick publication. The Rethink Plastic Alliance contends that the exemption should not be adopted unless it aligns with the PPWR’s conditions, is supported by recent and verifiable data, and all preparatory documents are published in a timely manner. Furthermore, we urge the Commission to avoid proposing any further exemptions from the PPWR. In order for Member States to have a decent chance of reaching their legally-binding waste prevention targets, it is imperative that this crucial Regulation is implemented as ambitiously as possible.
…prevention targets, it is imperative that this crucial Regulation is implemented as ambitiously as possible. Note: The full title of the proposed Delegated Act - Draft proposal on supplementing Regulation (EU) 2025/40 of the European Parliament and of the Council by exempting certain economic operators that use pallet wrappings and straps from the 100% reuse requirements of these packaging formats - shall hereby be referred to as the “Draft Proposal”. 1 Ref. Ares(2026)187154 - 08/01/2026 The exemption does not fulfill the PPWR’s own conditions The conditions for adopting the exemption to the reuse targets in accordance with Article 29, para. (18) (a) of PPWR are not fulfilled by the Draft Proposal 1. Exemptions to the reuse targets under Article 29, para. (18) (a) must apply to a specific economic sector in order to be adopted.
…to the reuse targets under Article 29, para. (18) (a) must apply to a specific economic sector in order to be adopted. Instead, the Draft Proposal provides a general exemption to the reuse targets for a specific packaging format, and does not target a specific sector. As is evident from the content of the Draft Proposal, by exempting plastic wrappings and straps from the reuse targets established under Article 29 of PPWR, the European Commission intends to establish a general exemption for a specific packaging format, namely, all plastic wrappings and straps used as transport (tertiary) packaging by any economic operator across the EU. The legal basis for the exemption proposed in the Draft Proposal is Article 29, para. (18), letter (a) of the PPWR.
EU. The legal basis for the exemption proposed in the Draft Proposal is Article 29, para. (18), letter (a) of the PPWR. However, this provision does not permit the adoption of general exemptions from the reuse targets established in Article 29, as envisaged in the Draft Proposal. Article 29, para. (18) of the PPWR sets out the conditions under which the European Commission may adopt exemptions from the reuse targets established in Article 29.
…conditions under which the European Commission may adopt exemptions from the reuse targets established in Article 29. These exemptions are narrowly defined and limited to specific circumstances: a. Letter (a) covers situations relating to economic operators from a specific sector, facing particular economic constraints triggered by the compliance with the targets of Article 29 of PPWR; b. Letter (b) covers situations relating to specific packaging formats and hygiene and food safety standards; c. Letter (c) covers situations relating to specific packaging formats and connected environmental issues. Letter (a) above-mentioned, which is the legal basis of the Draft Proposal, clearly mentions that an exemption to the reuse targets can be adopted provided that the exemption applies to economic operators from a specific sector, which means a specific industry or economic activity.
…exemption applies to economic operators from a specific sector, which means a specific industry or economic activity. Accordingly, this is the main condition that needs to be fulfilled in order for this exemption to be adopted. Furthermore, the exemptions adopted under letter (a) do not operate in relation to a specific packaging format, unlike the other legal basis for exemptions provided under letters (b) and (c). In the case of the Draft Proposal, this condition is not fulfilled as the Draft regards a general exemption applicable to all economic operators in the EU that use a specific packaging format: plastic wrappings and straps. Although the title of the Draft refers to “exempting certain economic operators”, the Draft Proposal does not make any reference to a specific type of economic operator and/or the sectors to which they belong.
Proposal does not make any reference to a specific type of economic operator and/or the sectors to which they belong. 2 In conclusion, by failing to refer only to a certain economic operator from a specific sector, and instead providing a general exemption linked to a specific packaging format, the Draft exceeds the Commission’s powers under Article 29, para. (18) of the PPWR and is therefore inconsistent with its legal basis. 2. Exemptions to the reuse targets can be adopted provided that they take into account “the latest scientific and economic data and developments”. In accordance with Article 29, para. (18) of the PPWR, the exemptions to the reuse targets in Article 29 of PPWR can be adopted if such are based on the latest scientific and economic data and developments.
…in Article 29 of PPWR can be adopted if such are based on the latest scientific and economic data and developments. It shall be thus interpreted that such data must be recent and had not been analysed before the drafting and adoption of the PPWR. Analysing the wording of the Draft Proposal, the scientific and economic data on which it is based are: a. “Targeted stakeholder consultations with the packaging sector as part of a dedicated study”. The minutes and documentation of such consultations have not been published, and are only announced to be published in the future without any further details. Moreover, a presentation given during the Commission Expert Group on PPWR on 10 October 2025 did not specify how the consulted stakeholders were distributed across the supply chain, nor did it provide a list of these stakeholders.
…the consulted stakeholders were distributed across the supply chain, nor did it provide a list of these stakeholders. b. “According to Eurostat, 600,000 businesses in the EU could be affected by Article 29 (2) and (3)”: This statement is accompanied by a link to Eurostat1 that shows data connected to a general listing of NACE codes, namely: “industry, construction and market services – except public administration and defence, compulsory social security, activities of membership organisations)”, and which indicates more than 33 million enterprises in the EU and not 600,000. c. “Costs to these businesses have been estimated approximately at EUR 610,000,000; such costs relate to the adaptation of the packaging lines (i.e., often maintaining dual packaging lines), such as purchase of new automated machines for wrapping up the pallets, IT equipment, and staff training”.
…such as purchase of new automated machines for wrapping up the pallets, IT equipment, and staff training”. This estimation statement has no source or further justification. d. “Costs to competent authorities typically refer to performing audits to the businesses to check compliance with the reuse obligations outlined in Article 29 (2) and (3)”. None of the (a) – (d) statements above contain any solid evidence which could be reasonably considered as valid “latest scientific and economic developments” that justify the exemption envisaged by the Draft Proposal. 1 https://ec.europa.eu/eurostat/databrowser/view/sbs_ovw_act__custom_17432478/default/bar?lang=en 3 Moreover, nothing from the above is new in the sense that there is nothing that had not been considered beforehand by the European Commission and co-legislators when drafting and adopting the PPWR.
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