New Proposal: EU Packaging and Packaging Waste Regulation (PPWR)
The European Union has seen a 20% rise in packaging waste between 2012 and 2020.
Having seen a 20% rise in the EU's packaging waste between 2012 and 2020, and aligning with the European Green Deal and Circular Economy plan, the European Commission proposed a revision to its packaging waste directive. This directive serves as the primary regulatory framework, laying down the fundamental criteria for packaging design and composition, as well as establishing benchmarks for packaging collection and recycling within the EU. This proposal was revised in November 2022 with the following objectives:
Reduce the current production of packaging waste.
Promote cost-effective circular economy principles across the industry.
Increase the use of recycled materials in packaging.
To achieve this goal, the proposal has been elevated from a directive to a regulation, aiming to enhance uniformity across the EU. This strategic shift is intended to bolster coherence throughout the EU, making it mandatory for all Member States to adhere to the outlined guidelines. The proposal specifically tackles various areas, including:
Setting objectives for reducing excessive packaging.
Enhancing uniform standards across the EU and providing essential requirements for standardized labeling.
Establishing Extended Producer Responsibility (EPR) mechanisms.
Encouraging designs that facilitate reuse and recyclability.
Ensuring consumer protection and fostering awareness.
However, the proposal could adopt a more holistic approach to reaching its waste reduction and management-specific 2030 and 2040 targets.
The untapped potential of biodegradable and compostable materials
The proposal addresses many key issues and employs advanced scientific evidence and economic tools to achieve a circular economy of packaging, but it underestimates the value and potential of bio-based and compostable content as part of the solution. While acknowledging that under appropriate conditions, the production and utilization of bio-based, biodegradable, and compostable plastics lead to favorable environmental results and do not exacerbate issues related to plastic pollution and biodiversity decline, the support for proliferating their use is lacking. Recycling is favored to achieve waste reduction targets. Although recycling plays a vital role in waste management, it fails to address the immense volume and severe consequences of packaging and packaging waste. It is essential to recognize that even with high-quality recycling, there is no guarantee of a sustainable end-of-life solution once a product reaches the limits of its recyclability.
To achieve the goals outlined in the European Green Deal and the revised Circular Economy Action Plan, a comprehensive interdisciplinary and holistic strategy is required, emphasizing innovation in exploring and enabling circular alternatives. The proposal and the suggested draft amendments lack a crucial element: fully maximizing the utilisation of bio-based and biodegradable materials. In the proposal:
There is continued reference to an ambiguous definition of Natural Polymer.
The use of bio-based content is not adequately promoted, and the use of recycled and compostable materials is considered mutually exclusive, while they can be jointly offered in materials like PHA.
The proposal favors recycling plastics more than reducing them at the source, and the dependence on fossil carbon is not adequately addressed.
The proposal recognizes the value of using compostable and biodegradable materials in increasing the volume of organic waste and includes a list of mandatory application.
There is a lack of incentive to promote greater utilization of biobased products to contribute to the reduction of fossil carbon consumption.
Challenges and impact of underutilizing biobased and biodegradable content
Embracing alternative materials presents an opportunity to become a more resource-efficient and circular economy. Increased use of biobased content can support recycling enhancement methods and practices across the EU significantly. In line with that, the Commission should review and revise:
Concept of recycling: Even though recycling is emphasized in the PPWR, the Commission has only referenced mechanical recycling, including remelting and reusing plastics. Chemical and organic recycling needs to be addressed as recycling in the PPWR. The concept should be broadened to include bio-based/compostable materials to achieve circularity. Additionally, composting represents a form of carbon recycling - this must be acknowledged as “recycling” in the proposal. The Commission’s Revised Waste Framework Directive accepts industrial compostability as organic recycling, and we ask policymakers to create coherence and recognize this in the PPWR.
Mandatory list of compostable applications: The Commission’s decision to mandate certain applications to be compostable and biodegradable would undoubtedly encourage a circular packaging management system and benefit the environment, but expanding the list for other compostable plastic packaging, according to the conditions set out in Annex III for packaging that could eventually enter organic waste streams would lead to increased rates of collected organic waste. For example, all fruit/vegetable and grocery carry bags, especially those packaging that touches food and food waste, should also be mandated compostable
Recycling requirements: The existing criteria for recycled content are overly inflexible for a growing sector like biobased materials, which hinders the potential for development. Recycled content mandates should not apply to renewable carbon-based packaging materials, allowing them to foster innovation and growth
There is potential for achieving a higher impact on circularity by addressing missing elements integral to packaging and packaging waste collection, recycling, and reuse. Underutilizing sustainable alternatives would lead to:
Missed recycled content requirements: Biobased content can fit in the existing waste management hierarchy, including recycling and composting. Across the EU, 45% of municipal waste is biowaste and as per the 2022 ECN data report on EU bio-waste, only 17% of municipal solid waste is organically recycled through composting and anaerobic digestion. The report also indicates that there has been no corresponding increase in bio-waste recycling. Thus, allowing for additional bio-based and renewable content could contribute to reaching the EU Waste Framework Directive target of recycling 65% of municipal waste by 2035
Lack of incentive for innovation: Integrating biobased and biodegradable alternatives to plastics into the regulation will encourage research and development in the field of innovative materials. Without regulatory support, stakeholders may lack the incentive to invest in developing environmentally friendly materials.
Limited resource efficiency: Biobased content derived from renewable sources offers significant environmental benefits along with similar functionality to conventional plastics. For example, The City of Milan efficiently used biowaste and biobased materials to become a pioneer of successful food waste management in the EU. By implementing a separate food waste collection system using compostable bags in 2012, the city’s collection rates from 2011 to 2015 rose by 17% - from 35% to 52% and reached a staggering 62.6% in 2020. From its inception in 2012, the city stands as a prime global illustration of effective food waste collection practices.
Dependency on fossil fuels: Embracing alternatives to conventional plastics that are biodegradable, compostable, and circular can effectively reduce our dependence on fossil fuels as an energy source. In cities such as Milan, where efficient biowaste collection is achieved through the utilisation of compostable bags, waste is harnessed to generate biogas, resulting in an 8,800-ton reduction of CO2 emissions and decreased reliance on fossil fuels.
Key stakeholders
ENVI Committee: The European Parliament has granted the ENVI Committee lead status to review the proposal.
Internal Market and Consumer Protection (IMCO) Committee: Designated as an Associated Committee by the European Parliament in June 2023.
Industry, Research, and Energy (ITRE) Committee: Designated as an Associated Committee by The European Parliament in June 2023.
Environment Council: Will engage in technical and political discussions to shape its internal position.
What’s next?
20 September 2023: The ENVI Committee will tentatively vote on the draft Report and amendments, after which the approved text will proceed to the plenary for adoption
2 October 2023: Tentative vote in the plenary.
18 December 2023: Member States’ Ministers will provisionally hold a debate on the Commission’s proposal, organized by the Environment Council.
After the Council and European Parliament finalize their stances, informal negotiations (trilogues) are anticipated to commence to reach an agreement.