Packaging and Packaging Waste Regulation : "The PPWR has the potential to revolutionise the way packaging is produced and managed"

According to you, what are the key elements the PPWR has to fulfill?

The main topics of the regulation are the recyclability of packaging, weight and volume reduction, reusable quotas, a mandatory recyclate content for plastics and a new type of participation in collection and recovery systems, known as ecomodulation, which is intended to put recyclable packaging in a better position than non-recyclable packaging. If the new regulation comes into force, many types of packaging as we know them today will no longer be permitted. It is therefore important that companies adapt to these changes at an early stage and push for more sustainable packaging solutions.

The EU wants to implement the PPWR before the election in June. But there is harsh criticism from various stakeholders. Plastic packaging producers criticize the exemption of paper and cardboard packaging, EuRIC the export regulations for recycled content and so on. How do you see those criticisms and how do you rate the regulatory proposals to date?

New regulations always arouse different opinions and interests. Ultimately, a compromise must be found. For this reason, work has been carried out over the past few months in the course of the revisions to adjust the legal text in such a way that the content works for everyone. According to current reports, the most recent changes made as part of the revisions are aimed in particular at reaching a compromise on the regulations regarding the recyclates that can be counted towards the minimum recyclate input quotas, which had recently led to disagreements with the European Commission. When implementing the regulation, it is fundamentally important that the EU Commission and national governments work closely with the industry to find solutions that take into account both the environmental objectives and the needs of the industry.

Related article: PPWR ready for adoption

One key point is the question of whether recycled plastics from third countries that are used in the production of new packaging may also be counted towards the fulfilment of the recycled content targets. The EU Commission had only envisaged this possibility for recycled plastic that originates from post-consumer waste collected and recycled within the EU. However, after the compromise text between the EU Council, EU Commission and EU Parliament also provides for the eligibility of recycled plastics from countries outside the EU. How would that influence the proposed system and the goals of the PPWR and the Green Deal?

This is quite a complex question. If we include recycled plastics collected and processed outside the EU in the targets of the new packaging regulation, this would expand the market for recycled plastics. It could increase the availability of recyclates which in turn could reduce the need for fossil raw materials. It would be a positive step towards the Green Deal goals of reducing greenhouse gas emissions and promoting a circular economy. However, we would need to ensure that these imported recycled plastics meet strict quality and safety standards, especially if they are used for packaging that comes into contact with food. This would mean that the EU would need to put in place effective control mechanisms to monitor compliance with these standards.

But of course there are also major potential challenges. The price of recycled plastics could rise if demand outstrips supply. We have seen this scenario before with PET prices. In addition, the environmental impact of transporting recyclates over long distances could negate the benefits of reducing greenhouse gas emissions through recycling itself. Thus, the inclusion of recycled plastics from third countries could support the objectives of the PPWR and the Green Deal as a whole, but it is important that we carefully consider the implications and ensure that the integrity and effectiveness of the system is maintained.

Are there countries or other stakeholders opposing important measures?

As already described in the second answer, new regulations always bring with them different opinions and interests. The challenge is ultimately to find a suitable compromise in the final legislative text. The PPWR is now at the end of the EU legislative process, which means that the countries have reached a provisional agreement. Final adoption is expected at the end of 2024.

Related article: Plastic packaging producers want to remove material-specific rules in PPWR

What steps do producers need to take to achieve the planned targets?

The circular economy must be transformed from a peripheral issue into a central component of corporate policy. The industry is increasingly being held accountable for demonstrating commitment to sustainability and fair processes. The biggest challenge for packaging manufacturers concerning the PPWR is to switch to more environmentally friendly materials and designs to fulfil the requirements of the new regulation. In some cases, this also requires investment in research and development in order to develop new, sustainable packaging solutions and at the same time guarantee the functionality and safety of the packaged products. This can be particularly challenging for packaging that comes into contact with food. In addition, consumers must be offered reusable packaging, which in turn must be accepted by consumers. This may not always be convenient, but it is good for the environment. Manufacturers, producers and consumers alike need to get to grips with making a contribution to a more sustainable circular economy - while politicians need to provide the legal framework.

To name one example: Single-use plastic packaging for fresh fruit and vegetables weighing less than 1.5 kg may no longer be sold from 1 January 2030, apart from defined exceptions. From then on, fruit and vegetables could practically only be sold openly or in other forms of packaging material than single-use plastic. Manufacturers will also have to prepare for more consumer protection at EU level. The planned "Green Claims" Directive is intended to enable sustainable purchasing decisions and put an end to greenwashing. For example, voluntary environmental claims such as "30% recycled plastic packaging" should no longer be permitted without independent testing and scientific evidence.

What impact will the proposed regulation have on the waste management industry?

Increased standardisation in the production and design of packaging will make it easier for the waste management industry to process this packaging. Sorting and recycling processes can thus be optimised. New opportunities may also arise in the processing of collected material, such as the continuous further development of chemical recycling, which should provide reliable, homogeneous material flows for the economy. The PPWR is expected to reduce the consumption of resources for packaging and help to reduce waste and pollution. Manufacturers will be encouraged to avoid unnecessary packaging and to design packaging in such a way that it is easily recyclable. This includes the use of recyclable materials and the labelling of packaging to facilitate correct disposal. The regulation will also hold manufacturers accountable by requiring them to participate in collection and recycling programmes and to bear the costs of disposing of packaging waste. This should incentivise the production of environmentally friendly packaging and support waste management. The regulation has the potential to revolutionise the way packaging is produced and managed and could create new business opportunities for companies specialising in sustainable solutions.

Many products are difficult to recycle due to their product design. How can the design for recycling be improved and would legal requirements necessary?

In order to improve the design of products for recycling, manufacturers should already consider the subsequent disposal and recycling during the development phase of a product. This includes selecting materials that are easy to separate and recycle, reducing the variety of materials and avoiding composite materials that are difficult to separate. The design of products is another important aspect that enables easy dismantling. This makes it easier to separate the various materials and components at the end of the product life cycle. In addition, by using modular designs and standardised parts, manufacturers can extend the reparability and therefore the service life of products. Legal requirements can create a framework that encourages manufacturers to develop more environmentally friendly and recyclable products. The EU has already taken steps in this direction by proposing ecodesign regulations that set minimum standards for durability, repairability and recyclability. These regulations could help manufacturers design more sustainable products and thus reduce the amount of waste that ends up in landfill or incinerated. Overall, it is a combination of conscious design, material selection and regulatory frameworks that can improve the recycling of products and drive the circular economy forward.

Eva Müller-Axmann is a circular economy expert and Managing Director at the international management consultancy RecyleMe. The company supports renowned clients in the fullfilment of international obligations relating to extended producer responsibility (EPR compliance).