PPWR unpacked - Part 9: Update on Reduction Targets and Packaging Bans

The rapporteurs in the European Parliament and the representatives of the Member States in the Council working group have been very busy over the last few weeks and are currently compiling their amendments to the Commission's proposal for the EU Packaging Regulation (PPWR). As reported, the Parliament's Environment Committee will vote on the proposals on 23/24 October and the plenary session is scheduled for 20 November. Member States are expected to decide on their position at a meeting of environment ministers on 18 December. If this does not succeed, it is very unlikely that the PPWR will actually be adopted before the European Parliament elections.

Today we turn to a highly political issue that has dominated public reporting on the PPWR: the reduction targets and packaging bans. As you know, the Commission had proposed that Member States reduce the amount of packaging waste per capita - regardless of the packaging material - by 5% by 2030, 10% by 2035 and 15% by 2040 compared to 2018. But for some this is not enough, for others it goes too far.

Special reduction target only for plastic packaging?

The Environment Committee's rapporteur, Frédérique Ries, wants more. She has proposed a specific reduction target for plastic packaging only, requiring member states to reduce plastic packaging waste per capita by 10% by 2030, 15% by 2035 and 20% by 2040 (see amendment No. 171 ).

The proposal may be well intended, but it has significant undesirable side-effects: A recent study shows that plastic packaging, with an average weight of 24 grams per kilogram of packaged product, is significantly more material efficient than all alternative packaging materials (116 grams per kilogram of product on average) and is therefore irreplaceable for a more efficient use of resources and the reduction of packaging waste (see GVM 2023 , p. 13). The study by GVM Gesellschaft für Verpackungsmarktforschung also shows that a 10% reduction in plastic packaging by 2030, as proposed by Ms Ries, would lead to a 10-20% increase in the amount of household packaging if it were replaced by other materials (GVM 2023 , p. 26). As a result, greenhouse gas emissions would increase by 10-14% (p. 31).

In addition, such a specific reduction target would further foster the questionable trend towards composite packaging, i.e. paper packaging laminated and coated with plastic, which uses less plastic than pure plastic packaging but cannot be recycled as far as its plastic content is concerned. This makes it more difficult to achieve plastic-specific recycling rates and recycled content quotas.

A specific reduction target for plastic packaging also encourages a shift to other single-use materials rather than promoting reusable packaging. Environmental associations and the retail sector agree that there is great potential to significantly reduce packaging consumption and greenhouse gas emissions in the wholesale and retail sectors through standardised reusable transport boxes/crates used in a pool system, such as the #GS1 SMART box . According to studies by GVM and ifeu Institute, this would save over 90% of packaging consumption and over 35% of CO2 emissions in this segment compared to disposable cardboard boxes (NABU 2023 , FreshPlaza 2022 ). Green Economy start-ups such as #RECUP , #Vytal and #Boomerang are currently discovering innovative business models for reusable packaging systems for catering and mail order sectors, relying on plastic for its robustness, lightness and recyclability.

Threat of cementing the market shares of packaging materials

The Member States, on the other hand, are debating quite different issues, namely the consequences of the general packaging reduction target proposed by the Commission. Irritated by the fact that such a reduction target would lead to heavy packaging being replaced by light packaging (e.g. glass by plastic), the Spanish presidency has proposed to virtually cement the market shares of packaging materials: Specifically, it is proposed that the amount of packaging waste per packaging material should grow by a maximum of 2.5% by 2030, 5% by 2035 and 7.5% by 2040.

This proposal explicitly targets plastic packaging and clearly contradicts the goal of the EU to be climate neutral by 2040. As we have seen, plastic packaging is a significant driver of CO2 reduction in the packaging sector. The Spanish proposal also contradicts the objective of replacing single-use packaging with reusable packaging where the latter is environmentally preferable, as reusable packaging is predominantly made of plastic.

Dispute in parliament over packaging bans

In Part 5 we have taken a close look at the Commission's proposals on packaging bans. In principle, the proposals are well received by the Environment Committee and Member States. The main focus of public reporting has been the ban on single-use packaging for on-site consumption in restaurants (including fast food), which the paper industry has been lobbying against for months. In recent years, single-use paper packaging has gained significant market share in this area as plastic packaging has been replaced in many cases. A ban on single-use packaging would inevitably lead to an increase in reusable packaging, most of which is made of plastic.

While Patrizia Toia, rapporteur for the industry committee ITRE (which shares competence with ENVI on packaging bans), had argued for the removal of the ban, ENVI rapporteur Ries is sticking to the ban in principle and only wants to allow exceptions in cases where there is no access to a reuse infrastructure. In the Council, however, the paper industry scored points by pointing out that there is supposedly no alternative to e.g. hamburger wrapping paper. As a result, it was proposed to exempt flexible packages and wrappers from the ban. However, it is questionable whether this proposal will survive the in-depth discussion with the Commission and the Parliament in the trialogue.

The second major issue is the Commission's proposed ban on single-use (material neutral) packaging for fresh fruit and vegetables. ITRE rapporteur Toia also wants to delete this ban, while ENVI rapporteur Ries wants to keep it, but limit it to plastic and composite packaging, so that, for example, cardboard packaging would be allowed.

Unlike ITRE, Ms Ries also appears to have no problem with the proposal that the Commission itself should be able to enact new packaging bans by delegated act - effectively bypassing Parliament and the Member States.

As a co-advisory committee, ITRE has the opportunity to put its proposals, which were not taken up by the leading ENVI committee, to a vote in plenary. This sets up a showdown in the European Parliament on 20 November.

Discussion about XPS packaging in the Council

In the Council, the Spanish Presidency has raised the issue of extending the packaging ban in the EU's Single-Use Plastics Directive (SUPD) to food and drink containers and cups made of XPS (extruded polystyrene). France, in particular, is pushing for an extension of the SUPD, claiming that manufacturers would circumvent the EPS ban in the SUPD by switching to XPS packaging.

It is easy to see that this allegation is based on a weak foundation by looking at the differences between EPS and XPS: XPS consists of gas cells that are cross-linked with each other, which hold together firmly and cannot be separated from the composite structure afterwards, e.g. by rubbing. In EPS packaging, on the other hand, the foam beads can be easily detached by friction. Therefore, the detailed examination of beach finds in Europe in the run-up to the SUPD 2019 did not provide any evidence that XPS packaging should be banned. For example, XPS takeaway packaging existed long before the SUPD and ensured the economic survival of many small restaurants and cafes during Covid19. A return to single-use aluminium trays, as was common in the 1990s, would be a huge step backwards for climate and resource protection. It is also clear that XPS packaging must also meet the future requirements of the PPWR, such as recyclability and recycled content.

Here are the links to all previous parts of this blog:

Part 1 : Process and People

Part 2 : All packaging shall be recyclable

Part 2a : Struggle over "Recycled at Scale" Criterion

Part 3 : Minimum quotas for recycled plastics in packaging

Part 3a : Bio-Based Plastics as Alternative for achieving the PPWR Recycled Content Quotas

Special : One Law to Rule them all - updated

Part 4 : Make all Packaging Re-usable again

Part 4a : Ban on Single-Use B2B Packaging?

Part 5 : More Packaging Bans ahead

Part 6 : Parliament and Council draft amendments to Commission Proposal

Part 7 : Update on the Recyclability of Packaging

Part 8 : Update on Recycled Content Quotas for plastics in packaging

Part 8a : How to Overcome the Recyclate Gap in 2030

Part 8b : How to calculate chemical recycling performance and why it matters