PPWR: What are the next steps?
4evergreen alliance
The 4evergreen alliance aims to boost the contribution of fibre-based packaging to a circular and sustainable economy
Back in November 2022, the European Commission proposed the Packaging and Packaging Waste Regulation (PPWR), with the goal of reducing the amount of packaging waste and further harmonising EU-wide rules on packaging.
While not yet in force, the PPWR is expected to be formally approved by the end of 2024. If approved, it will be published in the Official Journal of the European Union, entering into force 20 days after its publication and becoming enforceable 18 months thereafter.
This means that, in practice, new rules for EU packaging will have to be implemented in all 27 EU Member States in the summer of 2026.
What can you expect?
The PPWR will change the packaging landscape in Europe. Companies will need to prepare for substantial changes in how they handle product packaging to comply with the PPWR.
In line with the circular economy, the PPWR requires all packaging in the EU – with very limited exceptions – to be recyclable from 2030 onwards.
But what exactly constitutes "recyclable"?? Packaging will be considered recyclable if it meets the following requirements:
Firstly, as of 2030, all packaging items placed on the market must be designed for recycling. This means that individual packaging will have to comply with the ‘Design for Recycling’ Criteria, which will define what makes packaging recyclable from a design perspective. These criteria will be coined in the secondary legislation process by 2028 and enter into force in 2030.
Packaging will also be classified under three defined performance grades —A, B, and C— based on its recyclability.? To be considered recyclable, packaging will need to achieve a minimum grade of C (70% recyclable by 2030). Above 70%, design for recycling will be encouraged by modulation of extended producer responsibility (EPR) fees, which will remain at national authorities, according to performance grades. These fees aim to be an economic instrument to incentivise more sustainable packaging design, resulting in improved collection and recycling of packaging. Consequences for not fulfilling minimum recyclability thresholds will be product ban from the EU market.
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Secondary legislation will define how to assess and communicate recyclability performance in grades per packaging unit, as well as establish a framework for these eco-modulated fees.
Secondly, packaging must also be fit to be sorted into specific waste streams without affecting the recyclability of other waste streams and ‘recycled at scale’ (from 2035). The specific methodology for assessing this will also be established through secondary legislation.
As of 2038, packaging will need to achieve a minimum grade of B (80% recyclable) to be considered recyclable.
Some of the requirements will be determined in the coming years and established in coordination with EU member states.
Best practices in design guidelines can inform standard setting
European standards, developed by a recognised European Standards Organisation such as CEN, the European Committee for Standardisation, cover aspects such as terminology, dimensions, capacities, marking, test methods, performance requirements, and environmental aspects in the field of packaging. Therefore, they play an important role in promoting a high level of environmental protection.
The industry's input is essential to ensure that standards are based on best practices. The work will not start from scratch: the 4evergreen alliance has been leveraging its members' expertise for more than three years to develop tools that can perfect the circularity of fibre-based packaging.
By working together, the industry can help shape the future of sustainable packaging in Europe and achieve 4evergreen's goal of increasing the overall recycling rate of fibre-based packaging to 90% by 2030. Check out 4evergreen’s industry tools and guidelines here.
One very special topic are transport packaging. Most companies we are talking to are not aware of the requirements. And they seem to be even more complex to realise than consumer packaging. That's why we created decision trees and graphics to break down the legislative complexity to easy guidelines. There is a lot to do over the next years for all packaging types.
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