Despite significant improvements in rates of recycling of packaging, the overall increase in use has complex environmental impacts. In line with the circularity objectives of the European Green Deal and the Circular Economy Action Plan, the EU is adopting a Packaging and Packaging Waste Regulation (PPWR). The intent is to reduce the amount of product packaging waste and to contribute further to the circular economy in the market.
The regulation covers a range of topics which contribute to the packaging of products. In this article, we examine the core elements of the legislation and consider what businesses can do to comply when it comes into effect.
Objectives of PPWR
Aligned to the EU Green Deal, the objective of PPWR is to reduce the amount of packaging waste generate by the EU, to ensure packaging is sustainable and safe and to encourage further growth in the circular economy. In doing so, the EU will create a harmonized approach to labelling, giving consumers better information about the packaging on products.
Key Elements of PPWR
Within PPWR there are four main regulatory topics that companies must take into account. In the sections below, we will delve into each of these and outline the steps businesses can take to properly prepare.
Packaging Sustainability and Recycled Content
The first key areas the regulation addresses is the composition of packaging and the need for all packaging to be recyclable. These include restrictions on substances of concern used in packaging, in particular food contact packaging. Minimum volumes of recycled content in packaging, increasing over time up to 2040.
A recognition that bio-based packaging is likely to continue to evolve rapidly and for a reassessment to take place in 3 years to factor changes into the legislation. Finally, rules to reduce unnecessary packaging, including restricting the maximum amount of empty space within packaging of products to 50% to reduce the volume of materials required.
Re-Use and Refill
To reduce the amount of packaging used in the market, the re-use of packaging is a key aspect of the legislation. There are targets set across different types of packaging for 2030 and an indication of further targets by 2040. There range from 5% by 2030 for alcoholic beverages to 90% by 2040 for bulk shipment containers such as pallets and drums.
To re-use packaging, there needs to be refill systems made available for the corresponding products. The regulation focuses on food and beverages for refill systems, setting out targets for companies to adhere to by 2030 and 2040. The calculations for the percentage of products and packaging made available are calculated as averages over the year.
Deposit Return Systems
Still focusing on reducing the amount of new packaging and increasing the volume recycles, deposit return systems (DRS) are in scope of the regulation. The focus of attention is plastic bottles and metal drinks containers. The target is for each member state to collect at least 90% of these items by 2029.
Restricted Type of Packaging
Single-use plastics are already regulated within the EU under the SUPR, but PPWR extends on restrictions on their use for certain formats. Items such as hotel toiletries, condiments, nets, trays and use of cling wrap for grouped items to encourage multi-buy scenarios are all restricted.
What will business need to do to comply?
Many businesses operating in the EU market are already advanced in their use of packaging and transition towards more sustainable formats. As with many policies under the Green Deal, PPWR extends the obligations of companies much further than many are already committed to.
General guidance for companies is to move away from use of virgin materials in packaging. Focus should shift to the quality and durability of packaging to align with PPWR. To prepare to comply with the regulations, we have identified three areas of focus for businesses to start now.
Baseline Assessment
The regulation creates a harmonised set of rules against which companies can now assess their compliance. Performing a baseline assessment of the existing packaging strategy should be the first activity. This will include identifying where the regulation affects the business and the timelines and corresponding targets.
The assessment should include both goods for resale and goods not for resale and span across the value chain. The output of the assessment should be a clear identification of what actions, over what timeline need to be completed to comply. Our Prepare & Assess service is designed to deliver this outcome.
Value Chain Engagement
To meet requirements in PPWR will require collaboration. Most companies will be involved in complex value chains which extend outside of the EU. Engaging suppliers and distributors to communicate the need to comply with the regulation is a task which should start now. The import of goods which include packaging will be in scope of the regulation, placing an obligation on the company to ensure compliance.
The engagement with suppliers should communicate expectations to comply with the regulation, identify areas of concern from the baseline assessment and promote collaboration to foster a positive environment for transition, rather than simply shifting the burden to suppliers.
Transition Plan
Developing a transition plan to comply with the complex regulations is recommended. This plan should consider how to adapt the business to meet re-use and refill requirements if appropriate. Implementing these changes will require significant resources.
Companies using single-use plastics should align with DRS capabilities, taking into consideration the countries in which they operate and the local requirements. The transition plan also needs to include actions to address labelling of packaging to comply with regulations. A task which is also likely to extend significantly to value chain partners.
A comprehensive transition plan will address immediate areas of concern and also implement controls to ensure future compliance with PPWR. Our compliance programs and operational integration services support companies in these activities.
How We can help
Our teams of experts have the knowledge and experience to align your company with PPWR compliance. We provide services that can help you identify your specific scope of compliance and to help you to plan and execute the transition. Our work is tailored to your business’s specific needs, empowering you to meet the regulations. Get in touch to learn more about how we can help you succeed.
