Packaging and Packaging Waste Regulation - a BusinessEurope position paper

Key messages

BusinessEurope supports the ambition to establish a functioning internal market for packaging and secondary raw materials and a more circular economy, while addressing the adverse impacts of packaging waste on the environment.

European businesses have made extensive efforts to adapt their business models and develop new circular materials and product flows, including major investments in the recyclability of products. Businesses are now urging policymakers to ensure that the regulatory landscape creates favourable market conditions for a circular economy, where environmental benefits and increased competitiveness goes hand in hand.

The choice of legal instrument, i.e., a Regulation, with an internal market legal basis is welcome since it will contribute to increased harmonisation of e.g. labelling and packaging design requirements across Member States. As such, it has the potential to enhance the competitiveness of European companies, considering the high costs of complying with divergent requirements, and contribute to the development of a circular economy. While requirements for companies should be harmonised, provisions in the Regulation should not undermine efficient waste management systems already in place.

In nine specific areas, the proposal needs further work to better contribute to a circular economy:

• Reuse and recycling are complementary solutions to achieve circularity and should be treated as such in the Regulation.
• To achieve ‘recyclability at scale’, the Member States need to support with investment in infrastructure for collection, sorting and recycling of packaging waste. Existing EU funding should be made available to support the development of innovative solutions to achieve the ambitious aims of the PPWR.
• To ensure optimal environmental and economic outcomes, Member States should be prevented from introducing divergent or additional national requirements that risks fragmenting the internal market.
• Design for recycling criteria should be developed in close cooperation with relevant stakeholders, including from the packaging value chain, be technology neutral, backed by scientific evidence, and designed to foster innovation.
• For the targets for recycled content in plastic packaging to be reachable, they should be set as an average of the overall portfolio of plastic packaging of the economic operator placed on the EU market, instead of per packaging unit. Increased collection rates and separate collection is key to ensure access to sufficient quality recycled content.
• A more thorough impact assessment is needed to ensure that reuse targets and packaging bans are only put in place where it makes sense from a safety, hygiene, environmental and climate perspective based on a Life Cycle Assessment.
• Packaging waste minimisation requirements should guarantee packaging functionality, recognise the different packaging needs of various products and avoid conflicts with the reuse objective as well as disruption of transportation chains.
• Further work is needed to ensure the definitions are clear and differentiates between commercial/industrial and consumer packaging.
• Companies should be granted sufficient time to adapt to the new requirements.