The European Commission (EC)’s proposal for a new EU Packaging and Packaging Waste Regulation (PPWR), published today, will require significant improvements to be workable for food business operators to help achieve the collective ambition for sustainable packaging. That is according to the FoodDrinkEurope statement, which has been issued following the regulation changes.

Meanwhile, UNESDA Soft Drinks Europe flags that “further improvements are necessary” to accelerate the transition to a circular economy.

“The EC’s proposal contains several positive aspects, notably the push for harmonization to boost packaging circularity,” says Dirk Jacobs, director general of FoodDrinkEurope. 

“However, it lacks tools to support the food, drink and packaging sectors with the infrastructure and enablers to allow faster uptake of reducing, reuse and recycling processes.”

Last week, a group of business representatives, consumers and environmental organizations called on the EC not to bow to a recent tide of industry lobbying pressure against planned revisions to the Packaging and Packaging Waste Directive (PPWD).

A group of over 50 European packaging associations also released a statement expressing “serious concern” over the EC’s revision plans.

“Well-intended but regrettably unrealistic”
Jacobs at FoodDrinkEurope believes the targets and timelines set regarding reuse and re-fill are well-intended but regrettably unrealistic without appropriate enabling conditions and could even hamper – rather than enhance – sustainable packaging aims.

With the EU’s circular economy ambitions, the European food and drink industry has invested heavily in the transition to sustainable packaging. 

UNESDA Soft Drinks Europe says the proposal must address downcycling food-grade materials into non-food-grade applications.However, over the years, the industry’s efforts have been hindered by a lack of infrastructure in the collection and sorting in many countries across the EU, delayed authorization of recycling innovations and a growing shortage of available food-grade recycled material, which is needed for food safety and hygiene. 

The industry needs stable and consistent conditions to engage in long-term business investment to enable circularity in the future, underscores Jacobs.

On a positive flip, the legal instrument of a regulation, rather than a directive, should facilitate a harmonized approach across EU Member States, including harmonized sorting instructions, minimum requirements for deposit return schemes (DRS), and eco-modulation of fees for extended producer responsibility schemes (EPR).

However, the EC’s proposal still leaves too much space for divergent national initiatives, further fragmenting the Single Market and countering the proposal’s objective, argues FoodDrinkEurope.

Further bans on the horizon?
In addition, the proposal gives extensive power to the EC to expand measures such as bans on types of packaging, which does not provide businesses across the EU with predictability to gear their investments in the coming years. 

FoodDrinkEurope is also concerned about the administrative and associated cost burdens the proposal places on companies, particularly Europe’s 289,000 food and drink SMEs.

In short, FoodDrinkEurope believes the proposal will need to provide better clarity on definitions and timely, unequivocal guidance for the industry. The organization also wants to see realistic targets and timelines, ensuring targets consider availability and costs, impact on the environment, as well as the quality of infrastructure and technology available. 

UNESDA’s opinion 
Meanwhile, UNESDA Soft Drinks Europe says its sector is fully committed to accelerating the transition to a circular economy. The organization has made several bold commitments in its Circular Packaging Vision 2030.

“The proposal is ambitious and contains several important enablers for Europe’s journey toward increased collection and recycling and the integration of more reuse. However, further improvements are necessary to support our sector in achieving full circularity and integrating more reuse,” explains Nicholas Hodac, director general of UNESDA Soft Drinks Europe. 

He outlines that the proposal needs to urgently address the issue of downcycling food-grade materials into non-food-grade applications. 

“It currently fails to include a priority access mechanism or right of first refusal that grants fairer access to the necessary amount of recycled content to those sectors that are required to use food-grade materials to comply with EU food safety requirements.”

Hodac says this is a “key enabler for further promoting closed-loop recycling while preventing downcycling of food-grade recycled materials.”

Sectors that are not required to use food-grade materials must also be incentivized to invest in efficient collection and recycling systems that can achieve true circularity for their products.FoodDrinkEurope believes the targets and timelines are well-intended but “regrettably unrealistic.”

In addition, the proposal places reuse targets only on the beverage sector and on each of its manufacturers, distributors and in each Member State, notes Hodac. 

“The PPWR needs to consider the huge diversity of economic operators in the beverage sector, the different sizes of the companies and the different types of consumption experiences of Europeans. Indeed, many businesses may become unsustainable due to ineffective use of recycling technology investments, which will be made redundant with the necessary additional reuse investments in each country.”

Lack of evidence for proposed approach 
The proposal also does not state how the circularity of recyclable beverage packaging, achieved through mandatory investments in deposit return schemes, will be protected.

According to Hodac, there is also a lack of evidence that the proposed approach for reuse targets will lead to the intended environmental outcomes.

“That’s why we reaffirm the need for the targets to be based on a thorough environmental and cost impact assessment to ensure that reusable beverage systems are only put in place when and wher they make the most sense for our environment and are cost-efficient,” he explains. 

“We look forward to engaging with the European Parliament and the Council of the European unio to ensure that the legislative framework builds the right enablers for our sector to move toward full circularity of beverage packaging in Europe.”