Packaging and Packaging Waste Regulation: Retailers and wholesalers need harmonised EU rules for packaging and solutions that work for shops, products and customers

Today, the European Parliament’s Committee on the Environment, Public Health and Food Safety adopted their report on the proposal for a Packaging and Packaging Waste Regulation (PPWR), including requirements on refill stations for retailers, bans for packaging for fruit and vegetables and reuse and refill requirements for several packaging formats.

Commenting on the report, EuroCommerce Director-General Christel Delberghe said:

“Retailers and wholesalers support harmonising EU rules for packaging and a truly sustainable Single Market for waste. The regulation should support our members in their efforts and must provide clarity and legal certainty. We are highly concerned to see that the Committee added an unclear, unimplementable and unnecessary refill station requirement for retailers as well as bans for fruit and vegetable packaging. On the issue of reuse and refill targets, we need legislation that gives retailers and wholesalers the flexibility they need to deploy solutions that work best for their shops, products and customers”.

The association, representing European retailers and wholesalers, asks the European Parliament to take the following points into account during the next steps of the legislative process:

• Reuse and refill: The choice of the optimal packaging should be based on an assessment of the environmental impact that covers the entire value chain and key terms and concepts (minimum number of rotations, reusability requirements, pooling, and distribution lengths) that need to be clarified to allow for optimising storage and distribution processes.
• No mandatory refill stations: This new provision, which was not included in the Commission proposal or the Impact Assessment, is concerning for several reasons including lack of legal clarity, limited product suitability and freshness, potential food waste and spoilage, the need to ensure hygiene standards and disproportionate demands for additional floor space. Refrain from adopting mandatory refill station obligations.
• No ban on packaging for fruit and vegetables: Avoid restrictions for packaging for fresh fruit and vegetables. Packaging bans are not the right solution to address the many, often conflicting factors that define the choice of the optimal packaging (or even the need for no packaging at all). Therefore, this restriction should be deleted from the proposal.
• Labelling of packaging: Retailers and wholesalers support and welcome the harmonised labelling on packaging proposed in Article 11 as this helps establish a new norm where all EU citizens will know how to appropriately dispose of their packaging. They need clear and proportionate roles and responsibilities for all the actors across the supply chain, regarding their labelling obligations, in line with activities under their control, and at least 36 months for businesses to prepare. However, in the specific case of labels for deposit return systems with a security function, those labels should be allowed to be used without time restriction.
• Harmonisation and free movement of goods: Retailers and wholesalers ask the European Parliament to ensure harmonisation and free movement of goods and to maintain the Internal Market legal base. In line with that, deadlines, guidelines, transition periods and accompanying measures need to allow companies sufficient time to prepare for compliance.

EuroCommerce calls for a directly applicable Regulation with clearly defined, harmonised rules at EU level to avoid divergence between Member States, and to create a harmonised Single Market for Waste with better management and recycling. The European Parliament should deliver legislation that ensures that the free movement of goods doesn’t disrupt existing and well-functioning systems and provides achievable recyclability, reuse, recycled content and waste prevention requirements.

This needs to include enabling and supporting actions such as private and public investments in waste infrastructure, and clear, timely deadlines, guidelines, transition periods and accompanying measures such as the new Packaging Forum as an expert group to support the implementation of the regulation and bring relevant stakeholder together to provide expertise on the future delegated and implementing acts.