6 tips to improve the new EU packaging regulation

By Nick Dornheim, Adviser Sustainability & Environment, EuroCommerce

Retailers and wholesalers are significant users of packaging and therefore, closely following the review of the proposal for a Packaging and Packaging Waste Regulation (PPWR). The European Commission proposal was published in November last year with the overall goal of reducing the amount of packaging and its impact on the environment by using more reusable and recyclable packaging. The European Parliament will vote on this important Regulation next week, while the Member States are currently still debating its position.

Retailers and Wholesalers support the harmonisation of EU rules for packaging and a truly Single Market for waste, as it facilitates sales across borders. A joint study with McKinsey, estimates that our sector needs to invest 10-20 billion Euros from 2023 up to 2030 to increase the circularity of packaging. The new regulation should support retailers and wholesalers in their efforts and provide clarity and legal certainty.

From what we hear in the European Parliament and the discussions in the Council, the co-legislators need to get the following 6 points right to make this legislation a success and to ensure that it works for the environment, consumers, manufacturers of packaging and packaging users, including the 5 million retailers and wholesalers in Europe:

1. The regulation should support businesses in their efforts to use less packaging and refrain from forcing businesses to use a specific reuse format such as refill at store level, where other initiatives and innovations might be more appropriate. Refill stations, which are being pushed by the legislators, are – contrary to popular belief – not necessarily the best environmental solution. Retailers already deploy refill stations where they are useful, based on several factors that need to be considered. These include limited product suitability and freshness, potential allergen cross-contamination, the risk of inaccurate labelling, potential food waste and spoilage, the need to ensure hygiene standards and additional floor space. In addition, refill stations for retailers of textiles and electronics are hardly practicable and could only provide refill stations for a very limited product range, if at all.
2. The choice of the optimal packaging should be based on an assessment of the environmental impact that covers the entire value chain. Realistic reuse requirements, based on an objective and science-based analysis, should be used to give retailers and wholesalers the flexibility to deploy the solutions that work best for their shops, products and customers.
3. Labelling of packaging is very important for retailers and wholesalers; therefore, it is important to define the roles and responsibilities of all economic operators across the supply chain, in line with activities under their control. Businesses should be granted at least 36 months to prepare for new labelling requirements. The proposal also represents an opportunity to boost digital labelling and it should be technology-neutral to allow means other than QR codes to be used for labelling.
4. The new packaging regulation needs to deliver both harmonisation and ensure the free movement of goods. We need regulation with clearly defined, harmonised rules at EU level to create a Single Market for Waste. I believe we all want to avoid situations, where one country requires packaging to bear a specific national packaging label while the neighbouring Member State bans the very same label. And to ensure uniform enforcement of these new rules in EU Member States the regulation needs to ensure mutual recognition of agreements between Member States and the EU Single Window Environment for Customs.
5. We all support the target for more recycled content in packaging – this way we reduce the use of virgin resources. However, policymakers must pay attention to the availability of recycled material on the market and ensure that the right legal framework and waste recycling infrastructure are in place so that the targets can be fulfilled.
6. Very important for food retailers and supermarkets are planned packaging bans, which might have cross-contamination of waste and the environment. The sector has been part of the discussion on how to reduce plastic packaging for years and retailers have done a lot to reduce their plastic- use where possible. A good example is the famous cucumber wrapped in plastic and travelling long distances, which requires wrapping to avoid cross-contamination and food waste. Packaging bans cannot properly take into account the many, often conflicting factors that have an impact on the choice of the optimal packaging or even no packaging at all.

To do their job well, retailers and wholesalers need the free movement of goods. The current packaging proposal could disrupt existing and well-functioning systems and provide in the worst-case unworkable requirements on recyclability, reuse and recycled content. Shops and wholesalers need enabling and supporting actions as well as clear and timely deadlines, guidelines, transition periods and accompanying measures.

Let’s ensure that we get the update for the EU packaging rules that is urgently needed, and which can guide us towards more sustainable development for the next years and decades to come without jeopardising the competitiveness of businesses in Europe.