Revision of the Packaging and Packaging Waste Directive

In its efforts to tackle the challenges related to waste, overpackaging, and sustainable production, the European Commission not only introduces additional regulations but also focuses on the adaption of existing legislation. A milestone in the EU’s approach to respond to the environmental challenges we are facing is the revision of the Packaging and Packaging Waste Directive (PPWD). Together with the development of a policy framework on bioplastics and the revision of the Waste Framework Directive, the PPWD ranks amongst the most important policy processes for the bioplastics industry. With 48 percent, packaging is by far the largest sector for bio-based, biodegradable and compostable plastics.  

Bioplastics need a clear regulatory environment 

Bioplastics can make significant contributions to successfully tackle the challenges the Commission aims to overcome, but they require a transparent and reliable regulatory environment to fully tap its potential. However, so far, bioplastics lack a comprehensive regulatory EU policy approach, a fact that had also been confirmed recently by the European Commission’s “Bioeconomy Strategy Progress Report”. Therefore, it is important that the revision of the PPWD fully acknowledges the role of bioplastics within a circular economy. All regulations included in the PPWD must go in line with the priorities outlined in the European Green Deal, such as establishing a proper waste management infrastructure, reducing the dependency on fossil resources, and encouraging innovation in packaging.     

Driving the transition towards a low-carbon circular economy requires carbon to be regenerated using renewable resources. Therefore, the promotion of alternative feedstocks in EU packaging legislation should not be limited to recycled feedstock alone. It must also include bio-based feedstock as this can significantly contribute to achieving climate neutrality in the EU by 2050 and to closing the carbon loop. At the same time, biodegradable and compostable plastics help in closing the material cycle as well as the biological one. A particular benefit of biodegradable plastic packaging is that they can help in collecting a larger share of the municipal kitchen waste which would then otherwise end up in landfill or incineration.  

Definition of recyclable packaging  

Policy makers in the European Union should be cautious when focusing exclusively on the recycled content. Mechanical recycling will neither be enough alone to end Europe’s dependency on fossil resources, nor will it stop the current trend of over-packaging and excessive waste in the EU. Therefore, the EU-wide definition of recyclable packaging as part of the PPWD revision must also include compostable packaging which is designed to biodegrade in industrial composting (certified EN13432) and through the composting process closes the organic carbon cycle as soil improver. In this regard, the promotion of recyclability in packaging is very much supported by the bioplastics industry. However, the proposed 95% mandatory recyclability threshold is well over the target. Because one size does not fit all and the definition of recyclability must consider all different products used for packaging, their material specificities, and market share. 

Maximum period of 10 years to develop recycling stream 

To further boost recycling in the European Union, the Commission also proposed a 5-years period to be granted to new innovative packaging placed on the market. Accordingly, new packaging must be able to develop a new recycling stream within a 5-years period to remain in the market. For several reasons, such as demand or technology, this process can take significantly longer than the proposed 5 years. Such a requirement obviously does not incentivize to invest in innovative packaging. To avoid that it will hamper development in the bioplastics industry, the Commission should consider an extension of the maximum period to 10 years. This time period would better reflect the actual conditions on the market.        

Revision of Essential Requirements 

The revision of the PPWD also includes an amendment of the Essential Requirements for Packaging (ER). With regards to the ER for biodegradable and compostable packaging, the revised version should not scrap the current requirements. It is also important that the ER apply to all packaging following the principle of material neutrality. Before putting a packaging on the market, several other aspects should also be taken into consideration, e.g. prevention and re-use should be reviewed and in the case of recycling all technologies should be compared on an equal level (recycling technology neutrality). Organic recycling should be the preferred end-of-life methos in case it increases the capture rate of bio-waste and compostable packaging should also be exempted from targets regarding recycled content. To not hamper an emerging but still immature industry like the one of bioplastics, the Commission should rethink its proposal of a legally binding list of applications for packaging.   

The revision provides a great opportunity to sufficiently consider the important role that bioplastics play in reducing environmental and climate impacts. Therefore, it would be important to: 

  • include a provision in the PPWD that compostability falls within the definition of recyclability. 
  • consider bio-based content equal to recycled content for packaging.  
  • acknowledge the benefits brought by bio-based plastics in defossiling the economy. 
  • Incentivize innovation in the (bio)economy and include a 10-years minimum for innovative products placed on the market to find a proper recycling stream.   
  • Not include a 95 percent recyclability threshold in the definition of recyclable packaging. 
  • Promote an internal market for bio-based, biodegradable, and compostable plastics. 

To receive more detailed information on the PPWD revision and European Bioplastics’ view on the individual elements, please read our EUBP Position Papers: 

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