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PPWR: Everything you need to know

The Packaging and Packaging Waste Proposal

In November 2022, the European Commission launched the proposed revision of the EU legislation on Packaging and Packaging Waste. The proposal aims to cut down on Europe’s packaging waste and promote reusable alternatives. The Packaging and Packaging Waste Regulation is currently being reviewed by the European Parliament and the European Council.

However, the current version of the Packaging and Packaging Waste proposal places too much emphasis on reusable packaging, at the expense of other environmentally-friendly options like single-use paper packaging. This could have negative consequences for the environment, consumers, food safety, and businesses in Europe, as demonstrated in several robust science-based studies. To achieve its circular economy goals, the PPWR should be revised to prioritise the use of renewable, recyclable and environmentally performant  single-use paper packaging.

Recycling Mission Statement

How the PPWR will impact:



The PPWR sets unrealistically high targets for reusable packaging. This will lead to an increase in the amount of challenging to recycle plastic packaging, requiring the use of more scarce resources and damaging the environment.

Reusable packaging also generates more emissions through the washing and returning of packaging, resulting in an increase in the release of CO2 and freshwater use.

A study commissioned by EPPA, and conducted by the independent and reputable Danish Environmental consultancy, Ramboll, found that single-use paper-based packaging generates 2.8 times less CO2 emissions and uses 3.4 times less fresh water in quick-service restaurants for in-store consumption.

For takeaway, a recent LCA confirms that paper-based packaging is more environmentally efficient than its reusable plastic alternatives in all 12 impact categories considered.



The current draft of the PPWR will completely change the consumer experience for citizens across Europe.

Recent studies show that consumers would need to ensure that reusable packaging is not damaged or compromised in any way so that its robustness and food safety is not jeopardised.

Additionally, the current average €4 cost for a meal will almost certainly increase due to the increased costs of the reuse systems being passed onto the consumer.

Finally, reusable systems will be a significantly more burdensome manner of purchasing products for consumers as they will have to bring the tableware with them and return it after its use. The result of the PPWR for consumers would be an experience that is both slower and more expensive.


Food Safety

The PPWR does not take into account food safety, which is one of the most essential requirements of packaging.

The impact assessment for the PPWR neither evaluated the impact of mandatory reuse targets on food safety nor how multiple-use packaging increases the risks of cross-contamination between humans, packaging and food.

In contrast, single-use paper-based packaging prevents the spread of food-borne illnesses by stopping any external cross-contamination that may occur within the circular reuse system. Indeed, in a study commissioned by the paper packaging industry, Professor David McDowell, Emeritus Professor of Food Studies at the Ulster University, highlighted that multiple-use packaging increases the risks of cross-contamination between humans, packaging and food due to multi-location cleaning, sanitation, storage and transport.


European Businesses

The PPWR will create very burdensome requirements for businesses across the EU, while paper-based packaging is a full European value-chain that contributes to the EU strategic autonomy. This will have the most visible impact on small businesses and family-run enterprises.

Disproportionately impacting family-owned businesses and small coffee shops, many of these businesses will need to pay for industrial scale washing infrastructure and invest in costly reusable packaging up front. According to the National Syndicate for Food and Quick-Service Restauration (SNARR), the costs of the measure will be around €100,000 per restaurant. This will make businesses unfeasible to run and create barriers for new entrants.

Mandating the use of reusable packaging is bound to stifle innovation in the paper packaging industry. By focusing solely on reusables, there is a risk of overlooking the potential for developing sustainable, eco-friendly alternatives in paper packaging, which could further revolutionise waste management and recycling.

Moreover, the shift towards reusable packaging will create a market influx of low-priced plastic imports from outside the EU, undermining domestic efforts to curb plastic pollution and create a circular economy. It is crucial to consider the broader implications of such policies and support innovation across all sectors.