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[Originally published in Euractiv]

Time is fast running out to get the EU’s Packaging and Packaging Waste Regulation (PPWR) over the line in the final term of the current administration. The last ‘trilogue’ negotiation is scheduled for next week on March 4th, and food packaging might be front and centre of the debate.

By Matti Rantanen, Director General of the European Paper Packaging Alliance (EPPA).

According to the latest study from the Joint Research Centre (JRC), scientific findings suggest there is no more justification for bans and reuse targets. This also mirrors the European Parliament’s final report, where MEPs eliminated mandatory reuse targets for paper-based food and beverage packaging for take-away (Article 26) and supported amendments to Article 22 and Annex V.

The Commission’s original proposal was blunt in recommending that single-use food packaging, even when it was made from renewable, recyclable paper-based products, should be phased out in favour of reusable alternatives, despite these were made from hard plastic that is extremely resource-intensive to manufacture and clean, and for which recycling proves challenging, confirmed by low recycling rates across Europe.

After receiving many protests from players all along the supply chain as well as MEPs who urged the Commission to take into account the full life cycle of such products when evaluating their environmental impact, the Commission asked the JRC to do its own analysis.

Science for society

According to its website, the JRC “provides independent, evidence-based science and knowledge, supporting EU policies to positively impact society.” Doing so, in this case, was clearly challenging as it was a relatively last-minute request on a very technical topic. Only last week was the JRC able to publish its findings in a report titled Exploring the environmental performance of alternative food packaging products in the European Union.

While the report is far from perfect, both the abstract and conclusion reveals a stark truth:

This finding turns on its head the assumptions at the heart of the European Commission’s original proposal and confirms that if plastic replaces paper, mandatory reuse targets and sweeping bans on single-use paper packaging in the HORECA sector would do more harm than good to the environment.

Dispelling the reusable myth

The JRC analysed the environmental performance of single-use and reusable packaging, including paper-based options, across various scenarios, such as take-away and dine-in settings.

For take-away packaging, the JRC  found that single-use paper packaging had a lower impact on climate change than reusable packaging, regardless of whether outdated 2011 data on paperboard production, or more recent and accurate data provided by industry, was used.  The JRC also found that single-use paper packaging had a better impact on water use and an overall better environmental impact when more recent and accurate data on carton manufacturing are used (This data is included in the JRC sensitivity analysis in the “Alt. 2” scenario  – figure 1 in the report).

For dine-in HORECA packaging, the JRC shows that even with outdated data, single-use paper packaging has a lower climate impact than reusable options as soon as a 70%  recycling rate is achieved. Using the latest data on cartonboard manufacturing (“Alt. 2” scenario), even a 50% recycling rate is sufficient to make single-use packaging better in terms of climate impact than reusable packaging in dine-in.

Ensuring nuance

The JRC is to be commended for engaging with a wide range of stakeholders, including from the paper-based packaging value chain, in order to seek relevant data and expertise. Producers and associations shared up to date, robust and representative primary data, along with clarifications and input from leading experts. Despite significant political pressure, the JRC integrated this material into its sensitivity analysis. A closer examination of this analysis validates the conclusions of existing independently peer-reviewed and ISO-compliant life cycle analyses, such as the studies carried out by Ramboll and commissioned by EPPA that were shared widely with decision-makers across Europe.

The way forward

While the JRC report errs in some places by depending on outdated data, overall it has fulfilled its function of providing independent analysis to support policies that positively impact society. Once again, it has proven that positive impact can only be achieved through rigorous analysis and that it is crucial that science, not ideology, must drive decision-making on environmental files.

Rather than rigid directives, policymakers should adopt rigorous flexibility, permitting technical neutrality, but also exemptions for packaging materials achieving high recycling rates, or demonstrating superior environmental performance through scientific life-cycle analysis.

Moving beyond ideological constraints towards pragmatic, evidence-based solutions is imperative for progress.