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With its sights set on achieving a green circular economy as quickly as possible, the European Commission proposed a complex revision of packaging and packaging waste legislation late last year, writes Matti Rantanen, director general of the European Paper Packaging Alliance.

Yet, the underlying assumptions and impact assessment on which the proposal is based leave much to be desired and have been questioned by the Commission’s co-legislators.  During the meeting of the Council of the European Union that took place on 16 March 2023, a number of representatives of the 27 Member States questioned the impact assessment and urged the Commission to publish more scientific impact assessments given the far-reaching consequences of the proposal.

The Packaging and Packaging Waste Regulation (PPWR) proposal is the biggest overhaul to EU packaging rules in decades.  Among the many provisions, the Commission most notably proposes packaging reduction targets for Member States and strict reusable and refill targets for in-store dining and takeaway services. Unfortunately, the impact assessment undertaken to support such measures mixes non-transparent qualitative approaches and quantitative data of completely different packaging sectors impossible to aggregate, while ignoring ISO compliant and certified studies where they exist, especially as regards the restrictions on use of certain packaging formats (Article 22) as well as the re-use and refill targets (Article 26).

The impact assessment disregards large swaths of scientific research on single-use paper packaging and reuse.

The PPWR is a reform that could put some small enterprises across Europe out of business, change entire supply chains, significantly shift the use of scarce resources and radically transform our approach to achieving Europe’s green goals. With such a profound impact, a thorough and comprehensive analysis was needed.

What we got instead was an impact assessment that also did not have a dedicated chapter on food safety, which is an integral and critical function of food packaging. Given that certain types of packaging, such as reusable packaging, have the potential to transfer foodborne diseases and other contaminants, it is a significant gap in our understanding of the advantages and disadvantages of different packaging options.

Furthermore, the impact assessment disregards large swaths of scientific research on single-use paper packaging and reuse. Independent life cycle analyses show that for both for in-store dining and takeaway services, in quick-service restaurant environments, single-use paper packaging is more environmentally performant than reusable packaging. For in-store dining, reusable packaging systems emit 2.8 times more CO2, consume 3.4 times more freshwater and fossil resources and produce 2.2 times more fine particulates than paper-based alternatives. For takeaway services, the results follow the same trend with a 64% increase in freshwater use and a 91% increase in CO2 emissions.

The impact assessment also fails to take into consideration the enormous burden of developing a brand new infrastructure and supply chain for the already difficult to recycle reusable packaging systems. Meanwhile, paper-based packaging is effectively recycled at the highest rate of all packaging materials in Europe – 82%.

In places where reusable packaging has been mandated in quick service restaurants, as is the case in France since January of this year, the results have been underwhelming and have brought to light  disturbing new phenomena: massive return of plastic, low reuse rate and theft of reusable packaging. A number of businesses have revealed that they are unable to even meet 20 to 40 reuses, while the containers are stolen after only a few uses. Impact of the washing and drying system as well as the transport back of reusable packaging have been minimised in the impact assessment: as one example amongst many, the reuse “transportation and washing” CO2 impact represents only 37% of the total GHG emissions (and 27% in 2040) in the impact assessment whereas it accounts for 83% in the third party reviewed Ramboll in-store LCA and 82% in the expert panel reviewed Ramboll takeaway LCA. A major difference leading to unjustified regulation and showing that  simplification and aggregation cannot replace an LCA ISO standard approach.

With all of this in mind, the disconnect between what the science says and what the impact assessment and proposal bring to the table is worrisome to say the least. Everybody will be affected.  Companies will be hurt by the increased costs of doing business which generally tends to be passed on in a large proportion to customers. While we’re in a water and energy crisis, huge amounts of both will be spent on washing plastic containers at very high temperatures. And consumers will face ever increasing prices in a time when the cost of living has been skyrocketing. Because reusable packaging comes with a complex and costly system, there will not be a single winner in this equation.

The proposed text of the PPWR is now in the hands of the European Parliament and the Council, going through a detailed review process. EPPA therefore urges policymakers to ensure that science is at the very heart of the decisions they make moving forward on the matter. This is the only way to ensure that the impact this law has is for the good.