“The PPWR signifies a great opportunity to minimize waste and resources used for packaging while increasing its circularity both through actual recycling and increased use of recycled plastics” says Jakob Mosser, Chair of Flexible Packaging Europe.
Opting for a Regulation as legislative instrument will set the base for homogeneous rules for all economic operators in the Single Market. However, it remains concerning that Member States are granted freedom to adopt divergent national measures. More than 50% of food in the EU is packaged in flexible packaging, meaning that the well-functioning flow and supply of such food relies on clear, coherent, and consistent EU legislation.
All packaging will have to be recyclable by design by 2030 and recycled at scale by 2035. For flexible packaging, this represents a challenging opportunity that the industry is ready to take. Thanks to the improved timelines compared to the Commission proposal, industry has better legal clarity to work toward making all flexible packaging recyclable by design.
The targeted 55% recycling rate for ‘Films/flexible’ (and for other materials and categories) is now set as a market access condition as of 2035. Industry is ready to be ambitious by making sure all flexible packaging will be designed for recycling by 2030 and by paying its fair share of Extended Producer Responsibility (EPR) fees, but Member States require the same ambitions in order to allow industry to meet the 55% target by setting appropriate infrastructures for collections and recycling of such packaging.
Packaging designed for recycling will have to be collected, while the incineration and landfilling of such packaging shall be prohibited. This is a much needed waste management requirement, as the industry can recycle only if packaging is appropriately collected. However, that’s not enough as Member States are still able to postpone recycling targets and set up Producer Responsibility Organisations (PROs) with no producer mandate which will allow re-route EPR funds to the general revenue and for general expenditure and not for investing in collection and recycling.
Actual recycling will also enable industry to comply with the recycled content targets for plastics in packaging. Such targets are welcomed as they enlarge the market of secondary raw materials and unlock the potential of advanced recycling technologies, in particular for contact sensitive applications.
Reducing the use of resources is one of the goals behind much-awaited mandatory packaging minimization requirements. The flexible packaging industry is fully committed to sustainable use of resources having made resource efficiency our core principle thanks to our very low packaging-to-product ratio: 5 to 10 times lower than alternative solutions. Shifting towards lighter packaging is also an important measure of packaging waste prevention, as demonstrated by a study by IFEU. This scenario analysis shows that switching to flexible packaging would help reducing by 21 million tonnes per year the total weight of primary packaging used for non-beverage FMCGs in Europe, with an overall reduction of 44%. All this with recyclability in mind.
Jakob Mosser comments the way ahead: “The flexible packaging industry is now looking forward to the next steps in the approval process. After the publication of the PPWR, the important phase of secondary legislation will start, and the industry urges a timely approval of detailed rules on all sustainability requirements. FPE and its members look forward to continuing to share our expertise with policy makers and support them in achieving an ambitious and enforceable packaging legislation supporting a resource efficient society.”