EU Proposal for a Regulation on Packaging and Packaging Waste Nearing Adoption - The Highlights and Challenges Ahead
The European Commission (EC) proposal for a Packaging and Packaging Waste Regulation (PPWR), issued on 30 November 2022, is now nearing finalization and is scheduled to be adopted before the end of 2024. It will enter into force 20 days after publication in the Official Journal of the European Union (OJEU) and will apply 18 months after entry into force (EIF), although longer transitional provisions apply to certain requirements. The PPWR will repeal and replace the current Packaging and Packaging Waste Directive 94/62/EEC (PPWD).
Key points:
- Food packaging will be prohibited from being placed on the EU market if it contains per- and polyfluorinated alkyl substances (PFAS) above certain limits.
- The PPWR, as proposed, will require that all packaging be recyclable – there are conditions and timescale listed.
- Recycled content: The PPWR proposes to increase the recycled content of plastic packaging and there are mandatory targets.
- Packaging Minimisation: Packaging not necessary to satisfy certain performance criteria and packaging only intended to increase the perceived volume of the packaging will be banned unless subject to geographical indications of origins protected under EU law.
- Single use packaging will be banned in certain product groups.
- Re-use and Re-fill targets
- Declaration of conformity & Technical documents: These should be kept for10 years after the reusable packaging is placed on the market.
- Compostable: Some items will have to be compostable – tea & coffee bags, lightweight carrier bags, some single serve units
- Environmental Labelling: The PPWR will introduce labelling requirements for the packaging, per se, for consumer articles. This could include the following:
Labels with information on the material composition on the packaging to facilitate consumer sorting
Labels on packaging reusability and a QR code/other digital data carrier providing information on re-use and collection points
QR labels or similar technologies to identify SoCs present in packaging material, along with concentrations.
Clearly, the PPWR, with its ambiguous targets and the tight timeframes for compliance, notably with respect to recyclability and recycled content, will pose challenges for industry.