The European Commission published a much-needed proposal for a new Packaging and Packaging Waste Regulation (PPWR) on 30 November 2022, amending the existing Packaging Directive. The Commission’s proposal is open for public consultation until March, at which time it will be scrutinised by the European Parliament and the Council. Commercial interests have already begun reshaping its focus and weakening targets. But with billions of trees cut down annually for packaging, wouldn’t we all rather keep them to save our climate?
The proposal intends to tackle the plague of packaging, instantly disposed of, to which we are all exposed daily: fast food containers, bulk-use packaging, plastic film on dry-cleaned laundry….
Packaging waste is responsible for some 36 per cent of municipal solid waste in the EU. Online shopping and eating on the go means that packaging is rising dramatically, chewing up 50 per cent of all paper used in the EU, and 40 per cent of plastic. At the same time, design features that render packaging unrecyclable are rising significantly.
Confronting the packaging problem effectively would liberate municipal resources, and benefit consumers and the environment. The Commission’s initiative is therefore welcome.
The draft Regulation introduces several important innovations.
It establishes waste prevention targets, including obligations to reduce excessive packaging; it also introduces targets for a proportion of packaging to be reusable or refillable. Manufacturers would have an obligation to comply, including making sure that a functioning system exists to make re-use/refill possible. These welcome innovations reflect the Waste Hierarchy in the 2008 Waste Framework Directive, which calls on Member States to prioritise waste prevention and re-use over recycling, recovery (i.e., burning for energy), and finally disposal.
These targets were watered down by lobbyists even before the draft’s publication. For instance, an early leaked draft required 75 per cent of takeaway food packaging to be reusable by 2040, 20 per cent by 2030; for e-commerce packaging, 80 per cent, 20 per cent by 2030. The packaging industry fiercely resisted, calling for more focus on recycling instead. In the published draft, the re-usable food packaging target is slashed to just 40 per cent by 2040; re-usable e-commerce packaging, to 50 per cent by 2040.
Some business-to-business transport packaging targets were slightly more ambitious, but were also scaled back: even if the 2040 re-use targets are achieved, more than half of the target packaging will still be single-use. It is difficult to see how the Regulation can promote the kind of systemic transformation required to tackle overreliance on single-use packaging, when its targets seem to aspire to maintaining re-use systems as a minority approach only.
The proposal requires that all packaging be recyclable, as opposed to reusable. As ‘solutions’ go, this is misleading: The consumer is then responsible for recycling, yet sometimes ‘recyclability’ that is theoretically possible is, in practice, as easy as finding a unicorn.
By far the most ambitious recycling target in the proposal regards paper; 85 per cent of paper and cardboard packaging waste is to be recycled by 2030, 75 per cent by 2025.
Industry voices had called for this increased focus on recycling, rather than re-use. Many have even argued for widespread adoption of paper-based products to solve the single-use plastics problem, highlighting paper’s supposed recyclability. But, as the Commission’s own impact assessment points out, most paper recycling downgrades paper quality and functionality, meaning that recycled paper is virtually unused for products like drinks cartons; even corrugated cardboard in packing boxes relies on some long-fibre virgin pulp for structural integrity. Growth in use of disposable paper packaging means growth in demand for virgin paper.
Canopy estimate that roughly three billion trees are cut down every year to meet global demand for paper packaging. The pulp and paper industry is one of the world’s biggest polluters, and greatest users of fresh water – even without considering the vast amounts of energy, and chemicals it uses.
Effective recycling systems are an important part of mitigating the problems that runaway packaging waste causes, but can never substitute for reducing the amount of packaging waste we produce in the first place.
For now, all eyes are on the rapporteur for this file in the Environment Committee of the European Parliament, Frederique Ries (Renew), and the shadow rapporteurs, Grace O'Sullivan (Greens) and Delara Burkhardt (S&D).
Our message to them: the paper industry has a highly damaging impact on the climate and biodiversity. The revised packaging regulation should refocus on the top of the waste hierarchy and avoid false solutions downstream that could end up intensifying the pressure on the world’s remaining forests.