PPWR: what it means for packaging waste
by Ramisa Shahjahan at 12:07 in Packaging, Circular Economy, Environmental

Packaging and Packaging Waste Regulation (PPWR):

To tackle the growing issue of packaging waste, the European Union has introduced the Packaging and Packaging Waste Regulation (PPWR). This Regulation is a European Union initiative that aims to reduce packaging waste, promote recycling, and ensure the sustainability of packaging materials. It builds upon the existing Packaging and Packaging Waste Directive but sets tighter rules to help enable greater environmental impact.

Why is the Regulation needed?

Packaging waste has become a pressing environmental concern, with millions of tonnes ending up in landfills and oceans each year. The overuse of plastics, non-recyclable materials, and excessive packaging contributes to pollution, climate change, and resource depletion.

The EU Green Deal has set ambitious targets for sustainability. The implementation of PPWR can be seen as a part of the efforts to help achieve these. By enforcing stricter rules on packaging materials and waste reduction, the Regulation aims to significantly cut down on unnecessary waste and improve recycling efficiency.

Outline of some of the key requirements of the Regulation:

1) Prohibiting excessive packaging

Excessive packaging presents many environmental problems – it is a major source of greenhouse gas emissions.The Regulation makesclear that by 2030, the manufacturer or importer is expected to ensure that all packaging placed on the market is designed so that its weight and volume is reduced to the minimum necessary to maintain its functionality. Packaging that is not necessary to ensure product protection, hygiene or safety, and any packaging designed solely to increase the perceived volume of a product (e.g. false bottoms and unnecessary layers) will not be allowed on the EU market.

2) Reuse and Refill models

The Regulation introduces reuse targets for some types of packaging, including transport packaging and some grouped and beverage packaging, along with refill requirements for end retailers.

In principle, the idea of 'reuse' packaging simply means the packaging can be used multiple times for the same purpose. However, the Regulation establishes very specific criteria that producers will need to adhere to for their packaging to be considered 'reusable'.

'Refill' centres on the idea that consumers can bring their own container or use one provided by the retailer to fill with products repeatedly. The Regulation again provides very strict obligations for producers wishing to use this. For instance, economic operators are expected to ensure that the end user is clearly informed that the packaging item is refillable, as well as making sure hygiene standards are rigorously met.

3) Improving Packaging Design

The Regulation sets several design requirements to improve recyclability and promote sustainability. This includes:

• Tighter limits on substances used in packaging (including PFAS restrictions on food contact packaging)
• Mandated compostability for certain packaging types such as tea/coffee bags
• Requirement for all packaging on the market to be recyclable
• PCR threshold requirements for plastic packaging starting from 2030

All packaging (unless exempt) will need to undergo a recyclability performance assessment, where they will be subject to a performance grade of A, B or C. Anything that isn't grade C or above will be banned from being placed on the market.

Exemptions for the requirement of recyclability include certain medical devices, infant formula and packaging used for the transportation of dangerous goods.

4) Banning certain packaging formats.

The regulation also bans a number of packaging formats from being placed on the market from 1 January 2030. This includes single serve portion packs and sachets used for sauces.

5) Reinforcing Extended Producer Responsibility (EPR)

The Regulation maintains that producers are accountable for the entire lifecycle of their packaging. Therefore, they are responsible in financing waste collection, sorting, and recycling processes. If the producer is established in a different EU Member State, they must appoint an Authorised Representative, and countries will have the option to make an AR mandatory for non-EU producers as well.

6) Harmonised Labelling

As part of ensuring consistency, the Regulation stipulates that all packaging on the market will need to be marked with a harmonised label that contains information regarding the material type of the packaging. The labels will be used to help guide consumers on how to properly dispose of packaging for recycling. This obligation does not apply to transport packaging or packaging that is subject to a deposit return scheme.

How will this impact Businesses and Consumers?

For Businesses:

• Companies will be required to redesign their packaging to comply with the new standards.
  
• Conformity assessments - producers will be responsible in proving that their packaging meets the PPWR's requirements
• There may be initial cost increases in transitioning to sustainable packaging materials.
• Failure to comply could lead to fines and penalties.

• Can expect to see less plastic waste and more sustainable packaging.
• Reusable and refillable packaging options will become more widespread.
• Better recycling infrastructure should lead to more effective waste management.

Challenges and Opportunities:

Transitioning to the new packaging requirements will likely result in increased costs for the producer. Complying with the conformity assessments will also be challenging, as producers will be required to provide evidence that their packaging meets the PPWR standards. Additionally, encouraging consumers to adopt the reusable/refillable model may pose challenges.

However, in the long term, these changes will significantly help in the development of a circular economy and create opportunities to explore sustainable packaging materials and designs.

Verdict:

The Packaging and Packaging Waste Regulation is a crucial step towards reducing waste and promoting sustainable packaging practices. By enforcing recyclability, reducing excessive packaging, and eliminating harmful substances, the regulation supports a cleaner environment and a more circular economy. The Regulation will be implemented in phases. In the meantime, it is important for businesses and consumers to begin familiarising themselves with it.

Please note, this is a high-level overview of the Regulation and should not be relied upon to capture all the nuances of the PPWR. If you would like additional guidance on how it will directly affect you – then please get in touch with us today.

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