On November 30, 2022, the European Commission proposed new rules on how we deal with packaging waste in Europe. 

This is a big deal because packaging volumes are at an all-time high, having grown 20% over the last decade alone, outpacing the economic growth in the EU. 

Packaging waste makes up more than one-third of all municipal waste produced, mainly due to the widespread use of single-use packaging. Although the quantity of packaging waste going to landfill has decreased since the early 2000s, it is still significant - estimated at 20% in 2020 (1). In some instances, packaging waste that would have gone to landfill is now being incinerated instead - estimated at 16% in 2020 (2). 

That makes up 36% of all packaging waste - not recycled.

Despite many industry initiatives and policies on recycling, the EU's packaging waste recycling rate has remained stagnant since 2010, and approximately 17% of all packaging is also designed to be non-recyclable. 

So, new rules are needed because the current ones don't impact reducing the total amount of packaging trash generated in the EU.

Directive to Regulation - What is the difference?

First, the EU is moving from a 'Directive' to a 'Regulation'. 

I know it sounds like bureaucracy, but here's the simple version: 

A 'Directive' is like giving a goal to each country and letting them figure out how to reach it. This leads to different countries doing things differently, adding complexity and costs, especially for cross-border businesses like e-commerce and transit packaging.

So, a 'Regulation' is being proposed, simply a rule that every state in the EU has to follow the same way. It's more straightforward and ensures everyone's on the same page, especially regarding important stuff like who's responsible for the environmental impact of packaging and how products are labelled to show they're eco-friendly.

How is E-commerce and Transit packaging affected by PPWR?

The initial proposal from the Commission, which was leaked, was quite ambitious, especially in the long run. It had a specific goal of achieving 20% reusable packaging in e-commerce by 2030 and aiming for 80% by 2040. This would effectively eliminate all single-use packaging from e-commerce.

This proposal marked a significant change aimed at reducing packaging waste and creating a circular infrastructure for reusable packaging in European e-commerce. It also demonstrated the Commission's commitment to its Green Deal promise and Circular economy commitments.

Within a month of the leaked draft, the e-commerce reuse requirements were reduced to 10% by 2030 and 50% by 2040 in the official proposal after the Commission's first draft stirred up the throwaway lobby.

PPWR has been the most lobbied legislation in European history.

In October, the European Parliament's working group on environment (ENVI) proved the effectiveness of lobbying. In its proposal to the EU Parliament, ENVI suggested the removal of all 2040 targets on reuse from all sectors. While other changes to the PPWR have been documented in other articles, we will focus on the requirements for the transit and e-commerce sectors, which have been retained in the latest version. 

Starting from 2030, 10% of e-commerce deliveries must be made in reusables, while the 2040 target for e-commerce and transit packaging has been completely removed. 

Also, more importantly, cardboard as a material was exempted from reuse targets. What does that mean? Is reusable packaging required from 2030 or not?

Let's look at it in more detail.

An exemption should apply if 

(1.) the banned packaging achieves the best overall result from an environmental point of view and 

(2.) the companies prove that at least 85% of these packaging formats are collected for recycling.

(3) The Member States are obliged to grant exemptions if it is "not technically feasible not to use packaging" or "to obtain access to the infrastructure necessary for the functioning of a reuse system".

To the first argument, cardboard is unlikely to achieve the best overall result from an environmental point of view simply because of its weight and the additional CO2 emissions it creates during transport. This makes it the least environmentally friendly option in the Fashion For Good Life cycle analysis. 

To the second point, currently, 20% of packaging waste is landfilled, and 16% is incinerated. With these figures in mind, reaching recycling rates of 85% is a tall order for cardboard (and possibly paper packaging additions later on).

Third point: functioning reuse systems already exist for e-commerce. We at RePack have it, and legislation will accelerate the development of functioning, cost-efficient and convenient reuse systems all over Europe.

It's important to understand that our current system is designed for single-use packaging. While this works well for the industry, it has negative consequences for our planet and those living here. 

When comparing reusable packaging with cardboard packaging with 89% recycled content, it becomes evident that reusable packaging significantly reduces carbon emissions per cycle by up to 80%. 

What next?

Reuse and recycling must work together for two important reasons. First, reusable packaging will eventually reach its end of life and must be recycled. Secondly, we still have a long way to go before completely replacing single-use packaging. So, single-use packaging will still be around for years to come. 

However, for the good of the European economy and the environment, it's essential to establish a legal framework that provides legal certainty and enables the practice of reuse to begin. Europe, European companies, consumers and operators must do more than just recycling to achieve urgent climate and environmental goals.

[1] Eurostat, Packaging Waste Statistics 

[2] Eurostat, Packaging Waste Statistics

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