Last 30 November 2022, the European Commission published its long-awaited proposal for the revision of the Packaging and Packaging Waste Directive (EC/2018/852).
The legal instrument of this review will be a Regulation, meaning that it will be automatically binding in all Member States upon its publication in the Official Journal. This Packaging and Packaging Waste Regulation (PPWR) will now be examined by the European Parliament and the Council who will have plenty to discuss, judging by industry reactions to date.
At APEAL, we welcome the general approach and support the introduction of a set of so-called ‘recyclability performance grades’ based on design for recycling criteria and linked to eco-modulation of Extended Producer Responsibility (EPR) fees. According to this approach, to be defined in secondary legislation, packaging would be awarded a grade ranging from A to E, whereby the A-grade is the best-performer and E the worst. When labelled as E, the packaging format would have to be phased out within a certain time limit. The best performers benefit from advantageous EPR fees.
However, we would have preferred more ambition when it comes to recyclability of packaging materials, in order to achieve the Commission’s objective that all packaging on the EU market be reusable or recyclable in an economically viable way by 2030, as stipulated by the Green Deal and the Circular Economy Action Plan (CEAP) 2.0.
Packaging should not only be designed for recycling by 2030, but also be effectively and efficiently recycled at scale by that date. Recycled at scale means collected, sorted and recycled through installed state-of-the-art infrastructure and processes. Furthermore, minimum recyclability criteria should be introduced for all packaging put on the market, ensuring a level-playing field.
It is APEAL’s firm belief that not all recycling contributes to the same extent to the circular economy and that permanent materials such as steel, that can be recycled over and over again, should be rewarded over those that cannot be recycled or only be recycled a limited number of times.