Inside Brussels – Alexis Van Maercke on steel for packaging in EU policy discussions

Brussels is buzzing with the revision of Packaging and Packaging Waste Directive 94/62/EC and a draft proposal is expected this week.

As Europe faces ever-increasing levels of packaging waste – 178 kg in 2021 due mainly to an increase in the use of plastics and paper/carton – the Packaging and Packaging Waste Directive 94/62/EC, and its transition to a Regulation with immediate effect in all Member States of the EU, is an opportunity to clarify recyclability, and stimulate reuse and recycling.  

At APEAL, we fully support the European Commission’s objective to make all packaging put on the market either recyclable or reusable by 2030 and we welcome a new revision that could dramatically alter the packaging landscape as we know it.

Recyclable packaging

A clear definition of recyclable packaging is long overdue, and we believe that although high-quality recycling starts with design, packaging needs also to be really recycled at end of life. Highly recyclable packaging should be advanced (among others through legislation) and rewarded.

APEAL therefore welcomes that the European Commission appears to be considering a set of recycling performance grades, corresponding to the concept that not all recycling is of equal benefit. Depending on its recyclability, 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 performance grades would be linked to so-called eco-modulation of EPR-fees. The system is similar to existing energy labels for household appliances to help consumers choose the most energy-efficient option.

Establishing a ‘recycling hierarchy’ is a position we have long supported as it helps the entire value-chain step further away from a linear economy towards greater circularity and multiple recycling.

Recycled content

For materials such as steel, which are highly recycled and where demand for scrap already exceeds supply, a recycled content target would be neither economically nor environmentally advantageous. With regard to a possible reporting obligation of recycled content in packaging, it is our belief that this should apply only to packaging for which mandatory targets are set to boost the uptake of recyclates.


We support the Commission’s initiatives to promote the usage of reusable packaging. However, we believe that a clear definition of a reusable packaging is a key element in promoting reusable packaging. Only well-functioning schemes, being the ones that are ecological and economical feasible should be promoted. For steel packaging these would be drums, kegs and barrels destined for business use.

APEAL believes packaging waste prevention should essentially target excessive packaging, recyclability and complex packaging.

We look forward to a robust and ambitious legislative proposal that will allow Europe to take a firm step in the direction of a greener and more circular economy.

Read more in our July 2021 position paper here.