PACKAGING AND PACKAGING WASTE REGULATION (PPWR) proposal COM(2022)0677 – Position paper of steel for packaging sector

#21.02.2023 PACKAGING AND PACKAGING WASTE REGULATION (PPWR) proposal COM(2022)0677 – Position paper of steel for packaging sector

Executive Summary

APEAL, representing the steel for packaging sector, fully supports 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. Our sector welcomes the general approach taken by the Commission but believes that more is to be done to fully close the circular loop. Therefore, our sector has prepared a set of recommendations and amendments to improve the draft Packaging and Packaging Waste Regulation.

1. Criteria for recyclable packaging:
The current Commission proposal is a step in the right direction. However, to fully close the circular loop the steel for packaging sector recommends:
a) Stricter qualitative criteria to label packaging as ‘recyclable’.
b) The introduction of packaging recyclability performance classes or ‘grades’ for each packaging unit put on the market is timely and necessary. Non-recyclable packaging should be gradually phased out. Best performers should be rewarded via eco-modulation of EPR fees and by a higher recyclability performance grade.
c) Packaging should be ‘recycled at scale’ by 2030 covering at least 90% of the Union’s population and applied in 2/3rd of the Member States

2. Recycled content:
The steel for packaging sector supports the current Commission proposal that recycled content targets should only apply to materials with a low demand and uptake of recyclates.

3. Prevention of packaging waste:
Waste reduction targets should be set for each of the specific materials contained in packaging waste: plastic, wood, ferrous metals, aluminium and paper/cardboard.

4. Transport packaging:
Steel pails, drums, canisters and kegs are sales packaging and not transport packaging. Consequently, they should not be subject to the re-use targets set for transport packaging.

5. Legal instrument and legal base:
APEAL supports the choice for a Regulation and a full ‘internal market legal base’ for the Packaging and Packaging Waste Regulation (article 114 TFEU).

6. Phase out landfilling of packaging waste:
The steel for packaging sector believes that the review of the PPWR should be complemented by a review of the Landfill Directive 99/31/EC, aiming at accelerating the phase-out of landfill of packaging waste.