Unpacking the Packaging and Packaging Waste Regulation (PPWR)

Alena Maran, Director Strategy & Sustainability for Avery Dennison's Labels and Packaging Materials division, looks at the emerging challenges facing the packaging industry and the desired outcomes as the much-discussed Packaging and Packaging Waste Regulation (PPWR) gains momentum.

We are all inspired and stand by the EU’s Green Deal pledge to become climate neutral by 2050 and build a circular economy within Europe. A key instrument for achieving these goals is the Packaging and Packaging Waste Regulation (PPWR), which aims to prevent packaging waste and increase collection and recycling output.

We believe that it’s our role - both as companies and as citizens - to do everything in our power to help achieve these goals and drive positive environmental change. The packaging industry is of course a major part of the puzzle and needs to do its part, especially in the areas of greenhouse gas emission reduction and decoupling growth from the use of virgin materials.

However, when I joined a Packaging Europe panel discussion about the PPWR, it became clear that more needs to be done before manufacturers, recyclers, and legislators find the right balance between the need to achieve ambitious legislative goals and the need to support innovation to drive circularity.

Unpacking the Packaging and Packaging Waste Regulation (PPWR)

PPWR on paper vs. in practice

The PPWR outlines requirements for brands, other value chain players, and governments. Brands must ensure that all packaging is recyclable, all plastic packaging contains recycled content, and certain end segments introduce reusable packaging. Meanwhile governments are responsible for creating deposit return schemes and introducing extended producer responsibility schemes in their regions to improve the output and quality of recycling streams.

While on paper all these ideas are needed, and all have been developed with the greater good in mind, there are some concerning weak spots in how this regulation is being discussed and executed in practice.

Avoid solutions that hinder progress

When ironing out the details of the PPWR, we need to incentivize innovation and avoid prescriptive solutions that can actually hinder progress.

For example, the PPWR should not only create strict requirements for the recyclability of packaging. We, packaging producers, can design products that are perfectly recyclable and/or made with recycled materials, but if there is no infrastructure in place to efficiently collect, sort, and recycle packaging, then we will not have access to the affordable, high quality recyclates needed to keep making circular packaging.

The Commission should therefore also incentivize sorting and recycling facilities to invest in state-of-the-art technologies. This will ensure that the recycled materials they produce are competitive in quality and price versus imported recycled materials or virgin materials and available in sufficient quantities.

In the same way, the Design For Recycling Guidelines should also have an innovation-driven approach. Currently, many existing design-for-recycling guidelines are focused on banning certain packaging characteristics without considering the functionality and end-of-life of the product.

For example, we don’t see a clear distinction in the guidelines for recycling PET bottles vs. PET trays, or for food-contact vs. non-food-contact HDPE materials. In reality, both the recycling processes and the performance requirements for these materials are different, and the guidelines should reflect these differences.

Guidelines based on science, not assumptions

The view that packaging is at fault for many environmental concerns is increasingly widely held. In some cases, this view is justified, for instance in the case of marine plastic pollution or incineration.

However, let us not forget that packaging also plays an essential role in our daily lives. For one thing, it is necessary to protect and prolong the lifespan and safety of products. In addition, packaging is a fundamental communication tool whereby consumers are informed about the contents of products and how they are to be safely used and disposed of.

This is where EcoDesign comes in. If we use the principles of EcoDesign to create packaging that uses less materials and enables reuse or recycling, we will be able to produce packaging that both fulfills its essential role in society AND contributes to achieving net zero.

To ensure that packaging conforms to EcoDesign principles, all guidelines must be developed using science-based testing protocols. These protocols in turn must be developed in consultation with experts in the packaging ecosystem to ensure that the protocol is actually in line with the desired environmental outcome.

The role of labels in circular packaging

Finally, I would like to take a look at the role of Pressure Sensitive Labels (PSL), which Avery Dennison produces. We believe that PSL can contribute significantly to the success of the PPWR, by educating and raising awareness among consumers and enabling (and inspiring) them to play an active role in packaging circularity.

For example, one change introduced by the PPWR is the harmonization of consumer sorting instructions, and PSLs are perfect for enabling this communication. PSL can also enable packaging recycling or reuse. For example, multicycle labels are an ideal solution for brands that want to wash packaging and place it back on the market.

Looking ahead

The world we live in and the environmental problems we face are deeply complex. While we are all striving to contribute to the solution and make a positive impact to the environment, there is no single future-proof packaging format, nor is there one clear path forward.

To make progress as quickly as possible, packaging producers, brands, recyclers, associations, and legislators need to work together to develop both effective legislation and the variety of new and innovative circular packaging solutions we will need to achieve our shared climate goals.

Learn more

If you have questions or comments related to the Packaging and Packaging Waste Regulation or the impact it will have on you, please feel free to contact Alena Maran.

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