Packaging and packaging waste regulation

Shining a spotlight on the Packaging and Packaging Waste Regulation

 

 

As the Packaging and Packaging Waste Regulation (PPWR) gains momentum, there’s a clear divide between those who are ready and those who aren’t. The latter are often smaller organizations that don’t have the scale, resources, and/or internal expertise to navigate what is fast becoming one of our industry’s most complex challenges.

As a key part of this value chain, we want to share our in-house expertise to give clarity to those who need it. Here we’ve gathered the key takeaways from our recent podcast with Packaging Europe, featuring Emilie Bartolini, our Government Affairs Lead for Europe, and Alena Maran, our Director for Strategy and Sustainability in Label and Packaging Materials for Europe.

 

Q1: You're both relatively new in your current roles. What was it like to take responsibility for regulatory affairs and sustainability, just as everything went into flux?

Alena: When I joined Avery Dennison’s sustainability team, my number one priority was to map out the upcoming regulatory changes. I wanted to pinpoint how regulation and sustainability commitments impact brands and packaging companies.

Shortly after I met Emilie, we locked ourselves in a meeting room, set up a whiteboard, and tried to develop scenarios around how we saw the future potentially changing, and whether that change was going to be accelerated or whether we would see more gradual transitions. 

We place sustainability at the core of everything we do, so the question we were supposed to answer was: how do we prioritize and how do we create clarity in this sustainability maze?

Emilie: The fact that we were at the beginning of a long process to establish our government affairs function added a layer of complexity. We knew we wanted to engage with the Brussels audience, but we needed to identify the key external partners we should work with to achieve our government affairs goals. At the same time, I was tasked with working internally, primarily with Alena's team, to define our priorities.

In the midst of all of that, PPWR hit like a tsunami, accelerating the process. So there we were, locked in a room trying to figure out how to prepare the company for the uncertain road ahead.

Q2. What have you've learned so far about the implications of PPWR for the value chain and what do all players need to consider when planning their approach?

Alena: Step one is to understand how PPWR impacts your product portfolio. It doesn't matter where in the value chain you play, whether you're a packaging producer or whether you’re producing a packaging element, like labels.

There are a lot of moving parts in the regulatory process but the underlying objective is clear: packaging must be recyclable, and it must use fewer virgin materials. So, with those two objectives in mind, we need to ensure that every element can support packaging recycling, uses recycled content, and can support new business models, such as reuse.

 

Packaging and packaging waste regulation

 

Reuse is interesting - and still up for discussion - as the regulation may come with variable targets dependent on packaging types. In some countries, it’s already a well-oiled machine, but in others, and for certain packaging formats, it's unclear how to establish and build the required infrastructure. 

At Avery Dennison, we are piloting and partnering with various players to find a workable solution. For example, with Circolution, who recently rolled out a pilot for Nesquik packaging, we provided a wash-off label that enables reuse. Through such cooperation, we can test as many scenarios as possible (embracing failure as part of the process), so that when PPWR comes into play, we already know what works and what doesn’t.

Q3. What are the key milestones that we should be watching out for?

Emilie: Typically EU legislation takes between two and three years to be negotiated. PPWR sits on the faster end of the spectrum, since both institutional and industry players have an incentive to ratify it before the legislative mandate of the European Commission ends and ahead of the European election in June 2024. 

The European Parliament and the Council have started reaching agreements on how they will respectively adopt what the Commission has proposed. Many elements have already been agreed upon internally, which puts them in a good position to negotiate a mandate at the start of 2024. We expect to see an agreement in the first three months of 2024.

Q4. One of the key concerns of the value chain is whether PPWR will deliver the intended harmonization or lead to more fragmentation. Is that a concern for you?

Emilie: Absolutely. The Commission’s decision to go for a regulation over a directive was intended to ensure more harmonization. Previous directives neglected to deliver on all goals because they created a lot of regulatory fragmentation across member states.

At Avery Dennison we look at Europe as one market, so we support regulation that will bring harmony across the continent. However, there is still pressure to allow some flexibility, which is concerning as it’s important for economic operators to work on a level playing field. Also, the time and money it takes to comply with different regulations is perhaps better used for innovation, research, and development.

 

 Packaging and packaging waste regulation

 

Alena: An example of the current lack of harmonization is the requirement for labels to wash off of plastic packaging. Washing conditions vary across regions; for example France, Germany, and Scandinavia each want specific temperatures and specific additives in the water. While we can deliver solutions, it doesn’t make sense for us to spend all our resources innovating to develop a product that's applicable to every single variation across these markets.

Q5. How is Avery Dennison reacting to PPWR, in terms of future-proofing the business and supporting your partners?

Alena: As a leader in sustainability, we want to partner with brands, regardless of their size and position in the value chain, to share our knowledge and help them make the right choices.

Labels are a critical element in determining the sustainability of packaging, but we don't expect brands to figure out if every element of their packaging will comply in each market. Our labeling experts have done the critical thinking and are ready to offer products that will help satisfy the requirements of PPWR, including carbon reduction and enabling packaging recycling and reuse.

Emilie: We are very much in the middle of the supply chain, with proximity to suppliers and converters. We are trying to use our position to educate as many partners as possible, including end-of-life operators such as recyclers and sorters. This kind of collaboration is imperative to ensure that we implement solutions that will lead everyone to compliance. 

 

Packaging and packaging waste regulation

 

Q6. It's clear that PPWR presents a significant challenge. Do you see it as an opportunity as well?

Alena: As a major player in the packaging industry, we fully support the PPWR and have a clear role to play in reducing emissions and creating circular packaging. It’s also a great opportunity for us to showcase our capabilities.

Emilie: It’s definitely an opportunity. Everyone agrees that we need to reduce packaging waste and its footprint, and we need to do this by developing innovative solutions. Everyone in our ecosystem is affected and on board, there are just some disagreements on the route. It all comes down to working together to find an approach that gets us to the final destination.

 

Learn more

For more information and insights, you can listen to the entire Packaging Europe podcast below.