Rethinking Packaging: The Impact of the New Packaging and Packaging Waste Directive (PPWD)

Most products require packaging at various stages of their lifecycle. Today, the range of packaging materials and items is vast. Between 2009 and 2020, the total amount of packaging waste generated in the EU increased by 20%. The European Packaging Directive ( 94/62/EC) has established for almost 30 years measures to prevent the production of packaging waste and to promote the reuse, recycling, and other recovery methods for packaging waste. It also sets requirements for all packaging placed on the EU market to meet. These regulations aim to reduce packaging waste disposal and promote a more circular economy.

As part of the European Green Deal and the new Circular Economy Action Plan, the European Commission proposed a revision of this directive in November 2022. The goal of this initiative is to ensure that all packaging is reusable or recyclable in an economically feasible manner by 2030. The revision aims to strengthen the essential requirements for packaging to ensure its reuse and recycling, increase the use of recycled content, and improve the enforceability of these requirements within its member states. Additionally, measures are planned to address over-packaging, reduce packaging waste and encourage the use of lower-impact packaging materials to reduce the environmental impact of packaging waste.

On 4 March 2024, the Parliament and the Council reached a provisional agreement on the new regulation ​“Packaging and Packaging Waste Directive (PPWD)”. This agreement still requires formal approval by both institutions (expected before June 2024) so that the final new directive might come into force at the end of 2024 – beginning of 2025.

Packaging waste is a significant environmental concern, as it contributes to pollution, resource depletion, and climate change. By implementing the Packaging and Packaging Waste Directive, the EU aims to minimise the negative impact of packaging waste on the environment and promote a circular economy. The directive encourages the adoption of more sustainable packaging practices, such as using recyclable and biodegradable materials, reducing packaging waste generation, and increasing recycling rates.

In this article, we will explore the history, current status, scope, and requirements of the directive, as well as the opportunities it presents for businesses. We will also discuss how COSH!, an online platform promoting sustainable fashion retailers, can help businesses fulfill the requirements of the Packaging and Packaging Waste Directive.

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Evolution of the Packaging and Packaging Waste Directive

A brief history of the Packaging and Packaging Waste Directive

The EU Packaging Directive was first introduced in 1994 in response to the growing concern over packaging waste and its environmental consequences. Over the years, the directive has undergone several revisions and updates to align with changing environmental priorities and advancements in waste management technologies. The latest amendments are driven by the European Green Deal and the Circular Economy Action Plan, which aim to make more sustainable products the norm in the EU, boost circular business models, and empower consumers for the green transition. 

The revised directive includes stricter targets for recycling and reuse, mandates for reducing the use of single-use plastics, and new obligations for producers to design packaging that is easier to recycle. It also introduces measures to reduce the overall quantity of packaging waste generated, emphasising the importance of waste prevention.

The main objective of the directive is to reduce packaging waste in the EU by at least 15% by 2040 compared to 2018 and the recycled content of plastic packaging should be about 65% by 2040.

Changes and updates in the directive over the years

One of the key updates to the Packaging and Packaging Waste Directive was the introduction of recycling targets for member states. Under the revised directive, each member state is required to achieve specific recycling rates for packaging waste materials, such as paper, plastics, metals, and glass. The recycling targets have progressively increased over the years, reflecting the EU’s commitment to enhancing recycling practices and reducing the reliance on virgin materials.

Current Status of the Packaging and Packaging Waste Directive

Overview of the current regulations

The Packaging and Packaging Waste Directive is currently in force across the EU member states. It sets out the legal framework for packaging waste management and establishes the responsibilities of businesses involved in the production, distribution, and disposal of packaging materials. The directive requires businesses to comply with specific obligations, such as waste prevention, reuse, recycling, and reporting.

Compliance requirements for businesses

Businesses that fall under the scope of the Packaging and Packaging Waste Directive must meet various compliance requirements. These include:

Registering with the relevant national packaging waste authority: Businesses must register with the designated authority in their respective countries to fulfill their legal obligations and provide information about the packaging materials they place on the market.

Meeting recycling targets: Member states have set recycling targets for different packaging waste materials. Businesses are required to contribute to achieving these targets by implementing recycling initiatives, collaborating with waste management organisations, and promoting the use of recyclable packaging materials.

Reporting on packaging waste management: Businesses must collect and report data on the packaging materials they place on the market, their recycling rates, and their efforts to prevent packaging waste generation. This data helps monitor progress towards the directive’s objectives and enables policymakers to make informed decisions.

As each member state is obliged to establish an appropriate system incl. harmonised database for waste disposal there is a big chance that the entire process will become more easier than complicated.

The Extended Producer Responsibility (EPR) is a key component of the Packaging and Packaging Waste Directive (PPWD). The PPWD aims to reduce the environmental impact of packaging by implementing measures that promote the prevention, reuse, recycling, and recovery of packaging waste. EPR is integral to achieving the goals by making producers responsible for the entire lifecycle of their products, including the post-consumer phase. By promoting more sustainable packaging design, increasing recycling rates, and internalising environmental costs, EPR helps to achieve the directive’s goals of reducing packaging waste and advancing the circular economy. For fashion retailers, understanding and implementing EPR principles is crucial to compliance with the PPWD and contributing to broader sustainability objectives:

1. Producer Responsibility:
   • EPR shifts the responsibility of waste management from municipalities and taxpayers to the producers of packaging materials. This includes manufacturers, importers, and retailers.
   • Producers are accountable for financing the collection, sorting, recycling, and disposal of packaging waste, ensuring that it is managed in an environmentally friendly manner.
2. Lifecycle Management:
   • The PPWD mandates that producers design packaging with its entire lifecycle in mind. This includes considerations for material selection, durability, reparability, and end-of-life disposal.
   • EPR policies encourage producers to create packaging that is easier to recycle and to invest in the development of more sustainable materials and packaging solutions.
3. Recycling and Recovery Targets:
   • The directive sets specific recycling and recovery targets for different types of packaging materials. EPR schemes help achieve these targets by incentivising producers to improve the recyclability of their packaging and increase the use of recycled content.
   • By meeting these targets, producers contribute to the circular economy, reducing the need for virgin materials and minimising waste.
4. Cost Internalisation:
   • EPR ensures that the environmental costs of packaging are internalised in the product price, rather than being externalised to society. This creates an economic incentive for producers to minimise packaging waste and choose more sustainable options.
   • Producers who implement lower-impact packaging solutions can reduce their EPR-related costs, benefiting both the environment and their bottom line.
5. Collaboration and Innovation:
   • EPR encourages collaboration between producers, waste management companies, and other stakeholders to develop innovative packaging solutions and improve recycling processes.
   • This collaborative approach fosters the sharing of best practices and the development of new technologies that enhance the sustainability of packaging.
6. Compliance and Enforcement: 
   • The PPWD includes compliance mechanisms to ensure that producers adhere to EPR requirements. Non-compliance can result in penalties and increased regulatory scrutiny.
   • Producers are required to report on their packaging use and waste management practices, providing transparency and accountability

The already existing EPR schemes in France and the Netherlands might be a helpful blueprint to develop a system which is workable for all EU member states.

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Scope and Requirements of the Packaging and Packaging Waste Directive

Who does the Packaging and Packaging Waste Directive apply to?

The Packaging and Packaging Waste Directive applies to businesses involved in the production, distribution, and disposal of packaging materials within the EU member states. This includes packaging manufacturers, importers, retailers, and E‑commerce businesses. The directive also covers packaging waste management organisations responsible for collecting, sorting, and recycling packaging waste.

The directive sets out specific requirements for:

• Recyclability: Packaging must be designed to facilitate recycling, with clear labelling to inform consumers about disposal.
• Reuse: Encouraging the development and use of reusable packaging solutions.
• Reduction:Reducing the volume and weight of packaging materials used without compromising product safety and hygiene.
• Producer Responsibility: Producers are held responsible for the entire lifecycle of their packaging, from design to end-of-life management.

Key requirements for lower-impact packaging

The Packaging and Packaging Waste Directive encourages businesses to adopt lower-impact packaging practices. But in this concern retailers need a comprehensive view of their packaging footprint. The baseline analysis should cover raw material usage, environmental impact, costs, and formats.

Some of the key requirements for lower-impact packaging include:

Use of recyclable materials: Businesses are encouraged to use packaging materials that are easily recyclable, such as paper, cardboard, glass, and certain types of plastics. 

Reduction of packaging waste: Businesses should strive to minimise the amount of packaging waste generated by using efficient packaging designs, right-sizing packaging, and avoiding unnecessary packaging materials.

Promotion of reusable packaging: Businesses can explore opportunities to use reusable packaging solutions, such as refillable containers or packaging systems that can be returned to the manufacturer for reuse.

Adoption of biodegradable and compostable packaging: When suitable, businesses should consider using packaging materials that are biodegradable or compostable, ensuring that they meet the relevant standards and certifications.

Build New Internal Capabilities: Businesses shall invest in talent and capabilities to handle technical complexities of packaging and recycling. It might be helpful to train store employees on collecting recycled packaging and investing in relevant infrastructure. To ensure collected feedstock is properly processed it will be an important step to develop a reverse logistic.

Labelling: it will be necessary to inform the consumer about the packaging material. Those information can be provided with the Digital Product Passport (DPP)

Opportunities and Benefits of Complying with the Directive

Advantages of using lower-impact packaging

Complying with the Packaging and Packaging Waste Directive and adopting lower-impact packaging practices offer several advantages for businesses, including:

Enhanced brand reputation: By demonstrating a commitment to sustainability and environmental responsibility, businesses can enhance their brand reputation and appeal to environmentally conscious consumers.

Cost savings: Lower-impact packaging solutions often result in cost savings in the long run. For example, using lightweight packaging materials can reduce transportation costs, while using recycled materials can be more cost-effective than virgin materials.

Access to new markets: Increasingly, consumers are seeking out products packaged in an environmentally friendly manner. By using lower-impact packaging, businesses can tap into new markets and attract a broader customer base.

Business opportunities in sustainable packaging solutions

The Packaging and Packaging Waste Directive presents various business opportunities in the field of sustainable packaging solutions. Businesses can explore:

Innovation in packaging materials: Developing and using innovative packaging materials, such as bioplastics or plant-based alternatives, can meet the growing demand for lower-impact packaging solutions.

Collaboration with packaging waste management organisations: Partnering with waste management organisations can create opportunities for businesses to optimise packaging waste collection, sorting, and recycling processes.

Consumer education and engagement: Businesses can play a vital role in educating consumers about the importance of sustainable packaging and encouraging responsible disposal practices.

How COSH! Supports Compliance with the Packaging and Packaging Waste Directive

Services offered by COSH! to help businesses meet the directive’s requirements

COSH! offers the following services to assist businesses in complying with the Packaging and Packaging Waste Directive:

Packaging waste management guidance: COSH! provides guidance on best practices for packaging waste prevention, reuse, recycling, and recovery. This includes recommendations on lower-impact packaging materials, waste reduction strategies, and recycling initiatives.

Supply Chain Analysis: Our team can help analyse and optimise your supply chain to ensure that it aligns with the directive’s goals, identifying opportunities for reducing waste and improving efficiency.

Supplier network: COSH! connects businesses with a network of suppliers offering lower-impact packaging solutions. This enables businesses to find packaging materials that meet the requirements of the directive and align with their sustainability goals.

Consumer Education: We offer strategies to educate your customers about the importance of lower-impact packaging and how they can participate in recycling and reuse initiatives.

Book a meeting and learn more about the PPWD for your company.

Conclusion

The Packaging and Packaging Waste Directive plays a crucial role in promoting eco-friendly packaging practices and reducing the environmental impact of packaging waste. By complying with the directive’s requirements, businesses can not only contribute to a more sustainable future but also benefit from enhanced brand reputation, cost savings, and access to new markets. COSH! supports businesses in the fashion industry by providing guidance, supplier connections, and real-life examples of successful implementation. Embracing more sustainable packaging practices is not only a legal obligation but also an opportunity for businesses to make a positive impact on the environment and their bottom line.