How to ensure the PPWR actually enables more sustainable packaging

As the Packaging and Packaging Waste Regulation (PPWR)’s plenary voting date quickly approaches, The Alliance for Beverage Cartons and the Environment (ACE) takes a look at this draft piece of legislation with a critical question and asks, “what do we want our packaging to be like in the future?”

What is the PPWR and Why is it Important? 

Anybody working in EU policy is acutely aware of the draft PPWR legislation, which aims to ensure that the packaging we use every day is sustainable and circular. This piece of legislation will drive change in how products are packed and delivered throughout the EU. 

Beverage cartons are an essential, sustainable, packaging solution and a familiar household product used daily by millions of Europeans, to provide safe and nutritious milk and juice.

Keep sustainable products sustainable

To support continued innovation and sustainability leadership we need a legislative framework which supports:

1)  An open-loop approach to high-quality recycling
A high-quality recycling definition should be linked to the quality of secondary raw materials. What does this mean?  

Secondary raw materials are the “recycled materials that can be used in manufacturing processes instead of or alongside virgin raw materials.” Our view is that secondary raw materials need to find their way into new products with the least environmental and economic impact. 

For instance, beverage cartons consumed and collected in Spain are currently recycled in Spain into corrugated boxes. This is what we call an open-loop approach, meaning that recycled material is used to create a broad range of products. However, some proposed amendments in the PPWR could impose a closed-loop recycling approach, meaning a recycled product needs to be used to create the same product from which they derive. This would mean, for example, that beverage cartons collected in Spain would need to be sent to Germany or Sweden to be recycled and used in new beverage cartons. This solution would be economically unsustainable and technically challenging. Also, it would lead to increased transport operations which would result in higher emissions, environmental impact and make it difficult to satisfy food safety requirements. 

A network of effective beverage carton recycling systems is already in place throughout Europe. Our proposal for an open-loop approach would promote circular systems, and avoid unnecessary circularity disruptions. 

2) A transparent, technical and evidence-based approach for Design for Recycling (DfR) Guidelines 

For those who may not be aware, beyond the PPWR context, Design for Recycling Guidelines aim to ensure that products are designed to be recycled and do not become “waste”. Guidelines are often based on third party, technical expertise.  

It is therefore essential to avoid that the PPWR is overly prescriptive and, as suggested by some stakeholders, contains a list of packaging attributes that supposedly preclude recyclability. The PPWR should promote Design for Recycling Guidelines based on sound technical knowledge. A prime example of this are the beverage carton industry’s Design for Recycling Guidelines, which provide producers of beverage cartons with technical guidance to identify the materials needed in the packaging composition that are compatible with existing recycling processes and how the recyclability of beverage cartons can be optimized. 

Any arbitrary list of attributes that could hinder recyclability could also contradict key Treaty principles including proportionality, the obligation to avoid errors of assessment, and could create an unfair advantage for one material over another (e.g. plastic over paper).

Sometimes a picture …. 

3) No reuse targets for microbiological sensitive products 

What is a microbiological sensitive product? It’s your daily juice and milk which are not allowed to have additives or preservatives and are more sensitive compared to soft drinks and water. Because of this, it is critical to use packaging like beverage cartons, which provide a crucial and effective barrier against the entry of microorganisms, light and oxygen and allow for an extended shelf-life, potentially avoiding food waste.

Putting a lens on the European juice industry, 59% of their products are packed in beverage cartons. Why? Beverage cartons protect, transport and preserve juices, contributing to lower carbon emissions and a longer shelf life. The only technically feasible reusable packaging for fruit juices is glass. That means, if mandatory reuse targets are set for the fruit juice industry, the only alternative is heavy returnable glass bottles. These have a higher environmental footprint, and come with other challenges: they are heavier, bulky to transport, easily breakable, hard to clean after first use and could fail to meet hygiene requirements.

So, why choose a  glass bottle when the European Commission’s Impact Assessment accompanying the PPWR proposal calculates that switching from heavy packaging such as glass towards lighter alternatives would lead to a significant reduction in GHG emissions and water use? While reuse systems do exist, they’re not always the best solution for all packaging formats and only possible under certain conditions and at a small scale, which is not meaningful across the EU.

Let’s safeguard our juices and milk and not have them be in the scope of mandatory reuse targets. 

…Is worth a 1,000 words 

Looking to the future, not the past

Depending on the direction taken by EU Parliament discussions, the PPWR runs the risk of promoting fossil-fuel driven alternatives with a negative impact on the environment in the European market and negating sustainable paper packaging solutions, like beverage cartons. 

So, let’s call on our policymakers to adopt meaningful decisions by looking at the bigger picture. 

We’ve provided the evidence needed to ensure they vote for measures that protect sustainable packaging. Now let’s look forward to continued innovation for sustainable solutions, decreasing fossil fuel emissions and have the EU’s reputation shine as a truly green leader.