The EU Packaging and Packaging Waste Regulation (PPWR): How glass can support the EU’s circular economy ambition

In November 2022, the European Commission proposed an overhaul of the EU’s packaging waste rules, and the EU circular economy has been near the top of the policy agenda in Brussels ever since. Now, policymakers in the European Parliament and the European Council are debating the Packaging and Packaging Waste Regulation proposal (PPWR, for short), which could be adopted as soon as February 2024.

With the PPWR, policymakers hope to make up for some of the shortcomings of the Packaging and Packaging Waste Directive (PPWD) – with more ambitious circularity demands for packaging and a move from directive to regulation meaning Member States will have to meet the same EU-wide obligations at the same time.

To contribute to the EU’s growth strategy for a modern, resource-efficient, clean and competitive economy, the revised PPWR has two core objectives:

• Prevent packaging waste and promote recycling and reuse.
• Ensure that all packaging placed on the EU market is recyclable in an economically viable manner by 2030.

These new rules will shake up the whole EU economy. But how will they impact the glass packaging industry? What are the potential opportunities and challenges that could lie ahead? We share our perspective below.

In line with its objective to reduce packaging, the Commission’s PPWR proposal puts forward EU-wide packaging waste reduction targets requiring each Member State is required to reduce their packaging waste per capita by 5 % by 2030, 10 % by 2035, and 15 % by 2040, using figures from 2018 as a baseline. The targets are the same across all Member States, regardless of packaging material.

The thinking behind these waste reduction targets is straightforward. The goal is to reduce the amount of packaging waste the EU generates, packaging waste is measured in tonnes, therefore Member States need to reduce the tonnes of packaging waste they generate. This logic adds up on paper, but it’s flawed in the way it focuses on just one aspect of packaging waste: weight.

There’s more to a packaging material than its weight. What about a packaging’s recyclability, or its food safety credentials?  A packaging material can be lighter than the rest, but it’s not able to support the EU’s circular economy if it can’t be safely and easily integrated into new production loops through reuse and recycling.

By focusing only on weight, the proposal lays the groundwork for unintended consequences. The current measures will provide incentives for companies to switch from heavier, but circular materials, like glass, to lighter materials that are more difficult to recycle. Rather than reducing the environmental impact of packaging, this could have extensive negative consequences on the environment, and create market distortions that will disrupt the EU economy.

The European Commission’s PPWR Impact Assessment details what the potential market distortion could look like in practice. The Commission’s projects that, rather than reducing all packaging waste evenly, the EU will be substituting one form of packaging waste for another.  The data (shown in the graph below) suggest that while would most materials reduce the tonnes of packaging waste they produce, plastic would see a 17.41% increase in waste generation.

Wasn’t the goal to reduce packaging waste?

Continuing with the proposal’s focus on weight, the PPWR looks to introduces packaging minimisation requirements. In other words, the proposal mandates that packaging that should be as light as possible while remaining safe and functional.

This measure stands to create a new wave of packaging standardisation. The current proposal does not consider product presentation as a functionality of packaging. As a result, design choices that add any weight to packaging – unique shapes, patterns, embossing – will not comply.

This move to design standardisation has far-reaching implications for brands, consumers, and packaging manufacturers, as packaging is closely connected to the product itself. Colours, shapes, and textures are often key to helping products stand out on shelves and shape a brand’s identity, building consumer loyalty. Indeed, primary packaging is a fundamental factor in product enhancement and consumer choice, according to research from the University of Parma. Why give the rest of the world a competitive advantage against European brands?

One of the key objectives of the PPWR is to make sure that all packaging put on the EU market is reusable or recyclable. And glass couldn’t be better equipped to meet the moment.

No matter how many times it is recycled, glass will always retain its inherent properties, including inertness and impermeability. Thanks to these properties, glass is a permanent material, representing the gold standard of high-quality, closed loop recycling. Indeed, European brands have been known to position glass’s recycling credential as a brand asset.

With its PPWR proposal, the European Commission has taken a significant step towards ensuring that only packaging that is recyclable can be placed on the EU market:

• All packaging placed on the EU market should be recyclable by design by 2030.
• Harmonised criteria for ‘recyclable packaging’ should be introduced, to ensure that packaging is sufficiently and effectively collected, sorted and recycled in practice and at scale.
• All packaging would be graded with A – E recyclability performance grades (with packaging falling under grade E phased out as of 2030), which would form a basis for eco-modulation of Extended Producer Responsibility (EPR) fees (i.e. fees charged to producers would be modified based on the recyclability of their products).

We strongly support this ambition on recyclability. But can the proposal do more to take advantage of glass’s closed-loop recyclability? We say yes.