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UPDATED: Packaging waste regulation leaked before publication

A leaked Commission document on EU’s new packaging and packaging waste regulation has caused uproar and uncertainty in the food and packaging industry. Industry is concerned that the new approach proposed in the leaked document could lead to the waste of billions of euros of investments and years of innovation in the recycling sector. Moreover, the leaked document proposes the introduction of mandatory recycled content targets for plastics, new eco-design criteria, as well as a renewed push to put in place deposit return schemes for used items.

New reuse targets, considered unfeasible by most of the industry, include:

· 30% of cold and hot beverages by 2030 and 95% by 2040

· 20% of takeaway ready-prepared food by 2030 and 75% by 2040

· 20% of alcoholic beverages (excluding wine and spirits) by 2030 and 75% by 2040

· 20% of non-alcoholic beverages by 2030 and 75% by 2040

· 90% of large household appliance deliveries by 2030

Stakeholder have expressed diverging views on the content of the leaked document.

According to a substantial part of the industry, reuse and recycle are to be addressed together as useful tools to achieve the same goal. Consequently, one should not to be regulated at the expense of the other. Currently, the proposal focuses on reusable packaging to the detriment of recycling schemes, rather than taking a holistic approach combining both. Other industry representatives stated that reuse and refill necessarily imply additional logistics and transport that may produce more CO2 emissions. On the contrary, single-use items can be more easily discarded and recycled.

Some stakeholders support a reuse-balanced policy and consider that over 15 years is sufficient to achieve the transition. These stakeholders argue that Europe has never excelled in recycling and action should therefore be taken to improve the situation. For these reasons, environmental groups support the European Commission’s view, and advocate to apply the refill or reuse model also in other sectors. For instance, many dry products like rice, nuts, seeds and cereals, could easily be sold with such model, but the option is currently not covered by any legislation.

The proposal is set to be officially presented by the European Commission on 30 November.

UPDATE 30-11-2022

On 30 November, the Commission officially published the proposal. The leaked document is consistent with the published proposal but the latter offered new details including the plan to:

  • Reduce packaging waste by 15% by 2040 per member state per capita, compared to 2018.

  • Improve recyclability of packaging, by contributing to the increase of the overall packaging recycling rate from 66.5% in 2018 to 73% in 2030 (landfill is decreased from 18.7% to 9.6%).

  • Establish an obligation regarding the recycling of beverages, as, by 2030, 20% and by 2040 80% of cold and hot beverages will have to be filled into a container that is part of a reuse system or enable consumers to come with their container for a refill.

  • Establish an obligation regarding the recycling of takeaway prepared meals from restaurants. The targets of recyclability would be 10% in 2030 and 40% in 2040.

  • Establish an obligation regarding the recycling of e-commerce packaging. 10% of e-commerce packaging for transport will have to be reusable by 2030 and 50% of it by 2040.

The next steps involve the European Parliament and the Council which under the ordinary legislative procedure will have to consider the proposal.


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