Europe’s proposed Packaging and Packaging Waste Regulation lays down measures to prevent the production of packaging waste and to promote a more circular economy. More specifically, the initiative’s objective is to ensure that all packaging is reusable or recyclable in an economically feasible way by 2030.
Under the Commission’s proposal, 90% of packaging used for large household appliances must be “made available in reusable transport packaging” by 2030 when they are placed on the EU market for the first time. The mandate is contained in Article 26.1 of the draft regulation, which lays down reuse targets for packaging used in the transport of “large household appliances” such as refrigerators, washing machines, tumble dryers, electric fans or air conditioners.
For the majority of sectors, packaging has one purpose: protect the product from physical damage. "When buying an appliance, we only see the final stage when it finally lands at our doorstep,” said APPLiA Director General Paolo Falcioni, “but all that comes before then, the storage and the transport, is what truly determines the condition of our new purchase when we take it out of the box.” Manufacturers run extensive testing on product packaging not only to safeguard the integrity of the appliance, but also to ensure it is sustainable, recyclable, and minimally wasteful. A positive trend that the new proposal risks to reverse in favour of increased emissions, use of resources and over-packaging and which must be tested against real-life circumstances.
If targets are to be set, a thorough environmental and economic impact assessment is required. Targets are too prescriptive as to where investments need to be made and do not guarantee a positive environmental outcome. Counsellor to the Permanent Representation of Italy to the EU, Tiberio Schmidlin, outlined the need “to identify and preserve all good practices already in place,” whether that is reusable or single-use packaging.
The introduction of reusability models would represent a system change for the producer, retailer and consumer requiring the development of new reverse logistics, product designs, investments in new production steps or even complete lines. Which is why the proposal “can only be effective if it is sustainable from a practical and economic point of view,” outlined European Commission’s Dr Wolfgang Trunk.
This prerogative was echoed also by other critical sectors including the food and drink industry and the furniture industry. The integration of more reusable options on the European market needs to be done properly, not underestimating the significant costs and changes in manufacturing, logistics, distribution and retail that the transition to more reuse will imply.
“The creation of a returnable packaging fleet would require the manufacturing, maintenance, and transport of a large number of empty containers, which is not only costly but also environmentally taxing. Even more, if the reusable packaging target will apply to all international shipments or only to intra-EU ones,” clarified APPLiA’s Falcioni.
More widely, industry representatives found common agreement on the importance of harmonising packaging rules in the EU, to guarantee the smooth circulation of goods in the internal market. With national packaging initiatives on the rise, manufacturers of consumer products are faced with a high number of national divergences forcing them to produce diversified versions of packaging depending on local requirements. On this point, Dr Trunk highlighted the role of the new draft legislation in providing a European response to a global issue, “by introducing a harmonised set of rules across all European Member States to reduce packaging generation.”
Despite all the criticism, the Commission seems confident that the 90% reusable packaging target for white goods can be met. Asked about the cost of the measure, the EU executive referred to a background study that supported the PPWR proposal.
The plenary vote will then follow on 20 November. The new draft legislation has an opportunity to provide a European response to a global issue by promoting a harmonised internal market while recognising the challenges and limitations that must be addressed to ensure and scale its success.