EU packaging law: product integrity at risk?

Europe’s new packaging law wants to introduce reusable packaging for several products, including large home appliances like washing machines or ovens. Under the Commission’s proposal, 90% of packaging used for large household appliances will have to be made available in reusable transport packaging by 2030. However, differently from other product categories, the proposed targets for home appliances have not been assessed, with a risk that a less sustainable solution will be implemented and the integrity of the product at delivery, compromised. 

Every year, over 100 million units of large appliances are sold and shipped across Europe. By nature, these are heavy and fragile products. On average, a washing machine ranges between 60 to 90 kg. During transport from the factory to the consumer home, the packaging is exposed to a number of different climatic and mechanical shocks that, if not properly absorbed, could damage the appliance along the way. For this reason, the packaging is designed to match the specific characteristics of each appliance model available on the market. Experts in the factory test the packaging to replicate real-life conditions and select the type and amount of materials needed to secure the product, based on the results of these tests. 

With the introduction of reusable solutions, packaging formats would be standardised to fit as many products and models as possible, disregarding their inherent characteristics. This would not only increase chances of product damage during transport but also come with significant environmental trade offs. When ordering an appliance, private households would need to keep the packaging and return it to the manufacturer who would collect it and transport it back to the factory, where it would be cleaned and restored for reuse. According to a study published by McKinsey, packaging commuting alone would generate +10 to 40% CO2 emissions, as containers may have to travel long distances to be restored by the original company. This goes along with increased energy and water use to enable them for reuse. This makes it very difficult to make an environmental case for reuse, even more in absence of a viable assessment. 

With its vote on 22 November, the European Parliament sent a strong signal recognising the need to conduct an analysis with robust and verifiable scientific evidence, industry-independent, peer-reviewed and publicly available, that may consider the life-cycle perspective, whenever establishing packaging reusability obligations for fragile, heavy large home appliance packaging. On the contrary, Member States have significantly overlooked the case for home appliances and the consequences reusable packaging would bring about for consumers and the environment. 

The final political trilogue on the EU Packaging and Packaging Waste Regulation (PPWR) is foreseen to start next Monday. For Europe to truly benefit from this legislation, re-use should only be introduced where it is environmentally beneficial, while ensuring adequate protection of products. To do so, an assessment should be run to check the sustainability and safety of Europe’s proposed reusable solutions as applied to household appliance products and protective packaging should be exempted from reuse requirements.