Packaging protects home appliances in the factory warehouses and during shipping, ensuring that the product is in good working order when it arrives at retail shops or at consumers homes, with a view of further ensuring their safety during use. The most obvious side-effect of improper packaging is product damage, which could in turn harm consumers. With this in mind, the industry has been long committed to reducing the growing amount of packaging waste, by investing in the use of sustainable materials. In this sense, the new draft packaging law can represent a real milestone in the process of moving towards a sustainable packaging supply chain in Europe, however further environmental and cost analysis is needed to square the circle of reuse targets.Reusable transport packaging is not always the most environmentally-friendly solution. In the proposed regulation, the reuse target for large appliances is currently set at 90%. While reusable transport packaging “might appear to be more circular at first glance,” said APPLiA Environment Policy Officer Franziska Decker, “it is not always the most environmentally-friendly solution” due to an increased amount of greenhouse gas emissions associated with the manufacturing of a returnable fleet. The packaging of a washing machine shipped from Germany to Spain for instance, would need to make its way back to Germany generating emissions and additional costs to restore the packaging for reuse. Also, transport packaging may include different components such as pallets, plastic straps, boxes and wrappings for some of which reuse is technically very difficult, or even impossible. In absence of a large-scale system in Member States and in-depth impact assessment, it is difficult to evaluate the environmental benefits of reuse. Under this argument, the 2030 and 2040 targets for the food and beverage industry have been removed from the Rapporteur draft report already. Similarly, reuse targets for packaging in home appliances shall be based on “thorough analyses that take into account the full lifecycle of packaging, including transport.” Proposed goals for packaging reuse, recycled content, minimisation, and restrictions on packaging formats should build on available feasibility studies, real-world circumstances, logistical considerations, potential effects on consumer health and safety, as well as goals for reducing food waste and safety standards.There is no one size fits all. Household products come in a variety of shapes and sizes even within the same product group and brand, as well as with a collection of spare components. All of which must be considered while designing the packaging. If we take the case of fridges for instance, these might have different door handles mounted in different places or even recessed handles which determine the design of the box. The packaging must secure the product in a way for it not to move during transport and avoid any entry of humidity - a condition that can only hold true if the packaging matches all characteristics of the appliance. In order for this to work, a “complex closed-loop system would need to be implemented by each individual manufacturer to ensure that the packaging of each model of each product is returned for reuse,” explained Decker.
Transport packaging VS sales packaging. Most often products are sold in the same packaging as in which they were transported. Manufacturers package the product for transportation to retailers, who then deliver the product in the same packaging to consumers. Looking at the logistics, “drawing a line between the concepts becomes difficult for our industry, as these normally coincide,” she continued. Which calls for the need of more clarity on the definition of what constitutes transport packaging.
Toward EU-wide requirements for packaging. With national packaging initiatives on the rise, emphasis must also be placed on the need for harmonisation to avoid the introduction of additional requirements at Member State level. Today, manufacturers of consumer products, which are present across different European markets, are facing a high number of national divergences when it comes to their packaging. “Any flexibility risks making room for varying obligations that could create confusion and hinder the smooth operation of the Single Market,” said Decker, highlighting the need for the PPWR 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 its success.
The European Parliament and European countries are currently reviewing the proposed legislation ahead of negotiations on the final law. The European Parliament’s environment (ENVI) committee just released its draft report today and is set to vote in September 2023.