Packaging and Packaging Waste Regulation

Policy Engagement Overview

The aggregated evidence of corporate and industry lobbying on the review of the Packaging and Packaging Waste Directive shows intense, negative engagement from consumer products sector industry associations, the chemical industry and the packaging sector. Actors across EU industry supported some waste management and recycling measures.

Long-term Lobbying Trends

Cross-sector industry associations opposed the revision of the PPWR, including the Confederation of Italian Industries (Confindustria), the French Business Federation (Medef), the Federation of German Industries (BDI), and BusinessEurope.

The chemical, packaging and consumer goods sector seemed to prioritize recycling over measures to reduce or reuse packaging, including Cefic, Henkel, Tetra Pak and Coca-Cola. Waste management measures such as Extended Producer Responsibility (EPR) and Deposit Return Schemes (DRS) were strongly supported by companies Coca-Cola, Amazon and Henkel.

The consumer goods, chemical and packaging industries opposed specific measures on waste generation reduction. L'Oréal, FoodDrinkEurope, LyondellBasell Industries, Sappi, the Confederation of European Paper Industries (CEPI) and Amazon opposed waste reduction targets.

Reuse measures were opposed by the chemical, packaging and consumer goods sectors, including industry associations PlasticsEurope, CEPI, and EuroCommerce and companies Amazon, Stora Enso and DuPont. However, Unilever and Nestlé supported reuse and refill measures alongside ambitious proposals to scale up recycling.

The chemical and consumer goods sector advocated that recycled content targets take a flexible mass balance approach to recycled content, where companies could implement recycled content as an average percentage across production rather than a mandated percentage of recycled content per product. This included companies Eastman Chemical, BASF, Nestlé, PepsiCo, Unilever, and industry associations PlasticsEurope, FoodDrinkEurope and Cefic.

The non-plastic packaging industry opposed recycled content targets such as Stora Enso and CEPI.

Measures to reduce unnecessary packaging were broadly not supported by the packaging and consumer goods sectors, including Stora Enso, Amazon, FoodDrinkEurope, and PepsiCo.

The chemical sector did not support increasing the recyclability of plastic packaging by reducing the complexity of polymers and regulating specific materials and substances. This included PlasticsEurope, BASF, Henkel and CEFIC.

New engagement trends since the EU Commission’s 2022 Proposal

The consumer goods and paper packaging sectors increased active opposition to reuse measures. Associations CEPI, BusinessEurope, FoodDrinkEurope, Confindustria and companies Coca Cola, Sappi, Tetra Pak and McDonald's advocated for exemptions from reuse targets and disputed the environmental impacts of reuse over single-use packaging.

Impacts on Policy Ambition

EU Commission Proposal

• Waste prevention targets: The Commission proposed a target for Member States to reduce packaging waste by 5% per capita by 2030, by 10% per capita by 2035, and by 15% per capita by 2040, compared to 2018, which corresponds to the middle ambition option considered in the impact assessment of the policy. The leaked draft’s ambition was maintained despite opposition from cross-sector industry associations.

• Unnecessary packaging minimization: The proposal set a phase out of unnecessary packaging by 2030, as well as a threshold for empty space in packaging in selected sectors, including e-commerce. However, a ban by 2030 of heaviest packaging for selected items was not included.

• Reusable packaging and re-fill targets: The EU Commission proposed targets for re-fill and reusable packaging for consumer goods, including food, beverages and large household appliances, which were weakened after intense engagement from packaging manufacturers and the consumer goods sector following the leak of a draft proposal.

• Recyclable packaging and recycled content targets: The Commission proposed that all packaging must be recyclable, with all packaging to be designed for recycling by 2030, and to be recycled at scale by 2035. However, 2030 targets for recycled content for plastic packaging were weakened. A bid by the chemical sector to include a mass-balance approach to recycled content in the regulation itself was unsuccessful, but an implementing act expected to be published by 2026 will establish methodologies for calculating recycled content.

• Recyclability of packaging materials: Provisions regarding packaging complexity and a ban on substances of concern which inhibit recyclability were not included in the Commission’s proposal, echoing industry calls for these measures to be left out of the revised regulation.

EU Parliament Position

The EU Parliament’s position on the PPWR significantly weakened key elements of the EU Commission’s proposal.

• Unnecessary packaging minimization: The Parliament position introduced new exemptions which would weaken measures to reduce the use of unnecessary packaging formats.

• Recyclability of packaging materials: The proposal introduced a ban on certain substances of concern for health in food packaging while including measures to enhance traceability and transparency regarding the use of all other substances of concern in packaging.

• Reusable packaging and re-fill targets: The Parliament position weakened the reuse targets proposed by the EU Commission, introducing non-binding objectives for 2040 as well as new exemptions to the provisions on prevention and reuse, including for the food and drink take-away sector, in line with advocacy from industry.

EU Council Position

The EU Council’s position retained elements of the EU Commission’s ambition, whilst giving more flexibility to Member States in the implementation of the regulation.

• Waste prevention targets: The Council position introduced the possibility for Member States to set more ambitious targets at national level.

• Recyclability of packaging materials: The position called on the Commission to prepare a report by 2026 on the presence of substances of concern in packaging, to determine whether they negatively affect the re-use or recycling of materials or have an impact on chemical safety.

• Reusable packaging and re-fill targets: The Council proposed new exemptions from reuse and refill targets, including for cardboard, and allowed companies to form ‘pools’ to meet reuse targets on beverages. The Council’s revised position included a review clause requiring the Commission to “assess whether the re-use targets for 2030 have been effective in reaching their goals” — based on life cycle assessments for single-use versus reusable packaging, which leaves the door open for a weakening of the 2040 reuse targets at a later date.

• Unnecessary packaging minimization: The Council position introduced restrictions on the single use packaging, and required companies to minimize the weight and volume of packaging. However, it also proposed new exemptions to banned packaging formats, including for non-plastic packaging for fresh fruit and vegetables.

Policy Progress

EU policymakers reached a provisional agreement on the EU Packaging and Packaging Waste Regulation in March 2024, set to be formally adopted in April 2024. The agreement’s ambition aligned with the Parliament’s position, weakening the reuse targets proposed by the Commission by introducing non-binding objectives for reusable packaging, extending exemptions to the provisions on prevention and reuse, and treating recycling and reuse equally. Before agreeing on the agreement in a final vote, the Council further weakened the rules’ ambition on the calculation of Extended Producer Responsibility costs. The European Commission via delegated acts will adopt specific rules for the calculation and verification of recycled content in packaging.