In this issue, we talk to Alain D’haese, Secretary General of the FEA - Fédération Européenne des Aérosols - about the Packaging and Packaging Waste Regulation PPWR, which came into effect in February. Through his work for the association, Mr. D’Haese is an acknowledged expert on packaging and is at the source in Brussels when it comes to information in the sector. Mr. D’Haese shares his knowledge with the industry in many presentations - most recently at Paris Packaging Week in January.
PetPack Journal: Can you briefly explain what the PPWR is and what its main objectives are?
Alain D’haese: The PPWR aims to improve packaging sustainability and reduce packaging waste across the EU. Its main objectives are:
PetPack Journal: What are the biggest changes that packaging companies should expect as a result of the PPWR?
Alain D’haese: It depends on the type of packaging and the packaging material. The minimum required recycled content in plastic packaging is a major change for plastic packaging companies. The challenge will be to secure enough recycled material of sufficient quality to serve the entire industry.
PetPack Journal: What financial challenges will packaging manufacturers face as a result of the new requirements?
Alain D’haese: In fact, the PPWR will create financial challenges for various stakeholders along the packaging value chain:
Companies will need to invest in meeting the new regulatory requirements, including redesigning packaging to meet recyclability and reusability targets. This will involve significant costs for research, development and testing of new materials.
Brands will be required to participate in Extended Producer Responsibility (EPR) schemes, which may include different financial contributions depending on the EU Member State.
The shift to sustainable and bio-based materials is likely to increase sourcing costs. Finding high quality recycled materials that meet PPWR standards can be challenging and expensive.
EPR fees will be adjusted based on the environmental footprint of packaging materials. Brands that use non-recyclable or environmentally harmful materials will face higher costs.
Compliance with the PPWR will require robust tracking and reporting systems that can be costly to implement and maintain. Companies will need to provide detailed data on the type, quantity and recyclability of their packaging.
Failure to meet PPWR requirements can result in penalties and increased fees. This creates a financial risk for companies that do not adapt quickly enough.
Collection, sorting, and recycling technologies and infrastructure should be further developed across the EU to meet common minimum quality requirements.
PetPack Journal: How does the impact of the PPWR differ for companies within the EU and for companies importing into the EU?
Alain D’haese: The Regulation applies to packaging placed on the EU single market. This means that packaging manufacturers and importers follow the same rules. What the regulation makes crystal clear is that the importer’s name and contact details must be identified. The EU Declaration of Conformity and technical documentation must be made available to market surveillance authorities on request.
PetPack Journal: The PPWR strongly promotes recycling and the circular economy. Are the current infrastructures sufficient for this?
Alain D’haese: Collection, sorting and recycling technologies and infrastructure should be further developed across the EU to provide sufficient quantities of good quality recycled materials. Some EU Member States are more advanced than others. The remaining efforts depend on the EU Member State.
PetPack Journal: What innovations or adjustments will companies need to make to remain compliant?
Alain D’haese: The recyclability of packaging is under discussion. The European Committee for Standardization (CEN) is working on a series of standards and technical specifications to establish recyclability criteria for the different packaging materials and formats. The methodology for calculating the “performance grade” of packaging will be defined by the European Commission. Companies and trade associations have already identified certain challenges, but the devil is likely to be in the details. Predictability is key to avoiding no-regret investments, but no one knows all the challenges for sure.
PetPack Journal: Many in the industry criticize the PPWR as being too ambitious or impractical. What criticism do you think is justified?
Alain D’haese: The regulation was adopted in a hurry before the European elections. This is never ideal for producing a good quality legislative text. The Regulation is complex and open to interpretation, but the practical details will only emerge through delegated and implementing acts. Transitional periods should be two years, which may be too short if unexpected challenges arise. Is PPWR too ambitious or impractical? I do not know yet, but I am contributing within CEN to make it workable.
PetPack Journal: Large corporations have more resources to implement new regulations. What about smaller packaging companies?
Alain D’haese: EC President von der Leyen announced that future legislation must be simplified and designed with small businesses in mind and in the spirit of subsidiarity. This will be done through a new “SME and competitiveness check” to help avoid unnecessary administrative burdens while maintaining high standards. Let’s see if this will already apply to delegated and implementing acts to be adopted.
PetPack Journal: Is there a risk that the PPWR will unnecessarily increase the administrative burden on companies?
Alain D’haese: Compliance costs will increase and technical documentation will become more complex and detailed. The answer will probably be different if you ask the question to a NGO, authorities or industry.
PetPack Journal: Do you think the PPWR could serve as a model for other regions, or is it more likely to create barriers to trade?
Alain D’haese: Recycling is already a hot topic in many parts of the world. Is the PPWR the right model? It is likely that non-EU countries will try a simplified version that is less burdensome for both authorities and industry. However, the core remains the Extended Producer Responsibility (EPR) system, which will be implemented in more and more countries where it does not already exist.
PetPack Journal: Do you think there could be any changes or relaxations to the PPWR before it comes fully into force?
Alain D’haese: The full reuse obligation for pallet wrap and strapping has already been identified as a major problem in terms of transport efficiency and safety, economic consequences including supply chain disruptions, and undesirable environmental impacts, among others. A delegated act to exempt these packaging formats is being addressed as a “priority”, with the results of a study to substantiate the exemption requirements expected in the first half of this year and legally binding exemptions in the second half. In addition, if future delegated and implementing acts are not published on time, the transition period will remain the same.
PetPack Journal: What initial steps should packaging companies take now to prepare for the PPWR?
Alain D’haese: Packaging companies have already taken the first steps. It is also important to maintain close contact with their customers (packaging users) to understand their problems and develop solutions that meet their needs.
PetPack Journal: Dear Alain, thank you for this comprehensive introduction to the topic!
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