PPWR's reusable packaging targets: environmental saviour or plastic resurgence?
The EU's upcoming Packaging and Packaging Waste Regulation (PPWR), scheduled for implementation by 2024, has sparked a heated global debate.
Reusable transport packaging is composed of recyclable materials that can be recovered, refurbished or re-manufactured. Credit: Dr. Victor Wong via Shutterstock
The EU’s ambitious Packaging and Packaging Waste Regulation (PPWR), due to come into force by the end of 2024, has become one of the most debated policy issues in recent memory with expected reverberations across the European continent and beyond.
Jean-Pierre Schweitzer, Deputy Policy Manager for Circular Economy at European Environmental Bureau (EEB), went so far as to describe the law as the “most lobbied on file that many people in the Parliament have witnessed.”
According to investigative outlet DeSmog, members of the food and packaging industry “held over 290 official meetings with Members of European Parliament on the topic between the beginning of 2022 and early April, compared to just 21 equivalent meetings held by NGOs.”
Foodservice heavyweight McDonald's has spearheaded this lobbying, commissioning a report by global management consulting firm Kearney, which claimed that the PPWR’s suggested move to 100% reusable packaging for dine-in by 2030 would significantly increase GHG emissions.
DeSmog also reported that 177 meetings took place between packaging industry representatives and MEPs in the month following the publication of the Kearney study.
The implication is clear: the packaging industry is worried.
The paper industry insists on the adverse ecological ramifications of reuse targets
Various claims have been made about the legislation whose credibility and accuracy is difficult to ascertain. One of the most repeated claims is that the PPWR “sets unrealistically high targets for reusable packaging”, which could produce adverse effects for both the environment and business by “mandating a plastic resurgence.”
For example, British multinational DS Smith, a leading provider of sustainable fibre-based packaging and paper, told Packaging Gateway that, according to analysis commissioned by the European Federation of Corrugated Board Manufacturers (Fefco), mandatory reuse targets applied to all materials “would increase the amount of plastic packaging in circulation and establish a plastic monopoly on some market segments.”
The Kearney report commissioned by McDonald’s and the study commissioned by the European Paper Packaging Alliance brought forth similar criticisms. Both studies set up contentious Lifecycle Analysis (LCA) studies of reusable packaging, based on pessimistic assumptions about low average packaging return rates (70% McDonald’s and 50% EPPA), sub-optimal washing processes and dedicated return journeys.
The conclusion? That the PPWR’s reuse targets in the IEO sector will increase packaging waste and GHG emissions significantly compared to the baseline rate and will impose onerous costs (between €1bn to €20bn, according to Kearney) on businesses.
Packaging’s LCA studies – an improper use of “static assumptions”, says Eunomia
The consultancy Eunomia, however, has roundly criticised this use of LCA studies in a recent report, saying that “static assumptions in reuse studies present challenges, particularly when empirical support is lacking.” The McDonald’s study, they say, has failed to transparently state its methods and data, while the EPPA study is marred by “the creation of a baseline scenario that favours a particular outcome.”
Eunomia says: “Undeniably, the return rate [of packaging] is an exceptionally critical assumption that should not be arbitrarily chosen. Even if there are existing instances of low return rates to draw upon, these may not necessarily represent well-functioning systems, as a poorly designed and implemented reuse system will not outperform single-use alternatives.”
LCA experts have also written an open letter to European policymakers, urging caution when dealing with the results of Environmental Impact Assessments and issuing eight methodology check recommendations. “LCAs are snapshots of products’ environmental impacts,” they say, “Because they are snapshots, their results depend on how they are framed. Small variations in assumptions (rate of return, breakage rate, weight) […] can completely change results and undermine [their] applicability.”
Ioana Popescu, Coordinator of the Rethink Plastic Alliance, told Packaging Gateway: “McDonald’s have [since] acknowledged to the EU Commission that they used incorrect return rate estimations and that they will publish an updated report in January – which is conveniently after the Parliament and Council are expected to have finalised their position on the PPWR.”
By itself, plastic use is not an environmental indicator
Fefco’s peer-reviewed study argues that a proposed obligatory reuse target of 90% by 2040 would add 8.1 billion plastic crates to the bloc’s transport sector, requiring 16 billion litres of water for washing half of them, while displacing corrugated cardboard packaging.
Similarly, the Kearney study claims that a multi-use 16oz coffee cup contains nine times more plastic than a single-use paper coffee cup and that a reusable cup needs to be reused between 50 and 100 times to make it environmentally preferable from a plastic waste generation point-of-view.
Eunomia, however, has argued that “plastic use should not be isolated as an environmental indicator without addressing the trade-offs.” Demand for paper alternatives, for example, imposes greater demands on forestry resources, with imports of pulp from South America representing 15% of Europe’s total pulp consumption. Further, Popescu notes that the paper industry is exerting tremendous pressure on European forests with excessive harvests of Finnish forests impeding on their carbon sink capacity.
Kearney’s study also seems to flip-flop on some of its key claims: on prima facie analysis, a multi-use 16oz coffee cup containing nine times more plastic than a single-use paper coffee cup would need to be reused nine times, and not 50-100 times, to make it preferable to its paper equivalent.
The paper industry’s reaction to reuse targets is “disproportionate”, says founder of Unpackaged
Catherine Conway, the founder of Unpackaged, a consultancy for retail and foodservice businesses wishing to design and implement zero waste solutions, finds the industry’s reaction to mandatory reuse targets disproportionate, telling Packaging Gateway: “The single-use paper industry is terrified of reuse as it doesn’t see a role for itself in new reusable systems. However, many of the PPWD targets barely reach 50% by 2040 for lots of categories, which means a significant amount of packaging can still be in paper/board.”
“There will still be a significant amount of single-use paper packaging needed,” Conway says, “And the paper industry should be innovating here, rather than trying to stifle reusable packaging innovation in which it is currently engaged.”
The majority of packaging companies to whom Packaging Gateway reached out declined to speculate on the EU’s upcoming legislation.