The European Union is at the forefront of global efforts to tackle climate change, including dealing with plastic pollution. In recent years, EU institutions have taken important legislative steps to tackle this issue and advance plastic circularity in the region, leading to the signing of the Packaging and Packaging Waste Regulation (PPWR) this year.
This piece of legislation will put in place the much-needed harmonisation of recycling and plastics manufacturing practices across EU Member States, stimulating investments in the sector and safeguarding the EU Green Deal’s environmental objectives. However, although crucial, the PPWR represents only the start of the work to drive plastics circularity in the EU.
It is a complex puzzle with many missing pieces that will only be put together once the secondary legislation is adopted. This is the chance to find the pieces that fit best and create a healthy, competitive plastics recycling value chain in the European Union.
The kick-off of the work
The PPWR is a game changer for the whole packaging industry in the EU as it sets clear objectives for circular packaging. With a robust design for recycling framework and recycled content targets, it will secure high-quality input materials for recycling processes and boost their uptake in high-quality applications, potentially resulting in a decoupling of recycled plastics prices from their virgin counterparts.
However, with around 40 secondary legislative documents that will need to be developed, the real work is just about to start. To achieve the full potential of the PPWR, the details of this very important piece of legislation will have to be found on data, science-based results, and environmental performance parameters.
It will be equally important to pursue a true level playing field. It is a must for the plastics recycling industry – and the European industry as a whole - to retain its competitiveness in light of market challenges such as the ones it is currently facing.
Setting the bar high
The PPWR sets ambitious goals and targets for the plastic recycling value chain. Structured around pillars including recyclability, minimum recycled content, reuse, and collection, it aims to ensure that all packaging in the EU market is reusable and/or recyclable in an economically viable way by 2030.
It includes provisions on recycling targets of 50% for plastic packaging by 2025 and 55% by 2030 and foresees recycled content targets for all types of plastic packaging, with the most demanding ones set for 2040 – including 65% recycled content for SUP beverage bottles, 50% for PET contact-sensitive packaging and 65% for other packaging.
To ensure these ambitious targets are achieved fairly, a robust methodology must be put in place, including equivalent conditions for EU and non-EU recycled content, a strong methodology for verification methods and limits to priority access.
The PPWR also introduces as of 2030 a recyclability performance grade scale from A to C stating the extent to which packaging is considered recyclable, being 95% grade A, 80% grade B and 70% grade C. These grades, if issued by third-party certifying bodies and reliable audit schemes such as those of RecyClass, will allow consumers to make environmentally conscious choices, as sufficient and authentic information will be provided about the environmental performance of the product.
Transparency and equivalent conditions for EU and non-EU recycled content
EU recyclers are currently subject to robust legislation and safety requirements. However, these cannot always be verified for imported materials, leading to a lack of a level playing field. EU and non-EU recycled content must meet the same strict environmental and safety requirements to protect consumers and ensure that the ambitious objectives of the EU Green Deal are met.
The PPWR introduces requirements for the post-consumer plastic waste originating from outside the EU to be collected following standards for separate collection, and to be recycled in a facility meeting sustainability requirements, such as the reduction of GHG emissions.
However, these requirements will need to be paired with a robust methodology that ensures strict enforcement. The secondary legislation will need to provide a clear, trustworthy method of verifying standards for recycled plastics to avoid greenwashing which is imperative in ensuring the safety of consumers and maintaining the environmental goals of the EU.
When it comes to improving the traceability of imported materials, independent third-party certifications could represent one of the solutions. Such schemes must be based on a chain of custody model which includes verification of the origin of the waste, how it is recycled and to whom it is supplied.
Nowadays, companies are free to make claims on the use of recycled plastics without harmonised methods of calculation and verification, making it impossible for consumers to know whether the percentage they see on the packaging is real or not.
Priority access distorting the single market
One of the key pieces of the PPWR puzzle to be tackled in the secondary legislation is priority access which implies that systems of collection and sorting may provide priority access to recycled materials to be used in applications where the quality of recycled material is preserved and recovered so it can be recycled further and used in the same way and for similar applications.
This clause will restrict the EU internal market for plastic recyclates, hold back investments and distort the EU single market. Favouring specific players and packaging types can negatively affect market dynamics and the industry’s competitiveness.
The secondary legislation must find a solution so that the already threatened EU plastic recycling industry is not further imperilled.
A circular future for plastics?
The PPWR represents a big step in the right direction to attain a circular future for plastics in the European Union. It will harmonise recycling practices among Member States, push for the increased use of recycled plastic and contribute to the sustainability goals of the EU Green Deal.
However, the details and criteria of compliance with the set targets will determine to what extent the PPWR will enable a circular future for plastics. It is now more important than ever to ensure fair conditions for the plastics recycling industry in the PPWR’s secondary legislation and a level-playing field that will enable the creation of a healthy plastics recycling value chain in the EU.
One thing is sure: the commitment of recyclers is standing strong. While much work remains ahead, the legislative advancements, the stable growth and the massive technological developments in the industry are the foundation upon which a circular future for plastics can continue to be built.
PRE is committed to working with the institutions and stakeholders to deliver robust legislation, founded on data and science-based results to genuinely improve plastic waste management and plastic recycling in the EU.
This article first appeared in the May/June issue of Sustainable Plastics