The Brief: How can the packaging industry successfully achieve its sustainability targets?

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Introduction:

FoodDrinkEurope (FDE)’s ‘Sustainable Packaging Pathway’ gives advice on how the industry can meet the European Parliament’s Packaging and Packaging Waste Regulation targets on collection, reuse and more. We highlight some of the stipulations for the food and beverage industry, the industry’s praise and concerns for the deal and outline FDE’s advice to ensure packaging functionality and food safety without trade-offs in food loss and waste prevention.

Key takeaways:

• FoodDrinkEurope’s 6 steps to meet the PPWR’s recyclability and reuse deadlines are stimulating investments; supporting innovation; facilitating international trade and supply chain resilience; building better regulation; improving governance and coordination and enhancing the EU’s internal market.
• FDE’s asks and actions include timely adoption of “secondary legislation setting design for recycling criteria and consideration of existing work in innovating packaging” and “joint public and private investments in collection, sorting, and recycling infrastructures”.
• FDE defines the PPWR’s recyclability commitments as: contact-sensitive packaging made from PET as the major component (except bottles) should be at 30% by 2030 and 50% by 2040. It stresses that chemical recycling should be a complementary solution to mechanical recycling.
• Fundamental criteria for reuse systems includes clear labelling, e.g. expiry dates and handling instructions; considering environmental impact from energy consumption and waste generation and consumer education. Challenges include maintaining smooth logistics and ensuring complementarity with recyclability.

Conclusion:

To enable reuse, FDE suggests adopting an implementing act establishing a calculation method for recyclability at scale; giving the ‘green light’ to chemical recycling technology and adopting recycled content calculation methodology; and finally, developing criteria for setting reuse systems and well-established DRS systems.

In this edition of The Brief, we take an in-depth look at FoodDrinkEurope (FDE)’s ‘Sustainable Packaging Pathway’, which gives advice on how the industry can meet these targets.

We highlight some of the stipulations for the food and beverage industry, touch on the industry’s praise and concerns for the deal, and outline FDE’s key bits of advice in its aim to ensure packaging functionality, food safety and maintain food contact material safety, without trade-offs in food loss and waste prevention.

Adoption of the PPWR regulations and industry responses

In April, a vote by the European Parliament saw measures including collection targets, PFAS limits, and fresh produce packaging bans adopted for the Packaging and Packaging waste regulation.

The rules were provisionally agreed upon with the European Council, including packaging reduction targets of 5% by 2030, 10% by 2035, and 15% by 2040, requirements for EU countries to reduce plastic packaging waste, and plastic packaging getting held to minimum recycled content targets, with minimum recycling targets by weight of packaging waste enforced.

The vote also saw regulations approved for the packaging of unprocessed fresh fruit and vegetables; foods and beverages filled and consumed in cafés and restaurants and individual portions such as condiments, creamer, and sugar, with final distributors of beverages and takeaway food expected to offer a 10% discount on products served in reusable packaging formats by 2030.

Alcoholic and non-alcoholic beverage packaging will be held to their own reuse targets by 2030, but this will not apply to products such as milk, wine and spirits. By 2029, 90% of single-use plastic and metal beverage containers of up to 3L in size must be collected separately, either through deposit return systems or other solutions capable of meeting the target.

The month before, we reported on various industry players’ concerns and praise surrounding the PPWR deal, such as the Rethink Plastic Alliance’s assertion that the binding packaging reduction targets for Member States will help cut down on the rise of packaging waste within the EU and its suggestion to establish reuse targets for beverage and transport packaging, among other sectors.

We also highlighted that in a LinkedIn post, the New European Reuse Alliance described the new measures as “concerning” and “very disappointing for the reuse and refill industry”, noting the removal of reuse targets for takeaway packaging and the implementation of a general derogation to meet reuse targets if certain recycling rates are achieved.

Meeting the PPWR recyclability and reuse deadlines

With this in mind, how does FoodDrinkEurope propose to meet the PPWR’s deadlines for recyclability and reuse? It outlines 6 steps: stimulating investments; supporting innovation; facilitating international trade and supply chain resilience; building better regulation; improving governance and coordination, and enhancing the EU’s internal market.

This includes joint effort on investments from private and public bodies and a “science-based, predictable” policy environment for business investment and faster access to technology such as chemical recycling and sorting and reuse infrastructure. It also recommends finalizing the EU Food Contact Materials regulatory framework and prioritizing implementation of the EU harmonized sorting label.

The FDE’s pathway towards the PPWR targets is split into 3 areas: packaging recyclability, recyclability commitments set by the PPWR and implementing reuse. Each section has been split into a timeline of the regulation deadlines, key figures the confederation’s ‘asks and actions’.

The regulation timeline for packaging recyclability begins with the deadline that from 2030 (or 2 years from the adoption of the Delegated Act), all packaging shall be recyclable in line with design for recycling criteria to be established in delegated acts by 1^st January 2028. Also from 2030, packaging will not be allowed on the EU market unless recyclable within grades A, B, or C.

From 2035 (or 2 years from the adoption of Delegated Act), packaging will also have to be recycled at scale, in line with conditions set out in the Implementing Act by January 2030. By 2038, only packaging falling within grades A or B will be allowed on the market.

When outlining its key figures for packaging recyclability, FDE cites Eurostat statistics which state that in 2019, European countries generated approximately 86.7 million metric tons of packaging waste, accounting for nearly one-third of the total municipal waste stream.

It adds that more than 70% of waste generated in Bulgaria and Malta ends up in landfill, and in Greece, Cyprus and Romania it accounts for more than 50%. Reportedly, almost 50% of waste is landfilled in Spain and Portugal, and in 2021, EU exports of waste to non-EU countries reached 33 million tonnes. This is said to be an increase of 77% compared to 2004.

Asks and actions

The FDE’s first ‘ask’ for packaging recyclability is “timely adoption of secondary legislation setting design for recycling criteria and consideration of existing work in innovating packaging”. Actions towards this include the recyclable Pringles tube developed last year, designed for home recycling by consumers and due to be rolled out at the end of 2024.

It adds that the existing plastic cap on Beefeater’s glass bottle was replaced with an aluminium cap and the label changed from PVC to paper, apparently saving 410 tonnes of plastic annually. A one-material pouch for Choco M&Ms has been designed to be recyclable, according to existing local packaging waste collection and sorting systems.

The FDE also calls for urgent “joint public and private investments in collection, sorting, and recycling infrastructures” and for the correct functioning of Extended Producer Responsibility (EPR) schemes, suggesting that EPR fees should first be used to finance the cost of separate collection and recycling of packaging that is designed to be recyclable.

It gives the example of the Nestlé recycling partnership, operating since January 2023 and allowing all beverage capsules and pods of aluminium or plastic to be collected in the new Blue Bag for recycling in Belgium, financed by Nespresso, Nestlé, JDE Peet’s and FostPlus.

Recyclability commitments set by the PPWR

In its Sustainable Packaging Pathway, the FDE defines the recyclability commitments set by the PPWR as follows: contact-sensitive packaging made from PET as the major component (except bottles) should be at 30% by 2030 and 50% by 2040. Contact-sensitive packaging made from plastic materials other than PET, except plastic beverage bottles should be 10% by 2030, and 25% by 2040.

For single-use plastic beverage bottles, this should be 30% by 2030 and 65% by 2040. All other plastic packaging (such as non-contact sensitive) should be 35% by 2030 and 65% by 2040.

FDE highlights a report by Plastics Europe which says that 68% of post-consumer plastic waste is going to landfills and energy recovery across Europe, and incineration has increased by over 15% since 2018 (16 Mt in 2022), and around 25% of plastic waste is still sent to landfill (7.6 Mt in 2022).

FDE’s ‘asks’ for these commitments are ensuring fair priority access “where technically feasible and environmentally beneficial”, and recognising the importance of chemical and mechanical recycling technologies to maintain Europe’s competitiveness.

It stresses that chemical recycling should be a complementary solution to mechanical recycling. In this vein, the confederation draws attention to Coca-Cola’s implementation of 100% recycled plastic bottles in 10 European countries, and INEOS, PepsiCo and Amcor’s 50% recycled plastic film packaging for Sunbites crisps in the UK.

Implementing reuse: the requirements, challenges and enablers

FDE also sets out its fundamental criteria for reuse systems. Beginning with hygiene standards, food safety regulation and durability, it emphasizes the need for clear labelling such as expiry dates and handling instructions.

In addition, outlines the environmental impact from energy consumption and waste generation, consumer education – when returning containers for reuse, for example - transport and logistics, and collaboration and partnerships such as between public authorities and suppliers.

FDE recognizes the challenges of implementing reuse, like maintaining smooth logistics and ensuring complementarity with recyclability. The transport of reusable packaging from return points to washing and filling points requires new reverse logistics. For reuse to complement recyclability, investments for recyclability at scale should be made and recyclability implemented where it is the most suitable solution.

Key enablers for implementing reuse

What does FoodDrinkEurope believe needs to happen for reuse to be implemented successfully? This includes a tailored calculation method such as reuse metrics, which should be easy to report and demonstrate scale; financial support (European Commission financial schemes, for example); and effective collection through systems like DRS for recycling and reuse.

FDE encourages the consideration of reuse when it makes sense from an environmental point of view and asks for the establishment of effective collection systems for reuseable packaging. It adds that synergies between DRS for reuse and DRS for recycling should be explored based on local context, to utilize existing infrastructure where applicable.

To this end, it gives the example of Pakt Packaging’s reusable glass pilot, where single-use bottles and jars were collected at home by Picnic supermarket, sorted, washed, and redistributed to suppliers.

There is also the Nestlé pilot in Germany with local retail and start-up Circolution, which developed standardized reusable stainless steel packaging for Nesquik, compatible with existing DRS and cleaning infrastructure.

Finally, FoodDrinkEurope concludes its pathway strategy with enabling conditions and asks for policymakers regarding recyclability, recycled content and reuse. These are defined in terms of immediate (2024-2025); short-term (2026-27); and medium-term (2028-2030).

‘Immediate’ asks for recyclability include Member States investing “heavily” in recycling infrastructure and meeting recycling targets, to reach recyclability at scale by 2030. Clarity and simplification are requested on reporting duties introduced through the Implementation Act, expected by 31^st December 2026.

In the short term, FDE suggests minimum and steadily increasing landfill/incineration taxes introduced on all waste streams and implementing mandatory measures to incentivize mixed waste sorting. The medium-term ask is to adopt an implementing act establishing a calculation method for recyclability at scale.

For recycled content, policymakers need to ‘green light’ chemical recycling technology in 2024-2025 to unlock investments and innovation. Short-term asks include adopting recycled content calculation methodology and defining sustainability criteria for recycling technologies; and FDE’s medium-term ask is consistency between incorporating recycled content in food-grade packaging and tightening food safety requirements with clear regulatory procedures.

FDE’s ‘Immediate’ reuse suggestions include developing criteria to follow when setting reuse systems, and setting up financial support for sectors tied to achieving 2023 targets; in the short-term, publication of the Commission’s guidelines explaining better products in the scope of reuse targets; and medium-term, the ‘ask’ is for well established and functioning DRS systems.

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