The European Commission’s proposed packaging and packaging waste regulation (PPWR) is under scrutiny as the cost-benefit analysis conducted by the Commission is being questioned.

Industry representatives and right-wing lawmakers criticise the law’s reuse targets, while environmental campaigners, left-wing politicians and Green lawmakers demand more ambitious action.

The PPWR, introduced in November of last year, includes a plan to ban single-use packaging in dine-in restaurants starting from 1 January 2030. The proposal also sets targets to expand the use of reusable packaging for takeaway purposes.

However, the Commission’s impact assessment, which is meant to evaluate major legislation’s economic, health and environmental impacts, has drawn criticism for its failure to differentiate between packaging materials and its lack of comprehensive analysis of the proposed targets.

Industry coalition raises concerns

An industry coalition warned EU countries in March that without a proper impact assessment considering environmental, consumer behaviour and economic implications, there is no assurance that the proposed measures will yield the desired benefits.

The coalition expressed concerns about the potential detrimental impact on the environment, consumer access, choice, convenience and companies operating in the EU.

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The Commission defended its assessment, stating that it followed a transparent methodology and systematic approach, considering the environmental impact of packaging throughout its entire life cycle.

According to the Commission’s analysis, the proposed reuse targets could lead to a decrease in water consumption and a reduction of 1.25 million tons of CO2 emissions by 2030 without causing an increase in fossil fuel usage.

The impact assessments conducted by the Commission involve consultations with all interest groups, including the industry and are reviewed by an independent regulatory scrutiny board.

Key reuse targets removed by lead EU lawmaker

Lawmakers in the European Parliament are divided on how to tackle the growing issue of packaging waste in Europe, with the debate revolving around reuse versus recycling.

According to amendments seen by EURACTIV, the European Parliament lawmaker responsible for negotiating the new packaging waste law has removed targets to promote the reuse of packaging in the restaurant sector.

This move has sparked further controversy and raised concerns among critics of the law.

The industry argues that the impact assessment failed to individually consider specific sectors, packaging materials and recycling rates, resulting in unrealistic benchmarks.

They criticise the blending of different materials, such as paper with high recycling rates and materials with lower recycling rates, claiming that it is unfair to treat them equally. Industry representatives emphasise the need for sector-specific assessments to determine the best environmental outcomes.

On the other hand, the environmental group Zero Waste Europe disagrees, stating that a comprehensive and holistic view of the system’s interdependencies is necessary, as a sector-specific analysis may provide limited insights.

Concerns raised over reuse targets’ substitution effect

Critics have also raised concerns about the potential substitution effect caused by reuse targets. They fear that promoting packaging reuse could lead to increased use of plastic as a substitute for paper, which could have unintended consequences.

Green campaigners argue that reusable plastic packaging is likely more relevant for sectors prioritising speed and lightness, such as fast-food, takeaway restaurants and supermarkets.

Additionally, the Commission’s assessment has faced criticism for underestimating the economic costs associated with the reuse targets.

The industry claims the direct costs for implementing all reuse schemes would be much higher than the Commission’s calculation. They cite a study indicating that switching to reuse for only 20% of PET bottles used in the carbonated soft drinks industry would cost €18.7bn.

However, NGOs supporting the law argue that the assumptions made by the Commission are balanced and realistic, given the existing infrastructure in place.

Reuse systems raise health risk concerns

Another point of contention is the potential health risks associated with reuse systems. The industry warns that the lack of consumer trust in the safety of reuse systems could undermine the objectives of the law.

However, environmental campaigners argue that functioning reuse systems exist in several member states without adversely affecting hygiene or consumer safety.

While some advocate for stronger reuse targets to address Europe’s growing packaging waste problem, others express concerns about potential negative consequences.

According to left-wing lawmakers and environmental campaigners, the impact assessment highlights the need for ambitious, rapid and far-reaching action to address the pressing issue of packaging waste.

They emphasise the importance of considering multiple studies and evidence in making policy choices beyond the impact assessment alone.