On 30 November 2022, the European Commission released its proposal for a new Packaging and Packaging Waste Directive. The proposal entails various problems concerning the environment and the forest industry. The proposal favours reusable packaging at the expense of recyclable alternatives and is inconsistent with the targets of the EU’s Circular Economy Action Plan. According to the Action Plan, all packaging placed on the market must be reusable or recyclable by 2030.


The high recycling rates of fibre-based packaging indicate that recycling has become an important focal point in the value chain. The directive should have focused on correcting the existing shortcomings instead of trying to find a poorly justified “silver bullet” that would solve all the challenges related to packaging.


The most severe failings of the directive include the somewhat unrealistic requirements for the use of reusable packaging. The demands placed on the take away sector, in particular, are extremely challenging. According to the Commission’s proposal, by 2030, 20% and by 2040, 80% of beverages should be served in reusable containers. For food packaging, respectively, the corresponding figures are 10% and 40%. In practice, this would mean replacing the current, easily recyclable fibre-based take away packaging with washable packaging made of thick plastic or similar solutions.


Cleaning reusable containers and packaging consumes large amounts of water and energy, which is usually ignored in their lifecycle calculations.


Moreover, the proposal calls for the complete ban of single-use packaging for food and beverages when consumed inside fast food restaurants, starting in 2030. Strict reuse requirements are also set for e-commerce deliveries as 50% of goods would have to be transported in reusable packaging by 2040.


The Commission is also setting gradually increasing targets for the use of recycled materials in plastic packaging. The forest industry sees the requirement of recycled materials as problematic as it appears to also apply to the plastic parts of other than fully plastic packaging, raising questions about food safety and related legislation.


Representatives of the forest industry worry that the strict requirements for reusable packaging will not help reduce the use of plastic. At worst, they may have a completely opposite effect. Furthermore, there is no proof that 100% of the reusable containers would be returned to the system or cut back the environmental impact of packaging. Studies also show that the logistics and cleaning of reusable packaging consume large amounts of energy, water and chemicals.


Taking into account the environmental impact of the product’s entire lifecycle


Wanting to reduce and penalise the use of renewable materials is a questionable decision. Renewable materials are recycled very efficiently in Finland and Europe. The use of reusable packaging should definitely be increased, but not with complete disregard for the reasoning, cost and impact involved. Operators should always be able to choose a packaging solution with the environmental impact of its entire lifecycle minimised. This will not be possible if legislation directs operators to use reusable packaging for everything.


What makes the timing of the proposal interesting is that the global plastics treaty of the UN, aimed to mitigate the use of plastics and its side effects around the world, is currently being negotiated in Uruguay.


The directive will now move on to the usual legislative process of the EU, making it possible to correct the shortcomings.

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