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Plastic packaging waste regulations in the EU: A challenge and an opportunity
The packaging industry is transforming to join the circular economy. And Europe is leading the way in this push for sustainable packaging. As the European Commission works to harmonize rules across its 27 member states, how can you navigate the changing landscape of packaging regulations?
15 November 2023 | 
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The issue of plastic packaging waste has been on the agenda in Europe for some time now. For manufacturers — especially durables, food & beverage, cosmetics & personal care, and packaging film — keeping up to date can be a real challenge. But it’s also an opportunity to innovate and lead.
The first thing to understand is that EU action doesn’t always come in the form of direct regulation. In fact, there are different mechanisms that can limit the use of plastics and force manufacturers to adapt with alternative materials. Let’s look at four of these that have the greatest impact on your manufacturing processes, starting with the most recent updates on packaging and packaging waste regulation (PPWR).
Revised packaging and packaging waste regulation (PPWR) is still at the proposal stage[1]. It aims to make recyclable packaging mandatory, with specific targets on recycled content by 2030 and 2040 for reusables, refillables, and labelling. 2030 goals include a ban on single-use packaging in restaurants and cafes and an increase to 10% in reusables for takeaway.
The proposed regulations also works to resolve confusion about which packaging belongs in which recycling bin. All packaging would be required to carry a label indicating what it is made of and where it should go in the waste stream. Labels would also be placed on waste collection containers, with the same symbols used throughout the EU.
This proposal is currently under consideration with a final decision expected in late 2023 or early 2024. Enforcement would begin 12 months after that.
The new PPWR will drive the need for recycled content. Depending on the application, manufacturers can consider the use of mechanically or chemically recycled content. The need for one source or the other will be driven by the amount of recycled content needed and final performance balance.
The EU directive on single-use plastic[2] came into force in 2019. It aims to reduce the volume and impact of the 10 most common plastic items found on European beaches, including packets, wrappers, and food and beverage containers.
With each country taking a different approach, it can be difficult to implement a single EU-wide solution. For example, plastic bag regulation varies widely per country. Some are banning them, others are taxing them, and the rest are still considering what action to take.
In response to this, some countries are implementing their own plastic taxes. For example, Spain introduced a tax of €0.45 per kilogram of non-recycled plastic this year. And, in July, the Netherlands launched a tax on disposable cups and containers.
Plastic taxes vary widely. Some target all packaging, while others take aim at single-use plastics only. Some specifically target foreign-sourced plastic products. In addition, there is the possibility of fees for incineration or landfill.
The new tolerable daily intake (TDI) of BPA is 20,000 times lower than previously set. Now, the European Commission needs to determine what regulations or directives are necessary to protect consumers. A timeline for this is not yet available, but it will likely have significant implications for manufacturers.
The first thing to understand is that EU action doesn’t always come in the form of direct regulation. In fact, there are different mechanisms that can limit the use of plastics and force manufacturers to adapt with alternative materials. Let’s look at four of these that have the greatest impact on your manufacturing processes, starting with the most recent updates on packaging and packaging waste regulation (PPWR).
Navigating recycled content requirements in EU packaging waste regulation
Direct regulation is the clearest and least flexible mechanism used. Regulations must be implemented uniformly across the EU. This makes it easier for manufacturers to find a single solution for the entire region.Revised packaging and packaging waste regulation (PPWR) is still at the proposal stage[1]. It aims to make recyclable packaging mandatory, with specific targets on recycled content by 2030 and 2040 for reusables, refillables, and labelling. 2030 goals include a ban on single-use packaging in restaurants and cafes and an increase to 10% in reusables for takeaway.
The proposed regulations also works to resolve confusion about which packaging belongs in which recycling bin. All packaging would be required to carry a label indicating what it is made of and where it should go in the waste stream. Labels would also be placed on waste collection containers, with the same symbols used throughout the EU.
This proposal is currently under consideration with a final decision expected in late 2023 or early 2024. Enforcement would begin 12 months after that.
The new PPWR will drive the need for recycled content. Depending on the application, manufacturers can consider the use of mechanically or chemically recycled content. The need for one source or the other will be driven by the amount of recycled content needed and final performance balance.
Directive on single-use plastics policy
The EU’s action on single-use plastics (SUP) comes in the form of a directive. Directives are legal acts requiring each member state to accomplish defined goals — without dictating how they do it. Individual countries make their own decisions and laws to accomplish them.The EU directive on single-use plastic[2] came into force in 2019. It aims to reduce the volume and impact of the 10 most common plastic items found on European beaches, including packets, wrappers, and food and beverage containers.
With each country taking a different approach, it can be difficult to implement a single EU-wide solution. For example, plastic bag regulation varies widely per country. Some are banning them, others are taxing them, and the rest are still considering what action to take.
Plastic packaging tax in the EU
In 2021, the EU began charging member states[2] based on the amount of non-recycled plastic packaging waste they produce. Their contributions are calculated at a rate of €0.80 per kilogram. This is commonly referred to as a plastic tax. However, the EU has no direct role in collecting taxes or setting tax rates.In response to this, some countries are implementing their own plastic taxes. For example, Spain introduced a tax of €0.45 per kilogram of non-recycled plastic this year. And, in July, the Netherlands launched a tax on disposable cups and containers.
Plastic taxes vary widely. Some target all packaging, while others take aim at single-use plastics only. Some specifically target foreign-sourced plastic products. In addition, there is the possibility of fees for incineration or landfill.
EFSA re-evaluation of BPA policy
The final mechanism influencing EU-wide policy on plastics is recommendations from the European Food Standards Authority (EFSA). They recently re-evaluated the health risks of bisphenol A (BPA) and issued new standards[3] in April.The new tolerable daily intake (TDI) of BPA is 20,000 times lower than previously set. Now, the European Commission needs to determine what regulations or directives are necessary to protect consumers. A timeline for this is not yet available, but it will likely have significant implications for manufacturers.
How can IMCD support you with aligning European packaging regulations?
Sounds complicated? Don’t worry, we’re here to help. Our country teams across Europe continuously track the progress of local packaging regulations and rules to advise and support you. By taking a proactive approach, we can help you align and adapt with renewable solutions suitable throughout Europe. Our sustainable packaging range includes newly developed materials to help you comply with regulations and meet targets, including BPA-free materials and chemically recycled food-grade solutions.References:
1. Directorate-General for Environment (30/11/22). Proposal for a revision of EU legislation on Packaging and Packaging Waste. European Commission
2. (02/07/19) Single-use plastics. European Commission
3. (19/04/23). Re-evaluation of the risks to public health related to the presence of bisphenol A (BPA) in foodstuffs. EFSA EU
Fast facts
The EU packaging waste regulation refers to a set of legal requirements aimed at reducing the impact of packaging waste on the environment. The most recent proposal, the Packaging and Packaging Waste Regulation (PPWR), is designed to ensure that all packaging in the EU market is recyclable by 2030. It sets specific targets for recycled content in packaging materials and introduces measures to reduce single-use packaging, improve labeling for recycling, and increase the use of reusable and refillable packaging options. This regulation is part of the EU's broader strategy to transition towards a circular economy and reduce plastic waste.