Interesting things about the packaging industry, retailing dynamics, consumer trends and NOA’s insight.

PPWR: the forces at work influencing its scope and direction

Sep 8, 2023 | Corrugated Packaging, Market Research, Packaging, Packaging Research and Analysis


The European Parliament will be voting on the new Packaging & Packaging Waste Regulation. Neil Osment, Managing Director of paper packaging industry analysts NOA, looks at what this means for the packaging industry.

For reasons we are all too familiar with, sustainability is a hot topic and the packaging world is not immune to pressures to make changes in the face of climate change.

On September 20, the European Parliament is due to vote on the Packaging & Packaging Waste Regulation (PPWR), which will go on to be ratified by the European Commission in March next year.

PPWR’s aim, as we all know, is to curb packaging waste. But delve beneath this top level goal, and it is clear there is extensive lobbying, from different interested parties, who are trying to influence the direction of PPWR before it finally hits the statute books.

What do the politicians want to see from PPWR?

Their driver is the ‘reuse’ of packaging, both paper and plastic based. They see reuse as a more energy efficient way to reduce the amount of packaging produced.

However, this is at odds with producers of paper and plastic packaging who, perhaps for the first time, find themselves on the same side of the argument.

Why is this?

Let’s look at producers of corrugated packaging. If the aim is reuse, then clearly most corrugated doesn’t lend itself, plus it’s already committed to a well-developed recycling system; in Europe more than three quarters of the corrugated used is already produced from recycled paper and board.

What about the plastic packaging industry?

Similarly, producers are not in favour of reuse over recycling, for reasons we’ll explore. The result is that both sectors are lobbying hard to try to draw politicians’ attention to their concerns.

Their position is understandable. Europe leads the way in recycling, while the infrastructure for the return and reuse of packaging material isn’t there.

And what about the argument that reuse is more energy efficient?

On the face of it, surely reuse must be kinder to the planet? In fact, this isn’t clearcut.

Take the example of returnable plastic containers (RPCs), which are favoured by supermarkets for displaying fruit and veg, in particular. They are filled in the fields and go straight to the retailers, then, once empty, go back to the brand owners, in a closed loop system. But the volume of water and energy needed to wash these, at high temperatures, suggest the CO2/water use benefit is marginal.

In addition, for any brand owner thinking of setting up a new reusable systems, they need to be mindful that such systems require massive initial investment in container stocks, washing, collection, storage, transport and distribution facilities. Those stocks require constant (and costly) replenishment to keep the container ‘pool’ at optimum capacity.

Here’s another example. Germany has a highly developed deposit return scheme (DRS), but this has taken decades to fine tune and nobody else has adopted it. Attempts have been made, for example the Netherlands have introduced a DRS for plastic bottles, but the system is limited and has mainly been in place for handling 2 litre bottles only. In the last few years this has expanded to include 250ml and 330ml plastic bottles, however these changes were brought in largely as a response to pressure from the Plastic Soup Surfer (AKA Merijn Tinga, who campaigns for the introduction of deposit systems) and may stop at that.

In the UK there was an attempt to introduce a DRS in Scotland, and drinks companies invested heavily in the necessary infrastructure. Yet the scheme was scrapped by the Scottish government. Brand owners who invested millions in bottling lines to accommodate reuse are now making financial claims against the Scottish government.

It is clear that if the direction of travel for PPWR is reuse, then brand owners’ reluctance to get on board is in part due to cost. Indeed, it’s been mooted that some other food channels might consider a move to plastic closed-loop schemes; as just one example, good old-fashioned cardboard eggboxes could be replaced with plastic, as part of a RPC system. But there’s always a reluctance from producers to invest in the necessary technology and we’d question how such a change might go down with consumers.

So, what does influence the brand owners?

They are taking the lead from consumers, who want to see a reduction in the use of plastic packaging. This is driving a move towards fibre-based packaging, and we continue to see innovations in this area.

Carte Do’r (from Unilever) have switched to a moulded pulp carton, with a plastic liner, using 93 per cent less plastic. Packs of detergent tablets (such as Aerial, Persil and Fairy) now come in cardboard boxes. The new Pringles pack (from Kellogg’s) is 100 per cent recyclable, with the tube now being made of 90 per cent paper.

Walkers (made by PepsiCo) are moving their multipacks from an outer plastic bag into boxes and have taken this decision based on a better greenhouse gas score. They invested £14m to trial this in their Leicester factory and are now investing £100m to roll it out in other locations.

It’s clear that while the push and pull of PPWR and its final composition goes on, brand owners, and therefore packaging producers, are getting on with making changes. They are looking at the greenhouse gas score, they are responding to consumer pressure, and they are gravitating towards fibre.

And what will PPWR look like, when it finally becomes law, bearing in mind that, once voted in, it will take two or three years to have teeth? Whatever its look, we think its impact won’t really be felt until 2026-27 and the potential investment costs for compliance could be huge. The vote on September 20 is by no means the final story. This one will run and run…

For more information, please get in touch.