EU Packaging and Packaging Waste Directive industry concerns explained



Explaining industry concerns about the EU’s Packaging and Packaging Waste Directive.

The third European Union (EU) Packaging and Packaging Waste Directive (PPWD) is under consideration by the governing parts of the Union (Commission, Parliament and Council – see Fig. 1) in how to frame Packaging and Packaging Waste Regulation (PPWR) for its delivery.

The European Green Deal and the new circular economy action plan seek to ensure that all packaging is reusable or recyclable in an economically feasible way by 2030. The objective is to enforce the essential requirements for packaging to ensure its reuse and recycling, increase the uptake of recycled content in new products, help requirements of enforceability, address over-packaging and reduce packaging waste.

Figure 1: EU Legislative Bodies and System.

The proposal is now with the co-legislators (Parliament and Council) for consideration. 

The European Parliamentary Research Service determined six facts about Packaging and Packaging Waste as drivers for change, these facts are:

  • Each EU inhabitant produces 180 kg of packaging waste each.
  • Its more than 20% consumption than a decade before.
  • 13 billion kg of additional waste in 10 years.
  • 40% of all plastic used in the EU goes into packaging.
  • 50% of all paper in the EU is used for packaging.
  • All this packaging produces more Greenhouse Gas (GHG) than Hungary.

Table 1 below summarises the concerns of the packaging industry (10 bodies) and their support for changes. Please click on each hyperlink to learn more about each industry body.


Table 1: Packaging Industry Bodies Concerns of PPWR proposals – March 2024




Commons Seas

Growth of Plastic to 141 Million Tonnes

Combat of plastic growth via bans, reduction, reuse, recycling, EPR & DRS


Rethink Plastic Alliance

Watered down proposals

Impact of use of chemicals in Food Contact will have on circularity, environment, health and safety, etc. Single-use sector. Regulatory loopholes. Disregard for due process. Exclusion of cardboard from reuse targets. Replace waste plastic with paper with little environmental benefit.

Ban on PFAS Food Packaging

Reductions 5 to 15 % to 2040.

Reuse for beverage and transport packaging.  


Zero Waste Europe

Chemicals in packaging used for food contact. Not happy with shift of plastics to paper negating the single-use plastics directive.

Ban on PFAS Food Packaging

Toxic free CE


European Bioplastics

As above.

Review also of bio-based plastic packaging for sustainability requirements. 


European Reuse Alliance

Take away packaging, 

Trade-off Reuse v Recycling. 

None as they feel measures go in the opposite way  of PPWR objectives.


Environmental Paper Network

Distortion of single-use reduction via Brand lobbyists. Legislators are buckling.

Stricter regulation.


Circuthon Consulting 

New rules failed to outlaw cardboard fast-food containers and coffee cups or force the use of reusable containers. Need more support.

Need more support for the reduction of unnecessary packaging and over-packaging is a waste resource failure. Recycling alone is not the answer.


Environmental Coalition of Standards

Need more support for refill and reuse, prevention and minimisation. 

Use less resources. Less incineration of recyclable packaging.



Good balance – but concerns about further market fragmentation impacting on EU Single Market and collective progress towards circularity. 

Balance is good between ambitious environmental goals and the practical realities of implementation.

The table above indicates the concerns of industry stakeholders and support of the PPWR regulation as it makes its way through the mechanics of the European Union legislative structure (See Fig 1 above).

Industry stakeholders in a joint statement in December 2023 also aired concerns about State-owned Extended Producer Responsibility (EPR) bodies as they have “no represented producer mandate” and fear their role of being just a vessel for collecting taxes and only helping fulfil Member States reporting obligations.

This goes against the premise of Extended Producer Responsibility schemes as laid out in Article 8a of the Waste Framework Directive (WFD) and cannot be considered asEPR as put forward by the Organisation for Economic Co-operation and Developments (OECD). 

Send this to a friend