May 2023
International Organisation of Aluminium Aerosol Container Manufacturers

EU Commission submitted draft Packaging and Packaging Waste Regulation

In November 2022 the EU Commission submitted a draft Packaging and Packaging Waste Regulation (PPWR) which shall replace the current Directive 94/62/EC. The switch from a Directive to a Regulation means that the regulation becomes directly binding in all EU Member States once it has been published.

The proposed PPWR which follows the objectives of the European Green Deal represents an ambitious piece of regulation and contains a number of challenging requirements.

Minimization of packaging waste and recycling targets

The PPWR requires each Member State to progressively reduce the packaging waste generated per capita as compared to the packaging waste generated per capita in 2018, by 5 % by 2030, 10 % by 2035 and 15 % by 2040. The Member States shall implement measures such as economic instruments to provide incentives to reach these targets. In addition, the weight and volume of packaging shall be minimised with due account taken of the packaging’s safety and functionality. The compliance with this obligation shall be proven by technical documentation.

The PPWR stipulates that Member States ensure that Extended Producer Responsibility (EPR) systems are set up to enable the return and/or collection of all packaging and packaging waste from the consumer, other final user, or from the waste stream. It also lays down recycling targets of packaging waste that Member States must meet by 31 December 2025 (e. g. 50% for aluminium) and by 31 December 2030 (e. g. 60% for aluminium), which are the same as in the current Directive 94/62/EC. The rules on calculation of the attainment of the recycling targets become stricter. The draft regulation says: “The weight of packaging waste recycled shall be calculated as the weight of packaging that has become waste which, having undergone all necessary checking, sorting and other preliminary operations to remove waste materials that are not targeted by the subsequent reprocessing and to ensure high-quality recycling, enters the recycling operation whereby waste materials are actually reprocessed into products, materials or substances.” When calculating the recycling rate, Member States should be enabled to also take into account the recycling of metals separated after incineration of waste in proportion to the share of the packaging waste incinerated provided that the recycled metals meet certain quality criteria.

Design for recycling, recyclability performance grades and recycled content targets

As of 1 January 2030, packaging will have to comply with the design for recycling criteria and, as of 1 January 2035 the requirements will be further adjusted to ensure that recyclable packaging is also sufficiently and effectively collected, sorted and recycled (recycled at scale). The criteria for the design of recycling and the methodology to assess if packaging is recycled at scale will be established in delegated acts to be adopted by the EU Commission. Financial contributions to be paid by producers to comply with their extended producer responsibility obligations shall be modulated based on the recyclability performance grades under the design for recycling criteria. From 1 January 2030, packaging shall not be considered recyclable if it corresponds to performance grade E (lower than 70 %).

The PPWR also stipulates recycled content targets for plastic packaging differentiating between contact sensitive and non-contact sensitive products. Recycled content targets for aluminium packaging are not foreseen in the PPWR. As of 1 January 2030, plastic packaging shall contain certain minimum amount of recycled content recovered from post-consumer plastic waste, per unit of plastic packaging. Specific packaging has been exempted, as appropriate. These amounts shall increase by 1 January 2040 and the derogations should be revised. The Commission will adopt an implementing act to establish the methodology for the calculation and verification of the percentage of recycled content recovered from post-consumer plastic waste and the format for the related technical documentation.

Promotion of reuse and refill systems and deposit return schemes

Moreover, the draft aims at establishing efficient reuse and refill systems with sector specific reuse targets. One of the requirements is that the packaging is conceived, designed and placed on the market with the objective to be re-used or refilled a maximum number of times. The economic operator who places reusable packaging on the market shall ensure that a system for re-use for that packaging is in place. Those economic operators who offer products for purchase through refill must provide certain information to end-users and ensure the compliance of refill stations with certain safety and hygiene requirements.

With regard to the promotion of deposit return schemes, by 1 January 2029, Member States shall take the necessary measures to ensure that deposit and return systems are set up for:

(a) single use plastic beverage bottles with the capacity of up to three litres; and

(b) single use metal beverage containers with a capacity of up to three litres

A Member State will be exempted from this obligation, if the rate of separate collection of the respective packaging format is above 90 % by weight of such packaging placed on the market.

Harmonised labelling and declaration of conformity

Concerning harmonisation of labelling in the EU, the draft regulation lays down that packaging is marked with a label containing information on its material composition in order to facilitate consumer sorting. The same labels shall be placed on waste receptacles for the consumer to easily identify the appropriate disposal route. Harmonized labelling shall also be designed to inform about the recycled content in plastic packaging. Moreover, reusable packaging shall bear a QR code or other type of data carrier giving access to the relevant information facilitating its re-use.

Finally, the PPWR requires the suppliers of packaging or packaging material to provide the manufacturer with all the information and documentation needed to demonstrate the conformity of the packaging. The documentation comprises amongst others:

  • a general description of the packaging and of its intended use
  • conceptual design and manufacturing drawings and schemes of components, sub-assemblies, circuits, etc.
  • harmonized standards and technical specifications
  • test reports

Aluminium as an enabler for utmost sustainability

True, the draft PPWR poses big challenges for aluminium aerosol can producers, for example the established recyclability performance grades and the increasing documentation for the declaration of conformity. However, aluminium as a packaging material has a lot to offer when it comes to developing sustainable and economical packaging solutions.

Aluminium is a sustainable material par excellence because it is fully recyclable without loss in quality. Unlike other materials, its inherent properties do not change through recycling. The energy required to recycle aluminium is about 5% of that needed for primary production, meaning that CO2 emissions are reduced by 95 %, compared to average primary aluminium carbon emissions.

Since aluminium has the highest scrap value of all packaging materials, there is a big financial incentive in the entire value chain to collect, sort and recycle it worldwide. Its high value will ensure that aluminium will be one of the most demanded scraps in Extended Producer Responsibility (EPR) systems.

Concerning the promotion of refill and reuse systems which is also part of the draft PPWR, can manufacturers could, for example, think about investigating into the development of refill solutions for non-pressurized deodorants together with customers. In addition, impact extruded aluminium cans or bottles could also be a perfect packaging solution for non-aerosol, refillable products in the cosmetics and body care sector. Thus, besides the challenges, there are also plenty of opportunities ahead.