Mandatory PPWR reuse targets threaten “plastics flood” and backtrack on European progress, says DS Smith

28 Jun 2023 --- Proposals to increase mandatory packaging reuse in the EU could result in a massive rise in plastic use and backtrack years of progress, according to a report released by paper packaging giant DS Smith.

The company says that proposed revisions to the EU’s Packaging and Packaging Waste Directive (PPWD), which could see an obligatory reuse target of 90% by 2040, would require 8.1 billion plastic crates to the bloc’s transport sector, weighing approximately 12 million tons, and require up to 16 billion liters of water needed to wash half of them for reuse.  

The findings come from an independent review commissioned by Fefco, the European corrugated packaging association in Brussels. 

These amendments – if implemented – would contradict the aims of the Green Deal, the Circular Economy Action Plan, and ongoing global negotiations to curb plastic pollution, according to DS Smith. 

Recycling has an important role to play in the circular economy and reuse only benefits the plastics industry, says DS Smith.Alex Manisty, group head of Strategy & Innovation at DS Smith, says: “We support the aims of the Green Deal and the new legislation, but amendments that mandate reuse targets for paper and cardboard would compromise the European corrugated cardboard industry, embed a plastic economy into the single market, and hold the EU back on climate change.”

PPWR debates 
Amendments to the European Commission’s (EC) proposal for revisions to the PPWD are currently being debated by MEPs and member states, and proposed changes include introducing mandatory reuse targets for all materials.

According to the peer-reviewed analysis commissioned by Fefco, mandatory reuse targets applied to all materials would increase the amount of plastic packaging in circulation and establish a “plastic monopoly” on some market segments.

“Recycling and reuse both have a role to play in packaging circularity and should be complementary. Reuse systems should be used where beneficial for the environment, economy and society. Imposing mandatory reuse targets would only benefit the plastic industry,” says Manisty. 

“The EC recognized this by deliberately excluding corrugated cardboard from most of the mandatory reuse targets. We call on the European Parliament and member states to do the same.”

Last year, leaked proposals for the PPWR caused an outcry after showing watered-down reuse targets for plastics, which included a 20% drop for single-use plastics and a 10% drop for all other types of packaging. 

A pause on plastics progress? 
The injection of plastic into the EU economy shown in Fefco’s report would contradict years of progress in curbing the use of plastic packaging in the EU and internationally, says DS Smith. 

According to the company, if controversial amendments are adopted, PPWR would:

• Risk billions more pieces of plastic being added to the 91% of it that already remains un-recycled.
• Penalize the most widely recycled packaging material and pose serious threats to the functioning of the best-performing recycling system in the EU.
• Jeopardize the success of recent policy initiatives to curb plastics use in the EU, including the Single Use Plastics Directive.
• Contradict the objectives of the ongoing negotiations on the landmark international treaty to curb plastic pollution.

According to life cycle analysis data from Fefco, reusable plastic trays must be reused at least 63 times to be environmentally sustainable. In contrast, with a recycling rate of over 80%, corrugated cardboard is the most recycled packaging material.

In the last decade, DS Smith has developed a circular model that utilizes 100% recyclable paper-based packaging and has worked with some of the world’s largest brands to replace plastics in their supply chains with recyclable materials, creating more than 1,000 reuse design templates in situations where reusing cardboard makes sense.

A post-LCA world? 
At this year’s Packaging Innovations trade show, we spoke with circularity educator Paul Foulkes-Arrellano, who said that LCAs are often invalid and that companies commissioning them almost always receive the findings they want. 

“The LCA for a virgin material is one thing, but what happens to that LCA as you recycle multiple times?” he asked. “There is not a direct correlation between LCA figures and your planet friendliness.” 

“Smart packaging suppliers are looking at whole ecosystems; they’re looking at toxicity and renewables, both in energy and feedstocks. An LCA is a snapshot in time – it’s literally looking at one metric, whereas the metrics are four-dimensional if you add time.”

Edited by Louis Gore-Langton