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Criticism of impact assessment on EU Packaging Regulation

An impact assessment by the European Commission is currently being controversially discussed by associations, MEPs and NGOs, Euractiv reports.


The draft EU Packaging Regulation, presented in November 2022, proposes among other things to ban single-use packaging in restaurants from 1 January 2030 and to promote the use of reusable takeaway packaging. According to Euractiv, industry and right-wing MEPs criticised the bill's reusable targets, while environmentalists, left-wing and green MEPs said the planned measures did not go far enough. The Commission's mandatory cost-benefit analysis was criticised for, among other things, not distinguishing between different packaging materials and failing to analyse the economic, health and environmental impacts of the proposed targets. A coalition of European associations representing the food, brewing, beverage, glass, metal and PET recycling industries had warned in a joint letter in March that there was no certainty that the proposed measures would deliver the desired benefits and could even have a negative impact on the environment, consumer behaviour and many businesses operating in the EU. According to industry associations, the law threatens to backfire because the impact assessment has mixed all EU countries, sectors and packaging materials, leading to unrealistic benchmarks. The EU Commission, on the other hand, considered its approach to be purposeful. It had used a transparent methodology and a "systematic approach" to assess the environmental impact of packaging over its entire life cycle. Industry also criticised the Commission's approach for grossly underestimating the costs of the packaging reuse targets in its assessment. According to the Commission, the direct costs for all reusable systems amounted to 4 billion euros and an additional 523 million euros for the establishment and expansion of deposit return systems. According to a study by the auditing firm PricewaterhouseCoopers (PwC), to which the industry alliance refers, the conversion of 20 per cent of PET bottles for carbonated soft drinks to reusable alone would already cost 18.7 billion euros. The industry is also questioned the reusable targets because of possible health and hygiene concerns of consumers. Lack of confidence in the safety of reuse systems could undermine the PPWR targets. In contrast, environmental organisations argued that there were already functioning reuse systems in several Member States, such as for beverage bottles in countries like Belgium and Germany, with no unintended consequences for hygiene and consumers. The proposed regulation would also contain provisions to ensure safety and hygiene. However, the industry warned that although well-managed reusable systems could provide these guarantees, far-reaching obligations could undermine this.

Further information: to download the impact assessment report of the EU Commission, to the position paper of the industry coalition


  • (2.6.2023)
  • Photo: Fotolia

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