New European packaging law

Boosting the market for moulded pulp

After years of negotiations between industry and EU law makers, the Packaging and Packaging Waste Regulation (PPWR) has been finalized.

The law aims to reduce the mountains of waste being produced in Europe by pushing businesses to make their packaging fully recyclable by 2030. This implies design for recycling and re-use, favouring natural secondary resources and turning away from overpackaging.

The new law is particularly geared to single-use plastic packaging while promoting more sustainable materials, according to “polluter pays” and “waste hierarchy” principles. Set up as a regulation rather than a directive, the PPWR requires EU member states to craft their own national legislation to reach – or even over-achieve – the prescribed objective to cut packaging by 15% by 2040. Pending formal approval by the European Council and its publication expected in January 2025, the rules of the PPWR will come into effect as of mid-2026.

What does the new regulation mean for the European moulded pulp industry?

All in all, the PPWR generates a much welcome tailwind for our members to create a circular economy by replacing single-use plastic packaging by moulded pulp made from agricultural secondary resources and recycled paper and cardboard. It provides legal planning certainty for companies and investors to move away from plastic to truly sustainable packaging formats.

As stated in the EMPPA position paper, the recycling targets for paper and cardboard of 75% by 2026 and 85% by 2031 are realistic and achievable. Consumers can expect to see more fibre-based packaging on supermarket shelves in the upcoming years, as single-use plastic packaging like for fresh fruit and vegetables will be banned in the EU from 2030, to give only one example.

The paper and horeca industries were able to secure the concession that only 10% of foodstuffs sold must be offered in reusable containers. Also exempted from reuse targets is transport packaging made of cardboard. The good news for producers of thermoformed and processed moulded fibre products (type 3 and 4) is that coffee capsules are considered as packaging (rather than a proper product) and as such are allowed for recycling via the bio-waste stream. According to the new law, EU member states are flexible to decide whether to “allow the use of compostable packaging for coffee, tea or other beverage system single-serve units if composed of other than metal packaging material”.

The clock is ticking for polystyrene

In addition to the Single Use Plastic Directive (SUPD), the PPWR introduces recyclability performance grades based on “design for recycling” criteria combined with deadlines that will result in certain packaging products getting banned from the European market altogether. From 2035, packaging will not be considered recyclable and therefore get sanctioned if it does not comply with “recyclability at scale” requirements, meaning if it cannot be collected, sorted and recycled by established waste management system in an economically viable way. In order to give economic operators time to adapt, the deadline will be January 1st, 2030, for products that are not recycled by at least 70% in total volume and member state (category C = technically non-recyclable) and January 1st, 2038, for products recycled by less than 80% (category B).

At the top of the list are packaging products made of polystyrene (PS/EPS/XPS), due to their recyclability performance grade and toxicity.

Design for
Recycling performance
2030
  • A: higher or equal to 95%
  • B: higher or equal to 80%
  • C: higher or equal to 70%
  • Banned: lower than 70%
Recycling
"at scale" performance
2035
  • A: higher or equal to 95%
  • B: higher or equal to 80%
  • C: higher or equal to 70%
  • Banned: lower than 70%
Recycling
"at scale" performance
2038
  • A: higher or equal to 95%
  • B: higher or equal to 80%
  • Banned: lower than 80%

Thresholds for EPS and other materials

Member States can ask for a renewable five-year derogation if they can demonstrate that they are on track to achieve the targets and will exceed them by 5%. Going forward, the regulation will require several secondary legislations to be developed by the European Commission.

The prospect that eco-modulated extended producer responsibility (EPR) fees will be linked to recyclability performance grade based on recyclability assessment is also positive news. Once harmonised criteria are set up across the EU, eco-modulated EPR fees will become a “pro-bono”-kind of financial incentive for customers to choose easily recyclable packaging, such as moulded fibre, instead of plastic: the better the recyclability, the lower the fee and operational costs.  

Turning challenges into opportunities

Plastic or not, what goes for every type and format of packaging is the proof of recyclability performance in regard to eco-design and recyclability-at-scale. The challenge is to measure the impact of a packaging product throughout its life cycle, up and down the supply chain, manage it as a valuable resource rather than a liability, and provide auditable data for better comparability and reporting purposes.

On the winner side will be packaging made of non-toxic mono-materials that can be recycled at low cost in a closed-loop system, assuring circularity. Moulded pulp is in pole position to make the running. The prize will be a higher market share through substitution of plastic, competitive advantages through lower EPR fees and green public procurement, along with increased brand reputation and recognition by investors. EMPPA will continue to help seize these opportunities through advocacy at the European level.

You want to join as a Member of EMPPA?

Please find our membership application form as PDF for download on the left. Send it together with the SEPA form to the known email address: info@emppa.eu

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