Rewording: Interpreting European Union packaging laws

When we first launched Together for Sustainable Packaging — an alliance of businesses and associations from a wide cross-section of the food and hospitality European economy, known as HORECA (hotel, restaurant, catering) — in April this year, the debate around the EU’s Packaging and Packaging Waste Regulation (PPWR) proposal was still in its infancy. That is no longer the case. It has become one of the most frequently discussed policy issues of recent memory, and not without reason. The implications of the proposals reach far into the EU economy and business sectors, and will hugely affect all consumers across Europe and beyond. 

The alliance was created in response to concerns about the potential negative effects of the proposed PPWR legislation on the environment, economy, food safety, and consumers. Although the discussion has progressed, we remain worried about the focus on reusable packaging instead of recyclable options made from fiber, and the potential repercussions.

The concept of using an item repeatedly may seem like the obvious solution, but it’s not as simple as it appears. According to research conducted by global management consultancy Kearney, reusable packaging needs to be reused 50 to 100 times in order to have a positive impact on the environment compared to a single-use paper cup. However, current market trends suggest that we are far from achieving this level of reuse. This means that the use of reusable items will result in a significant increase in plastic waste in Europe, as stated in Kearney’s report “No Silver Bullet.” The proposed reuse goals in the PPWR will lead to four times more plastic packaging waste for dine-in and 16 times more for takeaway.

In recent times, Europe has experienced severe droughts, forest fires, and heatwaves, contributing to water scarcity. EU data indicates that almost one-third of its citizens are impacted, with forecasts predicting the situation to worsen. Despite efforts by EU policymakers to conserve water and alleviate stress on infrastructure, the implementation of PPWR regulations for packaging may exacerbate local water scarcity. This is because reusable packaging requires frequent washing, shifting the demand for water from a few production sites for single-use fiber packaging to all restaurant locations in Europe, many of which are located in areas with limited water supply. A life-cycle assessment conducted by Ramboll, which is a peer-reviewed and ISO-verified study, compared paper and reusable packaging for on-site consumption in quick-service restaurants and found that reusables consume 3.4 times more water than single-use paper packaging.

The European Commission has identified water scarcity and drought as a top concern in the Green Deal, with a particular focus in various major European initiatives, such as the 2020 Circular Economy Action Plan. However, implementing reusable packaging requirements may potentially lead to a significant rise in overall water consumption, as indicated by Ramboll’s findings of up to 267 percent.

The use of plastic containers that can be used again, as well as the processes of cleaning, drying, and moving them, consume more energy and contribute to higher levels of greenhouse gas emissions. According to the Kearney research, a complete transition to 100 percent reusable packaging by 2030 could raise emissions by 50 percent for dine-in services and up to 260 percent for takeout orders.

Packaging serves a crucial function in safeguarding our food and ensuring consumer safety, rather than just being aesthetically pleasing. Several research studies have shown that switching from disposable packaging to reusable systems can pose hygiene challenges and increase the risk of cross-contamination due to the need for multiple cleaning, sanitation, and storage protocols at different locations, as well as during transportation. Furthermore, packaging enables easy and secure transportation, making it possible to deliver fresh food to areas with limited access and ensuring that consumers receive products of the highest quality.

However, our argument does not support a singular resolution for the EU’s issue with packaging waste. We believe in a combination of solutions that considers the unique requirements of various industries. It is essential that any legislation considers the appropriate packaging options for each circumstance. Therefore, we urge for equal treatment of fiber-based packaging, as it is recyclable and the most suitable choice in our sector for the well-being of the environment, economy, food safety, and consumers.

Together for Sustainable Packaging and others have successfully stimulated a valuable debate, but decisions as important as these should be based on science and evidence and not merely ideology. As a sector, HORECA generates billions of euros for the EU economy and creates millions of jobs. We all want the best for the planet and the right solutions for society, but we must not rush, tempting though it is, because if we do, we risk making the problem worse — and as this year’s climate events have shown us, we cannot afford to make that mistake.