Today the European Commission released a proposal for a Regulation on Packaging and Packaging Waste. The harmonisation of EU rules is required to protect the EU common market and avoid fragmentation and as such the revision of the directive into a regulation is a step in the right direction. However, Copa and Cogeca regret the fact that some of the targets, notably for recycled plastic packaging content and reuse/refill, overlook the reality on the ground and the implications, in particular for wine, fresh fruit and vegetable producers in a difficult socio-economic context.
EU farmers and agri-cooperatives are already making strides to improve plastic management systems, reduce plastic packaging and food waste by taking eco-design approaches and using environmentally friendly packaging and materials. These efforts should be supported and not thwarted by requirements and targets that are not only unfeasible but downright counterproductive.
The proposed mandatory recycled content targets for plastic packaging is not realistic and runs against the objectives of encouraging the uptake of consumption of more fruits and vegetables. Moreover, they fail to recognise the role played by packaging in ensuring food safety and quality. The proposed ban on the single use packaging for less than 1.5kg of fresh fruit and vegetables is disproportioned regardless th e material uses and life-cycled analysis th at demonstrate th e sustainability of the packaging and does not bear in mind the diversity of produce within the sector. The proposed requirement for the compostability of stickers does not refer to any specific standard. Restrictions without workable alternatives will result in protection and shelf-life being drastically reduced, as well as hygiene, organoleptic quality and traceability being compromised. In th is ligh t, th e restrictions would not improve th e supply ch ain’s environmental impact; conversely, they would increase it as well as food waste.
The proposal sets mandatory reuse/refill targets for wine. Besides wine being enjoyed across the globe, which renders bottle collection as very hard to achieve, the mandatory reuse/refill targets also pose significant hygiene risks. With bottles often being used by consumers for different purposes; collection, cleaning, and reuse constitute a very energy-, fuel- and water-intensive exercise that increases the risk of entry and development of pathogens. It is for this reason that reuse is not recommended in the reference health guide of the wine sector. Moreover, any mandatory reuse targets would run counter to th e recycling objective to achieve packaging circularity. On top of this there is the logistical complexity of organising mandatory collection and transportation, as well as the lack of adequate infrastructure.
Furthermore, the aforementioned targets and requirements do not factor in the challenging socio-economic context and the repercussions for producers. The war in Ukraine has exacerbated the difficulties with access to packaging material due to reduced availability and affordability of raw materials. This is compounded by the surging costs of inputs, energy, and food, as well as supply ch ain disruptions. Against th is backdrop, restrictions and or/new requirements entail substantial extra costs which producer organisations are not able to afford or pass on to consumers. This is true in particular for wine, fresh fruit and vegetables for which hygiene as well as export orientation are not thoroughly considered.
Lastly, innovation can play a key role in achieving a true circular economy, which is the ambition of the EU. Not recognising and promoting bio-based content in the PPWR, alongside recycled content, is a missed opportunity, for it can serve to reduce EU’s dependency on fossil resources and enhance bioeconomy, stop the current trend of over packaging and excessive waste, and ultimately deliver better economic and environmental outcomes.
Artigo publicado originalmente em Copa Cogeca.
