Open letter to the EU Presidents from the cross-sector European business alliance, Together for Sustainable Packaging, to pause the proposal on PPWR

24 April 2023

Dear President Metsola,
Dear President Michel,
Dear President von der Leyen,

For several months we have followed, with increasing concern, the progress of the proposal on a packaging and packaging waste regulation (PPWR). We are businesses from a wide cross-section of the HORECA European economy – generating billions of euros for the EU economy and millions of jobs. While we fully support the overall goals of the Green Deal, we are worried about the unintended consequences of the proposed PPWR legislation for the environment, the economy, food safety and consumers.

It is because of these concerns that we have decided to join forces to create a new cross-sector alliance: Together for Sustainable Packaging.

While the Commission has conducted an initial impact study, we feel it currently lacks depth and in particular does not consider economic and food safety aspects. However, there are now several high-level independent studies, conducted by highly recognised experts such as Kearney, and Ramboll, into the implications of the PPWR. All of them reach alarmingly similar conclusions.

The idea of using packaging over and over, as opposed to just once, seems the obvious solution – but it’s not as simple as that. For reuse models to have a positive environmental impact, consumers need to return them – again and again and again.

By their very nature, reusables need to be washed every time they are used. That requires significant incremental energy and water. Europe’s water supply is already under stress. Indeed, the Commission recognises water scarcity and drought as a priority in the Green Deal; the issue is highlighted in several major European strategies, including the 2020 Circular Economy Action Plan. But reusable packaging mandates could result in the consumption of an additional 4 billion litres of water each year.^[1]

Washing and drying requires more energy, and so could dramatically increase greenhouse gas (GHG) emissions. Figures show that a shift to 100 percent reusable packaging by 2030 could increase emissions by nearly 50 percent for dine-in restaurants.^[2]  Another study puts the figure even higher at 177 percent^[3] (84 percent of greenhouse emissions in dine-in restaurants are caused by washing and drying^[4]).

A similar shift for takeaway could increase GHG emissions by 260 percent.^[5] Smaller restaurants unable to cope with new requirements, would need centralised cleaning facilities, leading to an increased transport infrastructure and a significant environmental impact – for takeaway alone, transportation of reusables back and forth could add 54 percent to CO₂ emissions.^[6]

Packaging isn’t just for show either – it plays a fundamental role in protecting our food. Multiple studies on the hygiene challenges of replacing single-use packaging with reusables find that circular reuse systems present greater risks of cross-contamination due to multi-location cleaning, sanitation and storage standards and transportation.^[7]

Crucially, packaging also allows for convenient and safe transportation. It facilitates delivery to areas where fresh food is in short supply, ensuring a longer shelf-life, guaranteeing the highest standards for consumers, and reducing food waste. This is essential, as almost 30 percent of food is lost or wasted, contributing to approximately 10 percent of total CO₂ emissions globally.^[8] 

Particularly worrying are the findings that reuse models could lead to a sharp increase in plastic materials. Reuse targets proposed in the PPWR could create four times the amount of plastic packaging waste for dine-in restaurants. This rises to 16 times for takeaway.^[9] That’s a lot more plastic instead of renewable, recyclable paper and cardboard – the opposite of what the EU wants to achieve.

The studies clearly show recyclable fibre-based packaging has the greater potential to benefit the environment, economy, food safety and consumers.

These are detailed reports, conducted by experts and commissioned by leading companies and associations who share the EU’s climate goals, and are innovating to try to achieve them – but who are concerned about the possible negative impact of well-meaning but potentially flawed legislation.

Any law should take into account the specific needs of complex business sectors, and the right packaging solutions. We believe this means allowing a mix of solutions.

A rush to a simplified solution for a complicated situation will only make the problem worse. It is for this reason that we are asking you all to pause, assess and reflect on the increasingly significant data, and upon the best way forward. We also ask that member countries not press ahead with their own legislation – this will lead to even greater complication for businesses and consumers, and could risk fragmentation of the single market.

Only by doing this we believe, can you achieve the broad goals of the EU Green Deal that both you and we wish to see enacted, before the unintended consequences of the well-meaning PPWR legislation have a lasting and negative impact on the environment, the economy and on consumers’ lives.