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New EU rules risk flood of new plastic packaging and contradict years of progress to curb plastic

The EU is close to agreeing new rules around packaging and packaging waste, but amendments proposed to the Commission’s proposal risk flooding the market with millions of tonnes of new plastic and rolling back a decade of measures to curb plastic use.

Amendments to the Commission’s proposal for a Packaging and Packaging Waste Regulation (PPWR) are being debated by MEPs and Member States, and proposed changes include introducing mandatory reuse targets for all materials.

According to independent peer-reviewed analysis commissioned by FEFCO1, mandatory reuse targets applied to all materials would increase the amount of plastic packaging in circulation and establish a plastic monopoly on some market segments.

Transport and e-commerce corrugated packaging
Transport and e-commerce corrugated packaging

For example, if applied to the transport and e-commerce corrugated cardboard packaging categories, 8.1bn new plastic crates weighing 12mn tonnes will be needed to achieve a reuse target of 90% by 2040, and 16bn litres of water will be needed to wash just half of them for reuse2.

This huge injection of plastic into the EU economy contradicts years of progress in curbing the use of plastic packaging in the EU and internationally.  

If the controversial amendments are adopted, PPWR would:

  • Risk billions more pieces of plastic being added to the 91%3 of it that already remains un-recycled;
  • Penalise the most widely recycled packaging material and pose serious threats to the functioning of the best performing recycling system in the EU
  • Jeopardize the success of recent policy initiatives to curb plastics use in the EU, including the Single Use Plastics Directive;
  • Be in contradiction with the objectives of the ongoing negotiations on the landmark international treaty to curb plastic pollution.

We support the aims of the Green Deal and the new legislation, but amendments that mandate reuse targets for paper & cardboard would compromise the EU corrugated cardboard industry, embed a plastic economy into the market, and hold us back on climate change.

Alex Manisty
Group Head of Strategy & Innovation, DS Smith

“Recycling and reuse both have a role to play in packaging circularity and should be complementary. Reuse systems should be used where beneficial for the environment, economy and society. Imposing mandatory reuse targets would only benefit the plastic industry. The Commission recognised this by deliberately excluding corrugated cardboard from most of the mandatory reuse targets. We call on the European Parliament and member states to do the same.”

According to life cycle analysis data from FEFCO4, reusable plastic trays must be reused at least 63 times to be environmentally sustainable. In contrast, with a recycling rate over 80%, corrugated cardboard is the most recycled packaging material, and the industry is committed to ambitious decarbonization targets.

In the last decade, we have developed a circular model that utilises only 100% recyclable paper-based packaging. And we have worked with the world’s largest brands to replace plastics in their supply chains with recyclable materials. More than 1,000 reuse design templates have been created, as well as reuse pilots explored and partnerships made in situations where reusing cardboard makes sense.


1 FEFCO - European Federation of Corrugated Board Manufacturers

2 FEFCO data. Sources: Plastics Europe, IFCO, Albrecht 2021, FEFCO, Investopedia

3 Plastic pollution is growing relentlessly as waste management and recycling fall short, says OECD 

4 FEFCO - Recycling vs Reuse for Packaging: Overview of study results (May22)RAMBOLL - Comparative Life Cyle Assessment (LCA) - Packaging solutions for the food