PFAS ban, recyclability and recyclates: New Requirements of the PPWR

The new EU Packaging and Packaging Waste Regulation (PPWR) is a cornerstone of Europe’s circular economy strategy and imposes far-reaching requirements on businesses. A central focus is on eliminating problematic substances, ensuring the recyclability of all packaging, and mandating the use of recyclates in plastic packaging. These provisions, enshrined in Article 5 (PFAS ban), Article 6 (Requirements for the recyclability of packaging), and Article 7 (Minimum recycled content in plastic packaging) of the PPWR, are crucial for the transformation towards a more sustainable packaging market.

PFAS ban (Art. 5): Implications for packaging

A core component of the PPWR is the PFAS ban and the general prohibition of “substances of concern” in packaging. Article 5 of the PPWR prohibits the intentional addition of certain hazardous substances in packaging once the relevant thresholds are exceeded. This particularly targets per- and polyfluorinated alkyl substances (PFAS), which are increasingly scrutinised due to their persistence and potential health risks.

Specific implications:

• General prohibition: The PPWR aims to prohibit the use of these substances in all packaging to prevent their release into the environment and recycling streams.
• Timeline for application: The obligation applies from 18 months after the PPWR enters into force, provided the relevant thresholds and test methods are established. This is particularly relevant for food contact packaging.
• Challenges: For industries that currently rely on PFAS or similar substances for specific properties like grease and water resistance (e.g., in fast-food packaging, pizza boxes), this necessitates finding alternative materials and coatings. The transition requires significant research and development investments to continue ensuring functionality and safety.

The PFAS ban is a clear signal from the EU to eliminate harmful chemicals from the packaging cycle and improve product safety and environmental compatibility of packaging.

Requirements for the recyclability of packaging (Art. 6)

The PPWR sets the ambitious goal that all packaging placed on the EU market must be demonstrably recyclable from January 1, 2030. Article 6 lays down the essential requirements for the recyclability of packaging and forms the basis for “Design for Recycling.”

Key requirements:

• Design for Recycling: Packaging must be designed in such a way that it can be collected, sorted, and recycled on a large scale. This includes aspects such as material choice (e.g., mono-materials), the separability of components (e.g., labels, closures), compatibility with existing recycling processes, and the absence of recycling impediments.
• Performance grades: The PPWR introduces a system of recycling performance grades (A to D) that assess how well packaging is actually recyclable. From 2030, packaging must achieve performance grade A (recyclable on a large scale) or B (recyclable, but improvements needed).
• Verification and classification: Conformity with recyclability requirements must be demonstrated through conformity assessment procedures. The classification of performance grades will be determined by technical regulations yet to be issued by the Commission.
• Waste streams: A minimum availability of infrastructure for the collection, sorting, and recycling for specific waste streams (plastic, wood, ferrous metals, aluminium, glass, paper/cardboard) is required.

The requirements for recyclability are crucial for establishing a functioning circular economy. Companies must critically review their packaging portfolios and, if necessary, redesign them to meet the 2030 requirements.

Minimum recycled content in plastic packaging (Art. 7): Challenges and solutions

Another central aspect of the PPWR is the obligation to use a minimum recycled content in plastic packaging. Article 7 sets binding quotas to ensure that a significant proportion of plastic in new packaging comes from recycled material.

Overview of quotas (examples for 2030 and 2040):

• From January 1, 2030:
  • At least 30% recycled content for plastic packaging with food contact (if recyclable).
  • At least 10% recycled content for other plastic packaging.
  • Specific targets for beverage bottles (e.g., 25% for PET bottles).

• From January 1, 2040:
  • At least 60% recycled content for plastic packaging with food contact.
  • At least 55% recycled content for other plastic packaging.

Challenges:

• Availability and quality of recyclates: The demand for high-quality recyclate, especially for food contact materials, often exceeds supply. The production of post-consumer recyclates in sufficient quantity and quality is a major hurdle.
• Technical feasibility: For certain applications, particularly in the food and pharmaceutical sectors, the technical requirements for the purity and safety of recyclates are extremely high. Innovative recycling technologies (e.g., chemical recycling) could play a role here but need to be scaled.
• Costs: The use of recycled plastics can in some cases be more expensive than the use of virgin material, which can affect product costs.

Solutions:

• Investments in recycling infrastructure: The expansion and modernisation of collection, sorting, and recycling facilities are crucial to increase the availability of high-quality recyclate.
• Design for Recycling: Better recyclability of the packaging itself facilitates the recovery of high-quality recyclate.
• Supply chain collaborations: Close cooperation between packaging manufacturers, brand owners, and recyclers is necessary to develop demand-driven recyclate solutions.

The PFAS ban, the recyclability requirements, and the quotas for minimum recycled content are not only regulatory hurdles but also drivers for innovation and sustainability in the packaging industry. Companies that invest early in adapting their packaging strategies will benefit in the long run.

Stay tuned for the continuation of our blog series, where we will delve into the regulations concerning bio-based and compostable packaging under the PPWR.