HomePackaging and MOCAReduction, reuse and recycling of packaging in the EU. PPWR's proposal

Reduction, reuse and recycling of packaging in the EU. PPWR's proposal

On 22 November 2022, the European Commission adopted the PPWR proposal, Packaging and Packaging Waste Regulation, aimed at promoting the reduction, reuse and recycling of packaging (1). A draft regulation in line with the EU Action Plan on the circular economy, already approved by the European Parliament on 10 February 2021. (2)

1) Packaging and packaging waste, the proposed regulation

The proposed regulation under examination is aimed at updating the regulation of packaging and packaging waste placed on the internal market, including those arriving from non-EU countries (PPWR proposal, art. 4). In repeal of the dir. 94/62/CE as well as the reform of the reg. EU 2019/1020 and EU directive 2019/904).

Environmental labelling of packaging must also be harmonized at European level, in the face of that kaleidoscope of national rules which in practice still hinders the free movement of goods, causing confusion among consumers and serious burdens for businesses. (3)

2) Reduction, reuse and recycling of the packaging, the objectives

The packaging sector today it is the first user in the EU of virgin materials (for 50% of paper and 40% of plastic), as well as expressing 36% of municipal solid waste. The volumes of all packaging, recyclable and not, have also increased over the last few years.

Recyclable packaging often they are not valued, also due to the inadequacy or non-existence of the necessary infrastructures. (4) Greenhouse gas emissions and pollution are also increasing. (5) The Commission is therefore proposing a number of circular economy objectives.


The design of packaging must minimize its weight and volume. All empty spaces that have the sole purpose of increasing the visual perception of the product will no longer be allowed.

The 'empty spaces' prohibited include those filled with cut paper, air cushions, air bubbles, sponges and foam filling, wood wool, polystyrene, polystyrene shavings or other filling materials (Article 9).

The 'very light envelopes', generally used for fruit and vegetables, will have to be drastically reduced. Without tolerating a consumption of more than 40 envelopes/year per capita, by the end of 2025 (PPWR proposal, art. 29).


Reuse and r are in second place in the Lansink scale, the paradigm of the circular economy. The the packaging reusable or rechargeable is the one that allows a greater number of uses and movements. The refilling and emptying operations must ensure the integrity of the material and compliance with hygiene and safety standards (PPWR proposal, art. 10). The recharging or reuse system must function upon payment of a deposit by the user (art. 25).

Vending Machinestakeaway e food delivery are subject to the reuse targets set in two stages, by the beginning of 2030 and the beginning of 2040:

  • vending machines for hot or cold drinks. 20% of containers reusable or refillable by 2030, 80% by 2040,
  • convenience foods, 10% and 40%,
  • spirits and other drinks to go (except wine). 10% from 2030 and 25% from 2040,
  • wine, 5% from 2030 and 15% from 2040 (PPWR proposal, art 26).

4.1) Secondary and logistics packaging, ecommerce

The reuse of secondary packaging and logistics follows variously ambitious objectives. 90%, starting from 2030, for transport materials of large appliances. But only 30% for pallets and plastic crates, by 2030 (up to 90% by 2040).

It's incomprehensible the privilege to the operators of ecommerce, where (for products other than food) only 10% of packaging reuse is expected from 2030, 50% from 2040. (7) In any case, packaging, ça va sans dire, must be included in an effective and not hypothetical reuse system.

4.2) Deposit and return systems

The Member States will have to ensure the establishment of Deposit Return Systems (DRS), in particular on:

  • disposable plastic bottles with a capacity of up to 3 litres,
  • disposable metal beverage containers with a capacity of up to 3 litres.

Are excluded containers for milk, wines and spirits. A less understandable derogation is then envisaged in favor of those countries which recycle 90% of these materials or which present a plan for their recycling by the beginning of 2027 (PPWR proposal, art. 44). (8)


All materials of packaging, starting from 2030, will have to be recyclable. And the materials obtained from recycling must be of such a quality that they can constitute secondary raw materials (PPWR proposal, art. 6). Recycling will have to achieve the following intermediate and final objectives, by the end of 2025 and the end of 2030 respectively:

  • for all packaging, 65% (2025) and 70% (2030),
  • plastic, 50% and 55%,
  • wood, 25% and 30%,
  • ferrous metals, 70% and 80%,
  • aluminum, 50% and 60%,
  • glass, 70% and 75%,
  • paper and cardboard, 75% and 85% (PPWR proposal, art. 46).

5.1) Recycling plastic in MOCAs

Materials and objects in contact with food (MOCA) must contain minimum percentages of recycled material, with targets set for early 2030 and early 2040:

  • MOCA in PET (6), 30% by 2030, 50% by 2040,
  • packaging in plastic materials other than PET (with the exception of single-use drinks), 10% and 50%,
  • single use plastic beverage bottles, 30% and 65%,
  • other MOCAs, 35% and 65%.

By the end of 2026 the Commission may adopt implementing acts to establish the methods for calculating and verifying the share of recycled materials (PPWR proposal, art. 7).

5.2) Compostable bioplastics

The adhesive labels on fruit and vegetables, the 'very light envelopes' (see supra, par. 3), coffee pods and tea filters - within two years of the entry into force of the regulation - must be compostable 'under controlled industrial conditions in organic waste treatment plants' (PPWR proposal, art. 8). (9)

It is emphasized that compostable packaging must not affect the recyclability of other waste streams. It refers to the problem of the contamination of municipal plastic waste with bioplastics and the lack of plants capable of composting this material.

6) Environmental labeling

Environmental labelling of packaging, to which Chapter III of the regulation is dedicated, must finally be harmonized at European level. The labels will have to inform consumers about the composition of the the packaging and indicate if it is part of the return system. If so, the label will need to contain a QR code reporting on reusability, calculating trips and rotations and the availability of a reuse and collection system.

Further information they concern the share of recycled material, the method of disposal of the packaging or of the individual materials that make up the packaging as well as the role of the end users in contributing to waste prevention. On the other hand, brands or symbols that could mislead the consumer regarding the sustainability requirements of the packaging must not appear.

7) Italy, various reactions

various reactions to the Brussels proposal they registered in Italy. Where the average recycling rates are overall appreciable, as we have seen, (10) while reuse unfortunately belongs to history.

7.1) Contrary voices

Confindustria and Federdistribuzione, Conai and also a trade union (CISL), as well as the new Minister of the Environment, have criticized the choice of a regulation – that is, a system of uniform rules – instead of a directive (instead subject to national variables).

It would be of an 'ideological regulation', according to the Deputy Minister of the Environment Vannia Gava, according to which the deposit system would go to 'dismantle the system of consortia in Italy [..] which guarantee excellent levels of recycling with which Italy has exceeded the EU targets 9 years in advance'. (11) According to Stefan Pan, Confindustria's delegate for Europe, the proposed regulation 'freezes the packaging recycling strategy to focus on reuse' overwhelming 700 companies that would risk closure. (12)

Conai he even affirms the uselessness of the security deposit compared to the traditional differentiated collection system, as if reuse and recycling were the same thing. (8) And he estimates an expenditure of 2,3 billion euros per 100 Reverse Vending Machine. (13)

7.2) The value of the security deposit

Il Deposit Return System (DRS), apart from the above reactions, has instead proved to be very efficient in the EU countries where it has been adopted. For the recovery of packaging, especially for beverages. Slovakia has thus achieved the formidable result of 80% of plastic collection in one year.

The value of the deposit system with bail is in fact also recognized in Italy. The Virtuous Municipalities have dedicated a special campaign to which Great Italian Food Trade adheres. (14) In line, inter alia, with the PLEF Reuse Manifesto (Planet Life Economy Foundation). (15)

A study of Assobibe however demonstrates how the adoption of a RVM (Reverse Vending Machine) for every 2.073 inhabitants, as in Germany, would require Italy to need 25.534 machines, a quarter of those indicated by CONAI. (13)

7.3) Costs and benefits

Extended responsibility of producers means that they will have to bear the costs of disposing of the packaging of their products (PPWR proposal, art. 40. In line with art. 8 of directive 2008/98/EC). And the deposit system with deposit is also useful, among other things, for the selective collection of packaging materials (eg PET bottles).

The Member States after all, they already pay the EU 800 euros for each ton of non-recycled plastic waste. A public expenditure that cost Italy 2021 million euros in 744. That is to say more than the investment required to install the 25 RVMs proposed by Assobibe at the costs indicated by Conai. The system therefore has an economic convenience that adds to the environmental benefits.

8) Perspectives

The project  di Packaging and Packaging Waste Regulation is subject to the legislative codecision procedure. That is to say, it is necessary to reach an agreement between the European Parliament and the Council, in agreement with the European Commission. It is to be hoped that Italian politicians will soon learn to represent the collective interests of citizens, rather than the particular interests of individuals LOBBY.

Dario Dongo and Alessandra Mei


(1) European Commission. Proposal for a revision of EU legislation on Packaging and Packaging Waste https://environment.ec.europa.eu/publications/proposal-packaging-and-packaging-waste_en

(2) Dario Dongo, Giulia Torre. Circular economy, European Parliament resolution on the action plan. GIFT (Great Italian Food Trade). 26.3.21

(3) Dario Dongo, Giulia Torre. Environmental labeling of packaging, new rules at the start on 1.1.23. GIFT (Great Italian Food Trade). 6.10.22

(4) The recycling rate of plastic packaging is still very low compared to other materials. In addition to being the cause of microplastic pollution of the atmosphere, surface water and groundwater, soils. See Dario Dongo. Plastic in packaging and in agriculture, a problem for the environment and health. Report of the EU Court of Auditors. GIFT (Great Italian Food Trade). 26.1.21

(5) Dario Dongo, Alessandra Mei. Plastic and greenhouse gas emissions, an emergency to be prevented. Scientific study. GIFT (Great Italian Food Trade). 9.2.20

(6) Marta Strinati. Recycled plastic in food packaging, new EU regulation. GIFT (Great Italian Food Trade). 16.9.22

(7) Marta Strinati. The sustainability of ecommerce. The VVA study for the European Parliament. GIFT (Great Italian Food Trade). 12.12.22

(8) Reuse is a materials management practice that is unanimously favored over recycling, in a logic of circular economy and LCA (Life Cycle Assessment), since the latter postulates the construction of new packaging instead not required in the hypothesis of reuse

(9) It is no coincidence that the leader world of coffee capsules, Nespresso has finally moved in this direction. To put an end, better late than never, to a wholly unsustainable production of packaging. See Dario Dongo. Coffee in capsules, environmental costs and health risks. GIFT (Great Italian Food Trade). 26.4.19

(10) Marta Strinati. Packaging recycling, the Italian example and new challenges. GIFT (Great Italian Food Trade). 14.12.21

(11) Packaging, Deputy Minister Vannia Gava: ideological regulation inadequate measures that condemn Italian excellence. https://www.mite.gov.it/notizie/imballaggi-viceministro-vannia-gava-regolamento-ideologico-misure-inadeguate-che-condannano?fbclid=IwAR2EZbjyQB2EUNGf6sZczLhJ7tZYSkm0aHr1bV0oSmuly2c9BumAjeva8iA Ministry of the Environment and Energy Security. 30.11.22

(12) Sarah Deganello. Packaging, on the new EU rules, companies aim for slippage. https://www.ilsole24ore.com/art/imballaggi-nuove-regole-ue-imprese-puntano-slittamento-AEooaNDC The Sun 24 hours. 2.11.22

(13) The Security Deposit at the center of the public debate is excellent news, despite everything. https://buonrendere.it/2022/11/28/il-deposito-cauzionale-al-centro-del-dibattito-pubblico-e-unottima-notizia-nonostante-tutto/ With good returns. 28.11.22

(14) Marta Strinati. Security deposit system for beverage bottles. The campaign of the Virtuous Municipalities. GIFT (Great Italian Food Trade). 13.3.22

(15) Marta Strinati. Encouraging the reuse of food containers, the PLEF Manifesto. GIFT (Great Italian Food Trade). 23.6.22

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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.

Alessandra Mei
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Graduated in Law from the University of Bologna, she attended the Master in Food Law at the same University. You participate in the WIISE srl benefit team by dedicating yourself to European and international research and innovation projects.

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