The classic example is familiar from everyday life: The three-component cup is an excellent way of making ecological problems relating to packaging tangible. Aluminium, cardboard, plastic - all three can be wonderfully recycled, and yet in the end they almost always end up in residual waste or are only recycled to a small extent.
Whether yoghurt pots, sausage packaging or drinks cartons: environmental problems with packaging are easiest to communicate where they are visible to consumers on a daily basis. However, there is one major area that is much less recognised by the media: the sustainability of transport packaging. "In our experience, most product manufacturers look at their 'visible' packaging that ends up on the shelf. However, distributors of e-commerce packaging should also take a closer look when it comes to their packaging. This is handled almost identically to transport packaging, but the latter goes a whole step further and includes all semi-finished products, raw materials and internal transport in particular. And here the requirements are usually higher than for sales packaging," says Pacoon Managing Director Peter Désilets.
Transport contributes massively to packaging waste
A recent study by the GVM Gesellschaft für Verpackungsmarktforschung (Society for Packaging Market Research) shed light on just how big this issue is. The study, which focussed exclusively on transport packaging and its waste in the German wholesale and retail trade, came to the following conclusions, among others:
- Transport packaging contributes 5.5 million tonnes to the total 19.2 million tonnes of packaging waste each year - almost 30%.
- 68 per cent of transport packaging is made of paper, cardboard or carton (PPK, by weight), which means that it is generally easy to recycle.
- Wood is in second place with 22%, followed by plastic with nine per cent.
- PPK transport packaging accounts for around a fifth of total packaging consumption by weight in Germany.
In reality, however, there is much more to transport packaging than what is visible in the shops. It can be found wherever companies ship goods in large containers: in the chemical industry, for example, or at raw material suppliers for the food industry. The delivery of semi-finished products to contract bottlers also requires transport packaging. In addition, there are countless transports of packaged goods within companies or between their sites.
When the Packaging and Packaging Waste Regulation takes shape in the coming months and years, it will therefore be about much more than just three-component cups. Peter Désilets: "We see a major challenge in the requirements for reusable packaging. And in this context, ensuring hygiene and product quality. We are therefore working with organisations that have been focusing on certification and compliance with standards for years in order to ensure product quality and thus brand values."
The aim of the PPWR: what does the new EU packaging regulation want to achieve?
It is almost certain how quickly the PPWR packaging regulation will be implemented. In April 2024, the European Parliament reached an agreement on the draft PPWR of November 2022. If, as is expected, the individual member states in the Council give their final approval to the regulation in autumn 2024 or early 2025, it could come into force in every EU country as early as mid-2026. We have summarised the details of the obligations and rules for packaging and packaging waste that will then apply to the industry (such as the obligation to appoint an authorised representative or extended producer responsibility) for you here. However, the EU is essentially pursuing three objectives with the regulation:
1. reduction of packaging waste
The central intention of the PPWR is to significantly reduce the enormous amounts of packaging waste, which are currently still increasing. This can be achieved by restricting packaging to a regulated minimum or by promoting re-use and research and development into new materials. This main objective of the PPWR also creates new requirements for packaging design.
2. promotion of recycling and the hope of new recycling technologies
The new EU regulation on packaging sets minimum standards for recyclability. At the same time, there are minimum requirements for the proportion of recycled material in packaging, which should increasingly replace virgin plastics. How these recycling targets are to be achieved is still somewhat up in the air. At the same time, further investment must be made in the corresponding infrastructure for collection, sorting and new recycling technologies. Recycling is one of the most important approaches with which the EU wants to minimise the negative impact of packaging on the environment.
A great deal of hope lies in chemical recycling, but the reality does not currently look promising and behind the scenes there is a struggle over calculation methods that artificially present the expected quantities in a more attractive light - as in the fuel exempt approach, for example. Here, the quantities of recyclates, including those that come from many recycling sources other than packaging, are to be unilaterally allocated to packaging recyclates. This would allow much higher proportions of recyclates to be recognised than were actually used proportionally. It remains to be seen whether this favoured approach of the oil industry will go through.
3. harmonisation of the law
An important effect of the PPWR is that it replaces the corresponding national legislation. This means that the same rules will apply throughout the EU for the first time. However, individual countries can already go beyond these minimum requirements for the sustainability of packaging in the European Union.
How the PPWR deals with the issue of transport
In its objectives, the PPWR does not differentiate in principle between transport and other packaging solutions or their environmental impact. Nevertheless, it is worth taking a closer look at some specific plans for transport packaging that are to apply until 2030:
- The PPWR defines sales packaging ("primary packaging"), secondary packaging ("secondary packaging") and transport packaging ("tertiary packaging").
- For transport packaging, one of the aims of the regulation is to minimise empty space to a necessary minimum, which in future must not exceed 50%.
- Implementation of reusable packaging with a target of at least 40 to 100% for rigid packaging of all materials except cardboard. This requires the establishment or utilisation of EU-wide pools.
- The proportion of recyclate will play a major role in transport packaging.
- Recyclability must be ensured for single-use and reuse packaging at the end of life 'at scale' (i.e. in reality) in the countries.
- In general, hazardous goods are largely exempt, but these must also fulfil empty space requirements, as must cardboard packaging.
Further challenges lie in the details, depending on whether packaging is contact-sensitive or not, whether PET-based or other materials are used. There are also still some unanswered questions and definitions to be made. "Our customer projects show that virtually the entire product range is affected and for some requirements there is not much time to deal with the issues. Particularly for companies that are not only active in the EU, but also in neighbouring countries such as the UK, Switzerland, Norway or the Balkans, the question arises as to how far solutions can be harmonised in advance in order to simplify logistics flows," says Peter Désilets.
Packaging and the circular economy: a tailwind for fibre-based products
The European Commission has built in a clear steering effect in favour of packaging made of paper, cardboard and carton (PPC): PPK transport packaging is explicitly exempt from all reuse and refill targets in the PPWR if it is actually recyclable in the markets at minimum rates ("recyclable at scale") and does not exceed empty space requirements. GVM has analysed the potential impact of the regulation on the German market for corrugated board packaging in a detailed study. The authors of the study come to mixed conclusions. "There could also be a stronger trend towards reusable shipping packaging for corrugated cardboard packaging. Of course, this depends on the individual circumstances of the companies, but it could lead to cost savings," predicts Désilets.
What the Packaging and Packaging Waste Regulation already means for B2B today
While the requirements of the PPWR for B2C are already high, they are exceeded by those for the B2B sector. The issue becomes particularly complex in the area of reusable packaging.
In industry, transport and internal transport are part of sophisticated and largely optimised supply chains. Changes to packaging therefore inevitably mean that these systems have to be at least partially unravelled. In addition, most companies use a variety of different containers - just think of the numerous pallet types and formats - which argues in favour of the introduction of standardised reusable solutions. With corresponding consequences for established transport and intralogistics.
The changes are likely to be particularly complex when it comes to food and other transport goods with special hygiene requirements. Here, hygiene or cleaning certificates must also be taken into account in the planning if reusable containers are to be used.
In other words, many companies will need years to set up an appropriate loop that is not only PPWR-compliant but also economically viable. And time is running out. If the regulations come into force in 2030 as planned, there will only be a good five years left. "The entire logistics chain will be affected, both upstream and downstream. After all, the packaging that is imported into the EU - i.e. to companies based in the EU - is also affected. For a holistic solution, it is therefore also necessary to look at the incoming flows. Digitalisation is also important here, because in addition to the PPWR and proof of reusable circulation, these figures should also be included in the CSRD and represent the CO2 footprint. Standards are therefore important," Désilets advises affected companies to take an overall view of the supply chain.
Ambiguities in the packaging ordinance create problems
The structure of the regulation itself could also prove unpleasant for companies. Although the original English version of the PPWR comprises over 300 pages with an annex and the wording aims to be as precise as possible, both individual definitions and certain objectives remain unclear. In addition, there are repeated staggered deadlines and quotas. This can lead to confusion and uncertainty, as companies may find it difficult to precisely fulfil the requirements of the regulation. In addition, the large number of requirements is likely to lead to increased bureaucracy.
Last but not least, companies that use transport packaging could face a psychological problem. While packagers of consumer goods meet consumer expectations with environmentally friendly packaging and its disposal - and thus also contribute to their brand image - the only motivation left in B2B, apart from legal pressure, is intrinsic motivation. And this needs to be activated as quickly as possible. "We definitely see opportunities for savings if you take a closer look at packaging and companies see their materials not just as waste, but also as a resource. But at the moment, our customers - and presumably the market too - first want legal certainty for the coming years after the PPWR comes into force," says Désilets.
Tool tip:
To give companies a better overview of the various packaging requirements, the experts at pacoon have created graphical overviews and customised decision trees for packaging types and sectors. Companies can use these to easily understand which requirements apply to them and when. These decision trees can currently be ordered from pacoon in German or English for early birds for 790 euros plus VAT against invoice - simply send an email to ppwr@pacoon.de
Of course, the professionals at pacoon Sustainability Concepts also offer support with analyses, solution ideas and implementation.