The European Recycling Industries' Confederation (EuRIC) welcomes several aspects of the EU Council’s negotiating position on the Packaging and Packaging Waste Regulation (PPWR), which was adopted at the meeting of the Environment Council earlier this week. However, EuRIC says "additional steps” are necessary to enhance packaging circularity.
The recycling industry umbrella association said there were several positive elements in the "general approach” (negotiating position) agreed by the Council. These included "maintaining the Commission’s proposal for packaging waste reduction targets, and allowing Member States to introduce their own, higher waste prevention targets”.
EuRIC also calls for "packaging with high circularity performance” to be exempted from the legislation’s targets for packaging waste reduction and reuse. It "strongly welcomes” the exemptions for cardboard packaging in the provisions regarding reuse, which were originally proposed by the European Commission and are now supported by the Council.
Request for greater clarity on bioplastics
The association also welcome the Council’s maintenance of the 2030 and 2040 targets for the minimum content of recycled material in plastic packaging. However, EuRIC "urgently requests” greater clarity on the provisions for bioplastics. "We maintain a strong stance against mixing biobased plastic feedstock with recycled content targets,” the organisation said.
The text adopted by the Council as its negotiating position would require the European Commission to review "the state of technological development and environmental performance of bio-based plastic packaging” within six years of the entry into force of the PPWR. Based on that assessment, if appropriate, the Commission is to propose targets to "increase the use of biobased plastic in packaging through a hierarchical approach” which prioritises recycled content over biobased plastic.
Another important topic for EuRIC is a free market for sales of recycled material. The association was therefore pleased that Council does not want to give certain producers preferred access to recycled material, for example through rights of first refusal. The Council’s decision to prevent prioritised access to recycled material "[safeguards] market fairness and recycling industry competitiveness”, EuRIC said.
Regret about deletion of eco-modulation.
In its original proposal, the European Commission had proposed to modulate the fees that producers must contribute to extended producer responsibility (EPR) schemes based on the recycled content of their plastic packaging. EuRIC "strongly regrets” that Council has deleted this provision from its negotiating position. "Acknowledging recycled content levels in packaging is essential for increasing the EU’s packaging waste recycling. It is imperative that this consideration be made mandatory across all the EU27, ensuring harmonised criteria throughout the internal market,” the association said.
Watered-down criteria for recyclability
EuRIC also criticises the "watering down” of the criteria for evaluating whether packaging can be recycled at scale. To meet the "at scale” definition, the Commission’s proposal requires recycling rates of at least 30 per cent for wood and between 55 and 85 per cent for other packaging materials. In its negotiating position, the Council maintains the 30 per cent quota for wood but reduces the targets for all other materials to 55 per cent.
The Council’s position would also make it easier for member states to exempt themselves from the planned rules requiring the establishment of deposit return systems (DRS) for single-use beverage packaging made of plastic and metal. The member states want exemptions for the DRS requirement if they achieve a separate collection rate of more than 78 per cent for these packaging types as of 2026. This is significantly lower than the Commission’s proposed threshold of more than 90 per cent in 2026 and 2027.
EuRIC noted the "additional flexibility” this change gives to member states, but firmly believes in the necessity of setting separate collection rates for all packaging materials to increase collection volumes.
The next step in the legislative process will be the trilogue negotiations, which bring together representatives of the Council and the European Parliament in talks chaired by the European Commission. The parties will work to reach compromises in the areas of the PPWR where the two EU legislative bodies hold differing positions, with the aim of finalising the text and adopting the Regulation prior to the EU elections.
With the start of the trilogue negotiations scheduled for January, EuRIC stressed its "commitment to working closely with all stakeholders to ensure that the final text not only provides all the key enablers for a circular economy, but also addresses key concerns for the recycling industry”.