The packaging industry is undergoing a dramatic shift as the global economy moves toward circularity and sustainability, which means large-scale implications for the fast-moving consumer goods (FMCG) sector.
Landmarks of the current legislative environment include the EU’s Packaging & Packaging Waste Directive (PPWD), which specifies that 65% of packaging waste by weight should be recycled by 2025, and 70% by 2030, including 50 and 55% of plastic waste, respectively.
Of course, there are many other legislative instruments and specific targets to consider, which is precisely why this topic is so crucial – members of the packaging value chain need as much information as possible in order to make the best decisions for their organizations, as well as for our planet. As they prepare for and navigate the upcoming legislative changes, the following four points are the most important for FMCG managers to bear in mind:
1. The complete picture is still unavailable
The European Commission will publish two major legislative packages — on the circular economy and tackling pollution — in the second half of this year, according to a drafted College of Commissioners agenda dated June 20 and seen by POLITICO.
A second circular economy package, initially slated to be published on July 20, is now scheduled for November 16, the Commission having presented its first draft of circular economy legislation in March. The new package includes six proposals: a proposal for a regulation on substantiating environmental claims; a policy framework for bio-based, biodegradable and compostable plastics; a review of the Packaging and Packaging Waste Directive; a revision of EU chemicals legislation; new measures to reduce the release of microplastics in the environment; and a proposal on promoting the right to repair.
However, there are other important instruments to keep an eye on, including the EU Waste Framework Directive, Single-Use Plastics Directive, and the Ecodesign for Sustainable Products Regulation. In addition, national governments and individual brands will continue to develop their own requirements, guidelines, and recommendations, creating a highly complex environment for all actors in the packaging value chain.
2. Every voice matters
Product managers, brand managers, and other professionals who work with packaging directly are often much more knowledgeable about the industry than legislators. Fortunately, this is well understood at the EU level, and the European Commission (EC) seeks industry input at every opportunity. Still, this doesn’t always prevent the drafting of legislation that misses the mark, especially when it comes to deeply complex matters such as how recycling contributes to sustainability.
In other words, FMCG managers should do their best to make their voices heard by participating in stakeholder organizations and meetings where legislative plans are disclosed and transparency is established around specific targets and rationales. In doing so, they can identify potentially harmful legislation – for example, directives that inadvertently undermine ongoing, effective sustainability measures – and recommend better alternatives.
Maximizing communication throughout the packaging value chain – and involving as many stakeholders as possible – is key to both creating and navigating a beneficial legislative environment.
3. Recycling is only one aspect of sustainable packaging design
The most important consideration in packaging design is always functionality. Protection of a product throughout its life cycle – including distribution, storage, sale, transport, and use – cannot be compromised even when optimizing for recyclability. If a poorly designed package leads to food waste or product failure, for example, the net effect on the environment, economy, and brand is always negative – no matter how sustainable the package is from a recycling standpoint. This is yet another reason for brands to take a multi-disciplinary approach to packaging that considers the various impacts a particular packaging choice may have, both in recycling and in the bigger picture of sustainability.
4. Recycling infrastructure is evolving and location-dependent
The recyclability of a package depends on much more than just the materials included in its design. While guidelines are not standardized, a package is typically only considered recyclable if it can feasibly be collected, sorted, processed, and repurposed in an economically scalable way. In other words, assessing the recyclability of a package also requires knowledge of localized collection and recycling infrastructures. This means that the potential for recyclability in a region changes over time along with the infrastructure. Packaging solutions that are ideal for the future may not be the best for today – a possibility that FMCG managers should consider when aiming for increased recyclability.
At this point, it’s unclear which targets will take the form of EU-wide legislation and what will remain only as guidelines or national requirements. Similarly, methods of implementation and enforcement are undecided and could vary by country or region. However, the uncertainty around legislative changes should not prevent companies from preparing for action. Now is the time to launch thorough explorations of the deep challenges around sustainability, and to form multi-disciplinary alliances both internally and externally.
All regulators and all FMCG brands have a vested interest in bringing sustainable methods and solutions to the market. To do that, we must help one another by providing mutual insight, expertise, and guidance. In this way, we can serve consumers and our brands while building a better future for our planet.
Insights for this article were provided by Vera Bartsch (Director, Sustainability Development, UPM Raflatac), Jukka-Pekka Rantakokko (Public Affairs Manager, UPM), and Pablo Englebienne (Regulatory Affairs Manager, FINAT labels).