Packaging and Packaging Waste Regulation, R3PACK’s position

R3pack position on Packaging Waste Regulation

The consortium of the R3PACK research project – in Horizon Europe, as seen (1) – expresses its position on the PPWR proposal, ‘Packaging and Packaging Waste Regulation’, adopted by the European Commission on 22 November 2022. (2) To follow a summary of the position expressed by R3PACK (3), with some brief notes by the writer.

1) Packaging and Packaging Waste Regulation, PPWR. Premise

PPWR file, ‘Packaging and Packaging Waste Regulation’, expresses the objective of promoting the reduction of the use of packaging (prevention) and the reuse of the related waste, even before their recycling. In line with the ‘Lansink scale’, also known as the ‘waste hierarchy’, which was approved by the Dutch Parliament way back in 1979 and is still the paradigm of the circular economy (4)

The scheme of regulation PPWR expresses a qualitative leap compared to the ‘Circular Economy Package’, launched through directives which have already recorded uneven applications in the Member States. (5) And it is therefore the subject of lively debates in the current phase of political examination in the European Parliament and the Council which sees the single-use packaging lobbies at the forefront, as has also been seen. (6)

2) PPWR, the position of the R3PACK research consortium

The research project #R3PACK (Reduce, Reuse, Rethink PACKaging) is focused on the analysis and development of innovative technologies that include the replacement of synthetic polymers with high-strength natural fibers in multilayer and multimaterial packaging.

The position of his consortium – which brings together universities and research centres, sector industries, retail and consumers – is all in all unusual, as it is expressed in a phase of political debate that may not end in the current legislature. And it is summarized in the recommendations that follow.

2.1) Definition of reuse

R3PACK welcomes the definition of reusable packaging set out in the PPWR proposal (Article 10). However, it considers it necessary to consider that some reusable packaging may require disposable components, such as lids or seals, to ensure the safety and functionality of the packaging.

The consortium therefore suggests admitting:

– the presence of these components in reusable packaging, when possible, ‘as there are often no reusable alternatives in certain contexts’,

– the use of disposable labels, where necessary, to ensure the accuracy of product information.

2.2) Reuse, impact assessments

The objective to increase reusable packaging, according to the R3PACK consortium, should be ‘tempered’ by technical evaluations that consider the various factors (e.g. logistics, substitution of materials, environmental impact) that affect the implementation of the different reuse systems.

The example mentioned – the ‘weight’ of reusable glass packaging, compared to ‘recyclable’ plastic – is not among the happiest, in the writer’s opinion, taking into account historical positive experiences in various countries. Impact assessments (ie LCA) are however ongoing, also in the R3PACK research project.

2.3) Standardization of reusable packaging

Standardization it is essential for efficient reuse systems. R3PACK encourages the review and strengthening of existing standards to align them with the requirements specified in Annex VI of the Regulation.

The standards improve interoperability, logistics and collaboration along the entire value chain, to the benefit of the environment and the economy. Even more so if shared at EU and international level.

2.4) Introduction of food safety protocols and washing grids

It is emphasized the importance of ensuring food safety and hygiene in reusable packaging. The interaction between packaging and its contents can have a significant impact on food safety.

European discipline of ‘food contact materials’ (FCM or MOCA, materials and objects in contact with food) is obsolete and has serious shortcomings, as we have seen. (8) R3PACK also calls for the development of verification protocols for car wash centers.

2.5) Incentives for returning packaging

We welcome the PPWR proposal regarding reuse systems (Annex VI, Part A). Effective collection systems are critical to the success of reusable packaging.

Specific incentives to the return (Deposit Return Schemes) are equally necessary, to ensure the efficient and regular functioning of the reuse systems.

Customers must be involved with incentives, but also through large-scale public information and awareness campaigns.

2.6) Gradually eliminate hazardous chemicals

Toxic chemicals still present in many packaging materials can pose serious risks to human health and the environment. The R3PACK consortium calls for the ‘gradual’ elimination of harmful substances such as PFAS, bisphenols and phthalates, as well as transparency in information on the chemicals present in packaging.

The security and the circularity of recycled packaging cannot ignore – adds the writer – an effective and timely reform of the REACH regulation, already promised in vain by the Von der Leyen Commission, as well as of the regulation of Food Contact Materials. (9)
Managing public health risks cannot wait any longer.

3) PPWR, a precious opportunity

Participants in the R3PACK research consortium are committed to collaborating with industry players, policy makers and consumers to drive positive change in the packaging industry. The consortium argues that the PPWR proposal represents a significant opportunity to promote sustainability, protect the environment and improve consumer safety.

Dario Dongo


(1) Dario Dongo. R3PACK, sustainable packaging and reuse in Horizon Europe. GIFT (Great Italian Food Trade). 10.9.22

(2) Dario Dongo, Alessandra Mei. Reduction, reuse and recycling of packaging in the EU. PPWR’s proposal. GIFT (Great Italian Food Trade). 14.12.22

(3) R3PACK. Packaging and Packaging Waste Regulation. 3.10.23

(4) Dario Dongo. Circular Economy. Égalité

(5) Dario Dongo, Giulia Torre. Circular Economy Package, implemented in Italy in September 2020. GIFT (Great Italian Food Trade). 2.10.20

(6) Marta Strinati, Dario Dongo. Goodbye baskets of strawberries and salad ready? False alarm. GIFT (Great Italian Food Trade). 10.5.23

(7) Martha Strinati. The lobbies of McDonald’s & CO. against the packaging regulation. DeSmog investigation. GIFT (Great Italian Food Trade). 19.5.23

(8) Dario Dongo, Paolo Rebolini. Kitchenware and food contact materials, test conditions in EU. GIFT (Great Italian Food Trade). 22.8.23

(9) See paragraph 6 in the previous article by Dario Dongo and Andrea Adelmo Della Penna, Microplastics, the first restrictions in the Old Continent in a mini-reform of the REACH regulation. GIFT (Great Italian Food Trade). 1.10.23

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