In June, a new cohort of Members of the European Parliament (MEPs) emerged following the elections. By September, the announcement of the new EU Commission-designates introduced a fresh set of priorities focused on implementing the Green Deal and enhancing EU competitiveness.

Source: BusinessGreen

As these new MEPs and Commission-designates enter autumn, policy momentum is building, with the first order of business being the EU legislative acts from the previous mandate that legislators could not finalize before the elections. This includes those related to the Packaging and Packaging Waste Regulation (PPWR).

For the packaging industry, this marks a pivotal moment. The PPWR, which has been widely discussed and debated, received approval from Parliament at the end of April and is currently undergoing the standard legislative corrigendum process, with final approval anticipated by the end of November according to the latest updates.

The PPWR is a crucial tool in advancing the circularity of the European packaging industry and achieving Europe’s net-zero goals, all while enabling the industry to regain competitiveness and maximize business growth opportunities. As Dow's director of sustainability policy and advocacy in the EMEA region, I firmly believe that the PPWR can serve as an effective policy instrument to meet both Dow's and the packaging industry's circular objectives. I am acutely aware of its significant potential to transform how we create, utilize, and dispose of packaging, and I recognize our essential role as a leading materials science company in serving the packaging sector. In the coming years, it will be vital for us to collaborate with policymakers and industry stakeholders to develop secondary policies that ensure smooth and practical implementation.

The Role of the Plastics Industry

At Dow, transitioning to a circular economy for plastic packaging is our top priority. We are investing in next-generation technologies and innovative plastic materials to ensure that more packaging can be designed for recyclability. Through our expertise in materials science, we aim to facilitate the use of recycled plastic content across a wider range of plastic packaging applications, including sensitive uses like food contact packaging. In essence, we are optimizing packaging circularity by ensuring necessary functionality for end applications while minimizing resources and waste.

Effective regulation is essential to enable this transition at scale. As part of the EU's Green Deal, the PPWR sets ambitious targets for recycled plastic content in all plastic packaging, driving market demand and unlocking investments needed to accelerate the shift to a circular economy. While the road ahead is long, the PPWR represents a promising step forward for our industry and the environment. It positions packaging as a bellwether for other sectors where circularity targets are still being contemplated.

The PPWR establishes mandatory recycled plastic content targets that inspire ambition and stimulate the European market for secondary raw materials, recognized as a priority by the new Commission to enhance economic resilience and growth.

By 2030:

• Plastic packaging made from materials other than PET (excluding single-use beverage bottles) must contain at least 10% recycled content.
• Single-use plastic beverage bottles should include a minimum of 30% recycled content.
• Other types of plastic packaging need to feature a minimum of 35% recycled content.

By 2040:

• Plastic packaging made from materials other than PET (excluding single-use beverage bottles) must have at least 25% recycled content.
• Single-use plastic beverage bottles should contain a minimum of 65% recycled content.
• Other plastic packaging must include at least 65% recycled content.

Targets are technology-neutral, allowing all recycling technologies to contribute toward achieving them.

Chemical recycling, also known as advanced recycling, complements mechanical recycling and will play a vital role in meeting the PPWR's goals. It is especially important for Dow’s objectives, particularly the aim of transforming waste and alternative feedstock to enhance our capacity for producing circular and low-carbon emission solutions.

This method allows hard-to-recycle plastics to be converted back into virgin-quality raw materials. Importantly, plastics recycled through chemical processes display the same performance and safety characteristics as virgin plastics, making them suitable for the same packaging applications, including food packaging. Traditional mechanical recycling methods do not achieve this at scale for contact-sensitive applications. By investing in both chemical and mechanical recycling, we can improve overall plastics recycling rates and meet the recycled content targets established by the PPWR.

A critical first step in realizing a circular plastics economy and unlocking the necessary private investments is the full endorsement of the fuel-use exempt mass balance accounting method for measuring recycled plastic content targets. This thoroughly audited approach allows for the calculation of recycled plastic content in packaging, not only measuring against goals but also providing transparency to consumers through third-party certification. Most importantly, mass balance facilitates the scaling of chemical recycling at existing manufacturing sites, offering a credible alternative to incineration and landfill for products that cannot be mechanically recycled.

Dow is collaborating with companies like Mura Technology and Plastogaz to scale chemical recycling. Additionally, we are partnering with recycler Valoregen to establish the largest hybrid mechanical and advanced recycling plant in France, combining the benefits of both technologies. Without mass balance accounting and efficient collection schemes, these technologies will struggle to be deployed at scale, hindering our ability to meet the targets set in the PPWR.

However, the new EU regulation focuses not only on recycled plastic content but also on reducing overall packaging waste and ensuring mandatory recyclability. The regulation proposes mandatory recyclability for all packages starting in 2030, with recyclability at scale expected by 2035, based on design for recycling guidelines yet to be defined. It also sets reuse targets for specific packaging formats and materials beginning in 2030. The industry has expressed concerns regarding mandatory reuse targets for stretch films used in transportation packages due to potential costs, safety issues, and environmental impacts, and is gathering evidence to advocate for exemptions for this packaging format.

Additionally, the regulation outlines:

• Packaging waste reduction targets for Member States: 5% by 2030, 10% by 2035, and 15% by 2040.
• Criteria to eliminate unnecessary packaging and optimize material usage.
• Bans on certain unnecessary single-use packaging formats starting in 2030, expanding on existing bans under the Single Use Plastic Directive (SUPD), including bags for fruits and vegetables under 1.5 kilos and single-use condiment and toiletry packages for consumption in hotels, restaurants, and cafes.
• New restrictions on Per- and Polyfluorinated Alkyl Substances (PFAS) in food contact packaging.
• A mandate for the Commission to explore potential mandatory bio-based plastic targets for packaging by the end of 2027.
• Mandatory eco-modulation of Extended Producer Responsibility (EPR) fees for packaging based on recyclability assessments from 2030, with the option for additional modulation based on recycled plastic. This measure aims to promote circularity by financially incentivizing leaders in the field.
• Mandatory reuse targets for specific packaging formats and materials starting in 2030.
• A mandate for the Commission to conduct an impact assessment and develop a regulatory proposal for bio-based plastics targets by 2027.

The PPWR is a significant step forward, but we require a framework to scale the tools necessary to achieve these ambitions. We welcome the vision for the new mandate of the European Commission for the period 2024-2029, presented by Ursula von der Leyen in the European Parliament on July 18. This proposal outlines a new Clean Industrial Deal and a Circular Economy Act aimed at fostering market demand for secondary materials and establishing a single market for waste. We also appreciate her new commitments to enhance investments in the green transition, including the establishment of a European Competitiveness Fund to support clean and strategic technologies. We believe that technologies within the circular economy are strategically crucial for the EU and essential for reducing Europe's reliance on virgin raw materials, boosting economic growth, and enhancing resilience while progressing toward our net-zero Green Deal ambition. Therefore, these initiatives should be supported under the new EU agenda.

Regulators and industry must collaborate to create a more sustainable future for packaging. Dow understands the importance of such partnerships and is actively engaging across the value chain to expedite the development of circular plastic material innovations and scale next-generation recycling technologies.

Highlights of this work include:

• Facilitating the simplification of multi-material packaging into mono-material polyethylene-based packages to improve recyclability at the end of their lifecycle without compromising performance, safety, or shelf life. This includes the development of mono-material pouches for food, home, and personal care packaging.
• Launching the REVOLOOP™ product line, which incorporates recycled plastics from mechanical recycling into non-food packaging applications, such as home care and industrial films, allowing for up to 70% post-consumer recycled (PCR) content in collation shrink film applications.
• Investing alongside innovative chemical recycling companies to enhance technologies that permit the use of recycled plastics in food contact-sensitive applications.
• Utilizing recycling boosters and compatibilizers to enhance the quality of recyclates in final applications, enabling higher recycled content levels.
• Developing high-performance plastics that utilize fewer packaging raw materials while facilitating the incorporation of PCR in technically challenging applications, such as stretch films.
• Offering a wide array of bio-based plastic products with a decreased carbon footprint, exemplified by Dow's recent collaboration with New Energy Blue in the U.S.