Posted by 
When we first launched Together for Sustainable Packaging — an alliance of businesses and associations from a wide cross-section of the food and hospitality European economy, known as HORECA (hotel, restaurant, catering) — in April this year, the debate around the EU’s Packaging and Packaging Waste Regulation (PPWR) proposal was still in its infancy. That is no longer the case. It has become one of the most frequently discussed policy issues of recent memory, and not without reason. The implications of the proposals reach far into the EU economy and business sectors, and will hugely affect all consumers across Europe and beyond.
The implications of the proposals reach far into the EU economy and business sectors, and will hugely affect all consumers
We launched the alliance because, while we fully support the overall goals of the EU’s Green Deal, we were worried about the unintended consequences of the proposed PPWR legislation for the environment, the economy, food safety and consumers. And while the debate has evolved, we are still concerned about the direction of travel when it comes to mandating reusable packaging over recyclable, fiber-based packaging solutions, and the resulting negative consequences.
For example, the idea of reusing something over and over again seems the obvious solution — but it’s not so simple. For reusable packaging to have a positive impact on the environment, it needs to be reused 50 to 100 times to make it environmentally preferable to a single-use paper cup according to independent research carried out by global management consultancy Kearney. But current in-market experience suggests we are very far from reaching that level of reuse. This means reusables will lead to a sharp increase in plastic materials in Europe according to the Kearney report, No Silver Bullet. Reuse targets proposed in PPWR will create four times the amount of plastic packaging waste for dine-in, and 16 times for takeaway.
In recent years and especially this year, Europe has been the victim of droughts, forest fires and heatwaves. All of these add to water stress. According to EU figures, almost one-third of the union’s citizens are affected, and predictions suggest it’s only going to get worse. Why then, against this backdrop, are those same EU policymakers who are enacting measures to save water and relieve the stress on the infrastructure, mandating packaging regulations under PPWR that will only add to the Continent’s local water stress? Reusable packaging needs to be washed after every use. For an industry like ours in the HORECA sector, this relocates water-demand from a small number of single-use fiber packaging production locations to all restaurant locations across Europe, many of which are in areas of higher water scarcity. A comparison between paper and reusable packaging for on-site consumption in quick-service restaurants, carried out in a life-cycle assessment (LCA) by Ramboll — which is a peer-reviewed and ISO-verified study — shows that reusables consume 3.4 times more water than single-use paper packaging.
The European Commission recognizes water scarcity and drought as a priority in the Green Deal; the issue is highlighted in several major European strategies, including the 2020 Circular Economy Action Plan. But reusable packaging mandates could result in an increase in overall water use of up to 267 percent, according to Ramboll.
The production of reusable plastic packaging, and its washing, drying and transportation, also requires more energy, resulting in increased greenhouse gas emissions. The Kearney study shows that a shift to 100 percent reusables by 2030 would increase emissions by up to 50 percent for dine-in and up to 260 percent for takeaway.
Packaging isn’t just for show either. It plays a fundamental role in protecting our food and keeping consumers safe. Multiple studies on the hygiene challenges of replacing single-use packaging with reusables find that circular reuse systems present greater risks of cross-contamination due to multilocation cleaning, sanitation and storage standards, and transportation. Packaging also allows for convenient and safe transportation. It facilitates delivery to areas where fresh food is in short supply, guaranteeing the highest standards for consumers.
And yet we are not arguing for a single solution to the EU’s packaging waste problem. Instead, we want a mix of solutions. Any law should take into account the specific needs of complex business sectors, and the right packaging solutions for the right circumstance. This is why we are asking that there should be no discrimination against fiber-based packaging, given that it can be recycled and serves as the best solution in our sector for the environment, the economy, food safety and consumers.
There should be no discrimination against fiber-based packaging, given that it is the best solution for the environment, the economy, food safety and consumers.
Together for Sustainable Packaging and others have successfully stimulated a valuable debate, but decisions as important as these should be based on science and evidence and not merely ideology. As a sector, HORECA generates billions of euros for the EU economy and creates millions of jobs. We all want the best for the planet and the right solutions for society, but we must not rush, tempting though it is, because if we do, we risk making the problem worse — and as this year’s climate events have shown us, we cannot afford to make that mistake.
Decisions as important as these should be based on science and evidence and not merely ideology.
