How packaging is affected by the EU Green Deal

The European Green Deal is a comprehensive strategy to make the EU climate-neutral by 2050. Its legislation is highly relevant for packaging managers, as it has a significant impact on material choice, production processes and the entire supply chain.

Relevant legislation and guidelines

The 5 most relevant laws for product distributors

Packaging and Packaging Waste Regulation (PPWR)

This regulation sets out requirements for designing environmentally friendly packaging and managing packaging waste. It aims to reduce plastic use, reduce the volume of waste, promote packaging reuse and recycling, and minimise environmental impact.

PPWR is changing the role of packaging
Sonja Bähr, Director Business Development Berndt & Partner Creality

Single-Use Plastic Directive (SUPD)

This directive aims to significantly reduce pollution from petroleum-based single-use plastics and to promote circular approaches such as recycling and sustainable reusable packaging solutions. The SUPD covers a total of 15 single-use plastic products and applies a range of measures that include bans, consumption reduction targets, labelling requirements and extended producer responsibility.

Now is the time to act
Christian Schiffers, Managing Director of the German Association of the Folding Carton Industry (FFI)

German Packaging Act (VerpackG)

The Packaging Act regulates packaging responsibilities and obligations. Manufacturers and distributors must participate in a dual system which ensures packaging is collected and recycled. The costs of packaging waste collection, sorting and recycling are borne by the distributors. In accordance with Section 21 systems are obliged to create incentives to make packaging more sustainable, by promoting packaging that is maximally recyclable and uses recycled materials and/or renewable raw materials.

3 criteria in the minimum recyclability standard
Svenja Dorn, Federal Environment Agency, ‘Implementation of the Packaging Act (VerpackG)’

EU Directive on Empowering Consumers for the Green Transition (ECGT) and the EU Green Claims Directive (GCD)

The Green Claims Directive is still being voted on in the European Parliament. The guidelines require companies to conduct a scientifically sound analysis of all significant environmental impacts and to prove that their product lives up to the claim. An independent expert must verify the claim before a company is allowed to use it.

Avoiding greenwashing
Christoph Goeken, founder and managing director of House of Change

General environmental claims
Statements such as ‘environmentally friendly’, ‘green’, ‘climate-friendly’ or ‘nature-friendly’ must be clearly explained and substantiated. For example, ‘biodegradable’ would have to be explained as meaning that packaging can be broken down in home compost within a month.

Misleading overall claim
An environmental claim for the entire product or company is misleading if it only refers to a specific aspect.

Advertising with legally binding characteristics (‘obvious facts’)
It is considered misleading if a claim presents legal requirements that apply to all products in a category as a special environmental achievement.

‘Own label’ without ’certification system’
It is forbidden to use a sustainability label that is not recognised by the state or based on an official certification system.

CO2-neutral claims based only on offsetting
CO2 neutrality claims based only on offsetting are misleading; real CO2 savings over the life cycle are required.

Source: Top 25 Questions & Answers on the new EU Green Claims Directive (updated) (houseofchange.net)

EU Deforestation Regulation (EUDR)

The EUDR came into force to combat deforestation and promote sustainable forest management and ensure that raw materials and products marketed in, made available for use in, or exported from, the EU, do not contribute to global deforestation.

Relevant raw materials (e.g. wood, coffee, soya) and relevant products (e.g. virgin fibre, paper, folding cartons) may only be marketed or made available for consumption/use in the EU (or exported to third countries) if:

they are deforestation-free
they were produced in accordance with the producing country’s relevant legislation and
a declaration of due diligence is available.

For each EU-based market participant there should be a supply chain person responsible for compliance.

Does the EUDR replace PEFC©/FSC© certification?

According to Dr. Christian Foldenauer, Deputy Head of Regulatory Affairs BayPapier, PEFC©/FSC© certification is a robust, effective tool to help companies fulfil EUDR due diligence obligations, in terms of risk assessment and risk mitigation. Certification or verification schemes may be used by supply chain members (e.g. operators or distributors) as part of their risk assessment, provided this certification covers the information needed to fulfil their EUDR obligations.

However, PEFC© PEFC©/FSC© certification alone is not sufficient. While certification can play a part in providing information on deforestation relevance (Art. 9) and risk assessment/mitigation (Art. 10/11), it does not release market participants and traders (who are not SMEs) from the obligation to submit due diligence declarations; they remain responsible for any violation.

In our view, FSC© will continue to provide a seal of environmental friendliness and sustainability for supply chain products through its (regular) certifications, which ensure customer confidence.

Request for free our: Checklist Future Ready Packaging

Where you should start now

Put your portfolio to the test

Are all your packaging and packaging components really necessary to protect products, ensure efficient logistics and communicate product characteristics?

Design for recycling is the top priority

If packaging is recyclable and its collection, sorting and recycling systems are in place, the foundation has been laid.

Data quality is decisive

Whether minimum standard, digital product passport or PPWR - every regulation is based on data that must be provided and networked by companies throughout the entire supply chain.

Standards make life easier

Whether calculating CO2 or assessing recyclability - defined methods, parameters and tolerances are required for solutions to be compared. Where these are missing, implementation is difficult.

Don't wait and see, get started!

Packaging is becoming a top priority. Not only does it embody the brand, it must also be compliant so that the products can continue to be placed on the market.

How we can support you

PERFORMANCE BASED DEVELOPMENT

Our developments are based on technical specifications and many years of experience from our development database. Technical specifications are essential for developing packaging that is as effective and efficient as possible. This applies to performance values such as BCT, ECT and Cobb value, as well as to application-specific barrier properties or recyclability.

RENEWABLE RECYCLED MATERIAL

Based on technical specifications, we determine the right material quality for the customer's requirements during the product development process. We focus on renewable raw materials, primarily wood fibres from responsible forestry (FSC© and PEFC™ certified), and we test alternative fibre sources such as grass, silphie, hemp, etc. We use paper and cardboard made from recycled fibres wherever possible and sensible.

MATERIAL EFFICIENCY | LIGHTWEIGHT

We select materials based on their technical values and save resources and CO2 with new papers and technologies. The focus is on using lightweight papers and custom flute profiles to achieve identical performance values with less material.

VOLUME OPTIMISATION

As much as necessary - as little as possible. This maxim guides us when developing custom packaging solutions. When it comes to volume optimisation, product protection and transport safety of the packaged goods are our top priorities.

DESIGN FOR RECYCLING

The aim is to maximise packaging and display recyclability and find alternatives for non-paper components or to eliminate them completely. High-quality material recycling via the recycling systems available throughout Europe is our top priority. We aim not only to use current state of the art technology but also to develop innovative solutions that extend today's possibilities.