- Despite its criticisms of individual provisions of the proposals for the PPWR, EPAL remains committed to supporting the legislative initiative for a uniform and binding design of European packaging law.
- The new regulations on the reuse of packaging in pool systems “are partially so abstract and imprecise that it is difficult to predict what consequences will be associated with them in practice.”
- EPAL already fulfills these key objectives of the PPWR, and it is, therefore, all the more important that the functioning of the EPAL open pallet pool is not compromised by provisions that may be correct for plastic and consumer packaging but do not take into account the specificities of transport and wooden packaging.
EPAL, the European Pallet Association, has expressed its position on the European Commission’s proposed Regulation on Packaging and Packaging Waste (PPWR), emphasizing the need for clear regulations for reuse systems like the EPAL pallet pool.
The organization criticized the European Parliament’s Environment Committee (ENVI) draft from November 2023 for its approach to recycling packaging, particularly for not considering the unique challenges of recycling wood. EPAL objected to the focus on closed-loop recycling, which favors recycling materials into similar products, arguing that this unfairly disadvantages wood, a sustainable material used in transport logistics.
Wooden packaging, unlike plastic, cannot always be recycled into similar products due to stability and safety concerns. EPAL pointed out that while wood chips from recycled pallets can be used in the furniture and construction industries, they cannot replace new wooden pallets. This approach, EPAL argued, would disadvantage sustainable materials like wood in favor of single-use plastics.
EPAL’s commitment to PPWR amidst uncertainty
In contrast, the European Council’s proposal from December 2023 aligned more with EPAL’s views. It recommended open-loop recycling, where recycled materials can be used in different products while maintaining quality. EPAL supports this approach, seeing it as more sustainable and viable for transport logistics.
EPAL also emphasizes the importance of considering the previous reuse of packaging and its overall sustainability, suggesting that the quality of recycling should be assessed using methods like Life Cycle Assessment (LCA), as proposed by the CountEmissions EU initiative.
The European Council’s proposal also supports the European Commission’s ambitious reuse targets, which the European Parliament had reduced. EPAL agrees with the Council’s stance on not accepting the Parliament’s exemptions, which could undermine sustainability goals through reuse and recycling. This principle is central to EPAL’s open pallet pool system, which relies on natural and renewable wood.
However, uncertainties remain as the trilogue negotiations between the Commission, Parliament, and Council begin. Numerous proposals throughout 2023 have made it difficult to predict the final outcome. EPAL is concerned about legal uncertainties and the planning challenges these pose for companies in the transport packaging and logistics industry. The Council’s proposal leaves room for interpretation and defers many decisions to delegated acts by the European Commission, which could create legal uncertainty for years.
Regulation on reuse in pool systems vague and challenging to interpret in practice
EPAL finds the new regulations on reuse in pool systems vague and challenging to interpret in practice. The PPWR’s focus on plastic and consumer packaging does not adequately consider the successful processes in transport packaging logistics, like open pallet exchange. EPAL regrets the lack of dialogue with the Commission, Parliament, and Council about the practical workings of reuse and exchange in an open pool system like the EPAL Euro pallet pool.
The organization also notes the PPWR’s attempt to uniformly regulate transport (B2B) and consumer (B2C) packaging, as well as plastic and natural material packaging like wood, as a significant unresolved issue. Even the Council’s positive proposal does not fully address this fundamental problem.
Despite these criticisms, EPAL remains committed to supporting the PPWR, aligning with its goals to enhance the reuse and recycling of packaging for environmental protection. EPAL believes its existing practices already meet key PPWR objectives and urges that its functioning not be compromised by regulations more suited to plastic and consumer packaging.