The definition of high-quality recycling in the report of the ENVI committee of the European Parliament on the Packaging and Packaging Waste Regulation (PPWR) favors plastic packaging over wooden packaging. According to EPAL, this will lead to more plastic packaging and therefore contradict the goal of the PPWR to reduce plastic packaging and plastic waste.
EPAL and the European timber industry share deep concerns regarding the definition of high-quality-recycling in the ENVI report on the Packaging and Packaging Waste Regulation (PPWR), dated 18 Oct. 2023 which will be the basis for the decision of the European Parliament planned for 20 Nov. 2023.
Bernd Dörre, CEO of EPAL:
“EPAL fully supports the sustainability goals pursued by the European Commission with the draft PPWR. EPAL pallets are made from wood, a natural and renewable raw material that meets all the requirements for sustainable packaging, including zero-waste recycling. With more than 650 million EPAL Euro pallets in circulation the open EPAL pallet pool is a prime example of the reuse of packaging in a functioning circular economy. This means that EPAL already fulfils most of the requirements of the PPWR. However, the proposal of the European Parliament’s Environment Committee (ENVI) puts wooden packaging and transport packaging, including EPAL pallets, at a disadvantage.”
EPAL criticizes the definition of “high-quality recycling” in the ENVI Committee’s report
According to the report of the ENVI report, a packaging material is only considered “high quality recycled” if the recycled material can be used in the same or a similar way. This definition restricts the use of recycled packaging material to the production of new packaging. In contrast, wood chips obtained from the recycling of wooden packaging such as pallets can only be partially used for new packaging material such as the chipboard blocks of pallets. The majority of wood chips, on the other hand, are used for the production of particleboards, which are used in the construction and furniture industry.
This “upcycling” through the conversion of wood recycling material into long-lasting applications and products is in line with the cascade principle of wood use in accordance with the European Green Deal and the EU Forestry Strategy 2030. It is therefore all the less understandable that the ENVI Committee’s proposal restricts this fundamental principle of sustainability.
Lack of consideration of specific packaging properties in the PPWR
The definition of high-quality recycling in the ENVI Committee’s report does not take into account the specific properties of wood for the protection of the environment and for the sustainability of packaging logistics. The reason for this is the “one-size-fits-all” approach of the PPWR, which does not take into account the purpose and the material of the packaging. When determining the quality of recycling, it is also not taken into account whether the packaging was previously part of a reuse system.
Bernd Dörre, CEO of EPAL:
“The lack of consideration of the sustainability of the material in the definition of high-quality recycling penalises natural and sustainable materials such as wood. The restriction of high-quality recycling to closed-loop recycling further exacerbates this disadvantage. At the same time, the lack of consideration of years of reuse of EPAL pallets directly penalises the open EPAL Euro pallet pool as one of the oldest examples of a functioning circular economy. All of this contradicts the objectives of the PPWR and in particular the objectives of the European Green Deal.”
Reuse is better than just recycling
Following the definition of high-quality recycling in the ENVI report, it is better to recycle plastic packaging after each use than to reuse wooden packaging for years before other products are made from the recycled wood material. This obviously incorrect result can easily be avoided if the definition of high-quality recycling includes an open material cycle and also takes into account the reusability of the packaging.
Bernd Dörre, CEO of EPAL:
“Together with many associations of the European wood, furniture and paper industry, we call on the European Parliament, the European Commission and the European Council to regulate an open material loop for the recycling of packaging instead of a closed product loop. Only such a flexible approach to the use of recycled material as a secondary raw material will ensure the use of natural and sustainable packaging and the reduction of plastic packaging and plastic waste.”
The EPAL statement, which was sent by EPAL to the Members of the European Parliament, can be found here: https://www.epal-pallets.org/fileadmin/user_upload/documents/pdf/EPAL-Statement_PPWR-ENVI_13112023_EN.pdf