From August 12, the operation of the European regulation on packaging and packaging waste (Ppwr) begins: many of its provisions become applicable and a common regulatory framework is introduced for all Member States.
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“However, it is essential to clarify that not all the prescribed provisions come into force simultaneously: many requirements related to reuse, recycled material content, and recyclability of packaging will take effect progressively in the following years,” explains Simona Fontana, general director of Conai, the national packaging consortium.
Documentary obligations
“The first operational news mainly concerns documentary obligations. Manufacturers will have to prepare the Declaration of Conformity for packaging placed on the European market, certifying compliance with the already applicable requirements, including limits on heavy metals for all packaging, those on PFAS for packaging intended for food contact, and, in the case of reusable packaging, compliance with design requirements for reuse,” Fontana says.
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Pods in recycling
“Another significant novelty – she continues – concerns the very definition of packaging. From August 12, for example, coffee or tea capsules and pods, as well as some beverage sachets, are considered as such. This has consequences both in terms of extended producer responsibility and in the management of end-of-life and consumer information for correct disposal in separate collection.”
The interpretative challenge
Faced with an approach that rethinks packaging waste considering the entire life cycle (no longer only at the end), with a strengthening of ecodesign, the supply chain does not lack difficulties, starting with regulatory ones. “For companies – Fontana emphasizes -, one of the most urgent challenges is interpretative. The regulation, in fact, immediately introduces new definitions of economic operators (manufacturer, importer, distributor, and supplier) that require companies to carefully assess their role in the supply chain, which entails different responsibilities including informational or documentary ones. In many cases, there is no automatic answer, but a case-by-case analysis is necessary.”
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