Members of the Food Packaging Forum (FPF) submitted feedback highlighting aspects of food packaging and chemical safety that FPF believes should be included in future versions of the packaging and packaging waste regulation (PPWR).
It is particularly important to consider food packaging in this process as, according to Eurostat, it makes up around 30% of overall household waste in the EU, and it strongly contributes to plastic littering (FPF reported). The revision of the PPWR is therefore an important opportunity for effective measures on hazardous components of food packaging. FPF’s primary concerns are (i) the presence of hazardous chemicals in packaging materials meant to be recycled or reused, (ii) the definition of compostable packaging- it should include chemical safety and a time limit, and (iii) the current lack of a definition of inertness in the EU. A shortened version of the comment follows.
Hazardous chemicals (generally)
The presence of hazardous chemicals in food packaging is a barrier to enabling a circular economy for food packaging and will hinder the successful implementation of the PPWR (FPF reported). It is essential that the issue of hazardous chemicals is adequately addressed in the PPWR, but the wording in the current text of the regulation does not guarantee this.
Defining compostable packaging
FPF supports the Commission’s idea of a short, defined list of packaging types that are mandatorily compostable as one necessary step to avoid confusion amongst consumers and other stakeholders in the value chain. But building off of FPF’s first point, to avoid exposure of humans and the environment to hazardous chemicals, all compostable plastics need to be inherently safe as defined under the Chemicals Strategy for Sustainability (CSS, FPF reported also here).
Additionally, while compostable packaging is currently defined as packaging that “ultimately decomposes into carbon dioxide, mineral salts, biomass, and water” the definition lacks a time limit. Multiple studies have found “biodegradable” or “compostable” plastics that do not degrade even after years (FPF reported, also here). Standards need to be developed on how to demonstrate or test safety and time-limited decomposition concerns.
Defining inertness
Finally, materials that are most suitable for reuse (and recycling) are those that are inert, meaning that they hardly interact chemically with the foods they are brought into contact with. For the PPWR’s ambitious reuse targets to be implementable, it is essential that a definition of inertness is provided that is applicable to reusable food packaging. Importantly, the current overall migration limit of 60 ppm specified for plastic FCMs in EU 10/2011 cannot be considered as a suitable threshold for inertness, as it does not take health aspects into consideration. The PPWR could make an important contribution to this issue by providing such a definition of inertness for reusable food packaging.
The European Commission (EC) proposed the EU packaging and packaging waste regulation (PPWR) in November 2022, with the objective to reduce the negative environmental impacts of packaging and packaging waste, while improving the functioning of the internal market (FPF reported). Specifically, the Commission would like to (i) reduce the generation of packaging waste, (ii) promote a circular economy for packaging in a cost-effective manner, and (iii) promote the use of recycled content in packaging.
Reference
Jane Muncke, et al. (April 24, 2023). “Feedback from: Food Packaging Forum Foundation.” European Commission.
