ECOS | Environmental Coalition on Standards

10 June 2020

Packaging requirements – when recycling is not enough

ECOS and the Rethink Plastic Alliance ask the EU Commission and Member States to improve the rules for packaging in the European Union.

Since last year, the European Commission has been looking into ways of reinforcing the essential requirements for packaging in the EU. As part of the process, the consulting firm Eunomia has undertaken the preparatory work for a review of the current essential requirements for packaging,  looking into the effectiveness of the current EU packaging laws and how to tackle trends such as overpackaging and lack of recyclability.

In the context of the preliminary discussions to review packaging waste rules in Europe, ECOS together with partners from the Rethink Plastic alliance has raised concerns over the narrow focus of the study, which did not examine options to better implement waste prevention and re-use.

This is all the more regrettable, given the fact that other solutions rank much higher than recycling among the EU priorities. More support should be given to upstream solutions, such as packaging-free shops and initiatives, as well as deposit return systems to enable refill and reuse of packaging at scale. As part of revised Directive on Packaging Waste 2018/852, the EU should widely introduce such initiatives.

As part of the work to update the rules, a new set of studies has been launched by the European Commission in early 2020. These new reports are dedicated to packaging prevention and reuse measures under EU rules.

At a workshop organised by the European Commission, NGOs and other stakeholders also contributed to the discussion on various options to improve EU’s waste prevention strategies and reach its re-use objectives. There, the Commission presented a study on the policy options ahead, which we welcomed.

However, we felt that a number of the proposals presented, in spite of their considerable potential, needed to be more ambitious to make circular economy a reality. For example, standards for reusable packaging gained quite some traction, but companies showed reluctance towards bans and mandatory requirements.

We shared our views in a dedicated paper on how to make the best use of various policy instruments to curb the current trend of ever increasing packaging waste.

The main points raised included:

  • The need to introduce a cap on amounts of packaging put on the market
  • The relevance of targets for refill and reuse in specific sectors such as business to business transport, the beverage sector, the food services sector, e-commerce packaging, as well as dried foods and household hygiene products
  • The need for universal formats for reusable packaging to be accepted by multiple reuse schemes across the EU and in support of sector-specific targets for refill and reuse
  • The relevance of selective bans to avoid packaging use as a marketing and product placement tool
  • The need to provide tools for enforcement of prevention and reuse measures at Member-State level

ECOS is co-funded by the European Commission and EFTA Funded by the European Union. Views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union or EISMEA. Neither the European Union nor the granting authority can be held responsible for them.

Website by