Publications » Position papers » Joint steel position paper on Packaging and Packaging Waste Regulation (PPWR)
Joint steel position paper on Packaging and Packaging Waste Regulation (PPWR)
Downloads and links
Recent updates
EUROFER supports the position of the steel for packaging sector represented by APEAL, the Association of European Producers of Steel for Packaging, regarding the Packaging and Packaging Waste Regulation (PPWR) proposal, as it suggests much needed improvements to the new EU legislation in order to contribute to a sustainable and resource-efficient solution for a green and resilient EU economy.
As an essential part of the steel products family, steel packaging is an incredibly versatile material with superior properties used in many applications. The European steel industry emphasises the importance of the criteria for recyclable packaging and recycled content as well as waste prevention, which can be supported through the review of the Landfill directive. The joint position paper also highlights the need for a legal instrument and legal base to ensure the successful implementation of PPWR provisions.
The key messages are the following:
1. Criteria for recyclable packaging:
The current Commission proposal is a step in the right direction. However, to fully close the circular loop the steel for packaging sector recommends:
2. Recycled content:
The steel for packaging sector supports the current Commission proposal that recycled content targets should only apply to materials with a low demand and uptake of recyclates.
3. Prevention of packaging waste:
Waste reduction targets should be set for each of the specific materials contained in packaging waste: plastic, wood, ferrous metals, aluminium and paper/cardboard.
4. Transport packaging:
Steel pails, drums, canisters and kegs are sales packaging and not transport packaging. Consequently, they should not be subject to the re-use targets set for transport packaging.
5. Legal instrument and legal base:
APEAL supports the choice for a Regulation and a full ‘internal market legal base’ for the Packaging and Packaging Waste Regulation (article 114 TFEU).
6. Phase out landfilling of packaging waste:
The steel for packaging sector believes that the review of the PPWR should be complemented by a review of the Landfill Directive 99/31/EC, aiming at accelerating the phase-out of landfill of packaging waste.
Full text available below.
Strasbourg, 17 December 2025 – The European Commission’s latest proposals on the Carbon Border Adjustment Mechanism (CBAM), unveiled today, correctly identify several loopholes that risk undermining its effectiveness, notably regarding EU exports, downstream sectors and circumvention practices. However, despite these laudable efforts, the measures put forward fail to deliver a comprehensive and durable response to carbon and jobs leakage, warns the European Steel Association (EUROFER).
A milestone occasion to quickly and effectively restore affordable electricity, to relaunch the
decarbonization and strengthen the international competitiveness of the European steel
industry.
Brussels, 02 December 2025 – Unchanged negative conditions – U.S. tariffs and trade disruptions, economic and geopolitical tensions, protracted weak demand and still high energy prices – continue to weigh on the European steel market. EUROFER’s latest Economic and Steel Market Outlook confirms for 2025 another recession in both apparent steel consumption (-0.2%, unchanged) and steel-using sectors (-0.5%, revised from -0.7%). A potential recovery is expected only in 2026 for the Steel Weighted Industrial Production index (SWIP) (+1.8%, stable) and for apparent steel consumption (+3%, slightly revised from +3.1%) – although consumption volumes would still remain well below pre-pandemic levels. Steel imports retained historically high shares (27%), while exports plummeted (-9%) in the first eight months of 2025.