Position papers

Joint steel position paper on Packaging and Packaging Waste Regulation (PPWR)

EUROFER supports steel for packaging sector APEAL

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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:

  1. Stricter qualitative criteria to label packaging as ‘recyclable’.
  2. The introduction of packaging recyclability performance classes or ‘grades’ for each packaging unit put on the market is timely and necessary. Non-recyclable packaging should be gradually phased out. Best performers should be rewarded via eco-modulation of EPR fees and by a higher recyclability performance grade.
  3. Packaging should be ‘recycled at scale’ by 2030 covering at least 90% of the Union’s population and applied in 2/3rd of the Member States.

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.


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Published: 21 April 2023

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