Recognising the complementarity of reuse and recycling is the solution

By Nicholas Hodac, director general, UNESDA Soft Drinks Europe, Krassimira Kazashka, CEO, Metal Packaging Europe, Patricia Fosselard, secretary general, Natural Mineral Waters Europe, Simon Spillane, director, The Brewers of Europe, Anne-Sophie Royant, secretary general, European Fruit Juice Association (AIJN) and Rocco Renaldi, secretary general, Food Service Europe


Ahead of the plenary vote on the proposed Packaging and Packaging Waste Regulation (PPWR), a large group of European and national associations across various sectors are expressing serious concerns regarding the approach to reuse adopted by the European Parliament’s Environment Committee (ENVI) on October 24.

Many sectors recognise the good progress made on the draft PPWR in a number of areas which will help industry to achieve its circular ambitions. However, they are highly concerned with the amendments to Article 26 of the draft PPWR related to the reuse targets, which have been adopted by the ENVI committee, and in particular the following two elements:

  1. The possibility provided to Member States to go beyond the proposed increased reuse targets without any justification needed.

This goes directly against the objective of the European Commission to promote harmonisation and risks fragmenting the EU single market by creating a patchwork of national targets that will have a considerable impact on Europe’s competitiveness. It would also increase the complexity of the implementation of the targets, would result in an unworkable situation for companies and would act as a barrier to the single market, as different targets would make it impossible to achieve a level-playing field.

Furthermore, it is worrying to see that the text does not seem to require any form of impact assessment being performed by Member States to justify going beyond the EU targets. How will the EU achieve the desired outcomes with its proposed measures without properly assessing the costs and benefits of scaling up reusable systems across the Continent?

  1. The absence in the proposal of a mechanism which would allow for recyclable packaging as an alternative to packaging for reuse if a better overall environmental outcome can be achieved, on the basis of a waste management or lifecycle assessment.

The European Parliament’s Committee on Industry, Research and Energy (ITRE)’s opinion adopted in July 2023, and alternative compromise amendments proposed ahead of the vote in ENVI, rightly recognised that reusable solutions will not bring environmental benefits in all situations and for all packaging. It is important to provide for an alternative option if economic operators can prove that the use of recyclable packaging is environmentally more sustainable than the reuse of packaging.

Facilitating complementarity is of critical importance to support the achievement of our sectors’ climate objectives and ensure that operators have to invest in reusable packaging formats only when it actually makes more sense than recyclable packaging from an environmental perspective.

We therefore ask MEPs to:

  1. Reject any proposal that would allow Member States to set higher targets than those proposed by the European Commission under Article 26.
  2. Support plenary amendments that propose mechanisms which would support the complementarity of recyclable packaging and reusable packaging.


We look forward to seeing MEPs support the complementarity of reuse and recycling in the PPWR in the plenary vote in the end of November. If MEPs want to enable beverage manufacturers to create a circular economy for beverage packaging, they should provide them with flexibility to invest in reuse only where it makes the most sense from an environmental and economic perspective. Our sector stands ready to strengthen its engagement with decision-makers to ensure that the PPWR will work for the environment, for consumers and for businesses.  

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