Provisional agreement on proposal for regulation concerning packaging and packaging waste

On 4 March 2023, the EU Member States, European Parliament and Commission reached a provisional political agreement on a proposal for a regulation on packaging and packaging waste. Finland has taken an active part in the preparation of the regulation. The proposal that was agreed on can be evaluated in further detail only after its final content is available. The proposal is still pending formal adoption by the Member States and Parliament. The regulation will become applicable 18 months after its adoption.

The aim of the regulation is to reduce the amount of packaging waste, increase high-quality recycling, reduce the consumption of natural resources and create a market for recycled materials. The proposal considers the full life-cycle of packaging.

Obligations for re-use and re-fill 

Binding re-use targets are proposed for 2030 and indicative targets for 2040. The targets vary depending on the type of packaging, and they concern the following: alcoholic and non‑alcoholic beverages (excluding wine and aromatised wines, milk and other highly perishable beverages), transport and sales packaging (excluding packaging used for dangerous goods or large-scale equipment and flexible packaging in direct contact with food) and grouped packaging. Cardboard packaging is also generally exempted from the requirements concerning transport packaging. Exemptions from the re-use obligations will be allowed subject to certain conditions, such as if the exempting Member State is on track to achieve its targets concerning waste prevention and recycling of packaging waste.

For Finland it is important that the re-use target does not concern milk and other highly perishable beverages where the use of re-usable packaging would not be appropriate in terms of food hygiene. It is also very good that wine is excluded from the target as in Finland this is primarily an import product and it would be difficult to create a re-use system for this. Finland also considers it important that the re-use obligations for transport packaging do not concern cardboard packaging and packaging used for large-scale equipment. Finland has actively advocated these exemptions. The other flexibilities allowed by the regulation will also be explored in detail.

Finland has supported the aim to promote the re-use of packaging in purposes of use where this is easy to apply and justified in terms of the environment. Obligations that are ill suited in the Finnish conditions have been excluded, but even now the implementation will be challenging for certain operators. 

Businesses selling take-away products will be obliged to offer customers the possibility of bringing their own containers to be filled with beverages or ready-prepared food, at no additional charge. By 2030, take-away activities must endeavour to offer 10% of products in packaging formats suitable for re-use. 

The re-use targets do not concern micro-enterprises. It will also be possible for operators to form pools of up to five final distributors to meet the re-use targets on beverages.

Requirements for safe and sustainable packaging

According to the proposal, all packaging must be recyclable. 

The regulation would set headline targets for minimum recycled content in plastic packaging. These do not concern compostable plastic packaging and packaging whose plastic component represents less than 5% of the packaging’s total weight. This exemption is important for some Finnish operators. The Commission will have to review the implementation of the 2030 targets and assess the feasibility of the 2040 targets. 

The proposal also calls on the Commission to assess, three years following the entry into force of the regulation, the state of technological development of bio-based plastic packaging and, on the basis of that assessment, to lay down sustainability requirements for bio-based content in plastic packaging. Finland has advocated a stronger role for bio-based plastics and the proposal has improved with regard to these.

The proposal contains stricter requirements for the presence of substances of concern in packaging. It also lays down labelling harmonisation requirements to improve consumer information and facilitate sorting. 

Member States will be exempted from the requirement to introduce a deposit return system if they reach a separate collection rate of above 80% in 2026 and if they submit an implementation plan with a strategy for achieving the 90% separate collection target. Finland’s current deposit return system meets these requirements. 

The proposal also prohibits single-use plastic packaging for fruit and vegetables, for food and beverages, condiments, sauces within the hotel, restaurant and catering sector, for small cosmetic and toiletry products used in the accommodation sector (e.g. shampoo or body lotion bottles), and for very lightweight plastic bags (e.g. those offered at markets for bulk groceries).

Inquiries:

Tarja-Riitta Blauberg
Senior Ministerial Adviser
tel. +358 295 250 059
[email protected]