Brussels│Proposal for a Packaging & Packaging Waste Regulation

Position Paper


Increasing recycling and reuse rates are central parts of achieving the EU’s circularity objectives. The proposed review of the Packaging & Packaging Waste Directive will aim to bring packaging legislation in line with the objectives set out in EU strategies such as the EU Green Deal and the Circular Economy Action Plan.

Among several high-level targets, the Commission is aiming to have all packaging reusable or recyclable (in an economically viable way) by 2030. The measures contained within the proposal touch upon various industries and sectors which have an impact on the level of packaging waste generated. Collectively, they will aim to reduce packaging waste by 15% by 2040, compared to 2018 levels


General Comments

In principle the Malta Business Bureau supports efforts to reduce waste levels and increase recycling rates. Waste represents not only a loss of resources, but also leads to environmental degradation, processing and transportation costs, and spatial challenges, especially given Malta’s extremely limited land available for such activities. It is consequently in the interest of all actors, including businesses, to introduce measures which minimise waste where possible.

Aside from the environmental benefits, increasing emphasis on recycling may open the door for new market opportunities which businesses could meet. This is especially relevant for those involved in waste management, including the collection, sorting, or processing of recyclable and recycled materials. Likewise, packaging manufacturers will need to meet the increasing demand for reusable packaging and material, introducing another avenue to grow their business. Promoting more sustainable forms of packaging will also enable businesses to meet the increasing demand for greener products and practices, while also signalling their commitment towards waste reduction and sustainability more generally.

It is positive to note that the current Packaging & Packaging Waste Directive will be repealed and instead replaced by the proposed Regulation. This approach will contribute towards the further harmonisation of national measures concerning product packaging, which will have a direct positive impact on the proper functioning of the EU single market through increased legal certainty, lower adaptation costs, and a level playing field for businesses seeking to market their products in other member states.

Nonetheless, some measures included within the Commission proposal raise concerns over their practicality and may be excessive when compared to what they are trying to achieve. A major challenge shall be the anticipated cost of compliance for businesses. This will include both costs related to changing operational practices (e.g. from single use packaging to refillable options), and reporting obligations. ). Certain information needed relating to, for instance, permissible packaging and practices, needs to made available at the earliest possible to provide guidance and allow businesses sufficient time to transition away from current practices.

While an exact quantification will depend on the business in question and its starting point, the Commission’s own impact assessment concedes that gains will primarily be borne by consumers and the environment, while businesses will be faced by additional costs due to reuse and recycling schemes. The impact assessment adds that the latter costs will only be partially offset by decreasing expenditure on labour and raw material.

SMEs in particular will experience challenges in complying with the requirements of the proposed regulation, due to their limited resources and competition from larger businesses which may be in a better position to introduce operational changes and absorb additional costs.

Click here to read the Malta Business Bureau’s full position paper.

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