RCI’s position paper: “Commission proposal for a Packaging and Packaging Waste Regulation” (May 2023)



This position paper highlights chances for the EU to lead the way to a sustainable packaging industry and to promote innovation

In November 2022, the Commission adopted the Proposal for a Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. The proposed regulation includes several rules that would – if implemented – push for a much stronger circular economy in the packaging sector, due to higher re-use and refill quotas, higher use of recycled materials and mandatory composting of certain hard-to-recycle products.

The Renewable Carbon Initiative (RCI) welcomes this proposal and wants to offer several suggestions to strengthen it further and get implementation closer to the market realities of Europe.

1. Set ambitious targets for all types of renewable content:
A complementary renewable content target should be added to the proposal promoting the use of bio- and CO2-based feedstocks in packaging similar to recycling.

2. Keep Article 8 as it is – scientific evidence shows that these products offer true environmental benefits from being compostable
The proposal, following scientific evidence, requires that certain types of tea and coffee packaging, sticky labels attached to fruit and vegetables as well as very lightweight plastic carrier bags shall be compostable in industrially controlled conditions in bio-waste treatment facilities.

3. Support the market uptake of all state-of-the-art recycling technologies
To actually achieve the ambitious recycling quotas and recycled content targets, technologies will have to evolve. Advanced recycling technologies (i.e. depolymerisation) are key.

Renewable Carbon Initiative
Date of publication
May 2023
File type