The Consumer Products Sector and the EU's Circular Economy Policy for Packaging and Packaging Waste

An InfluenceMap Briefing

February 2023

An Analysis of the Consumer Products Sector's Engagement on the EU's Packaging and Packaging Waste Regulation

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InfluenceMap has undertaken analysis of European consumer products companies' and their industry associations' policy engagement on a key policy in the EU's Circular Economy Action Plan, the Packaging and Packaging Waste Regulation.

The Packaging and Packaging Waste Directive (PPWR) is the key policy of the European Circular Economy Action Plan (CEAP) which aims to reduce the amount of packaging and packaging waste in the EU. It builds on the 1994 Packaging Waste Directive, and the first review of the policy in 2018. The legislation proposes targets and mandates to reduce packaging waste, increase reuse and scale up recycling through packaging design and measures aimed at end use.

After predominantly negative engagement from the European consumer products sector in 2020-23, notably following the leak of a draft of the PPWR revision in early November 2022, the EU Commission's ambition for the policy was clearly weakened. Strong measures and targets were lowered, compared to the leaked draft, in the official proposal published in late November 2022. However, despite intense negative lobbying from industry associations and a notable lack of engagement from the focus companies in this briefing, the proposal retained some ambition.

InfluenceMap detected limited engagement from focus companies on the PPWR in public and direct engagement with policymakers. No grocery retailer focus companies engaged on the PPWR revision. Overall, in the fast moving consumer goods (FMCG) sector, positions on the PPWR revision were mixed. Henkel and Coca-Cola Europacific Partners (CCEP) took unsupportive stances on the policy, but Danone and Nestlé were positively engaged. L'Oréal supported the PPWR revision with some exceptions.

The companies' industry associations are engaged overwhelmingly negatively with the PPWR, with six out of seven taking oppositional or unsupportive stances on the file. Several national business associations, including the French Business Federation (Medef) and the Federation of German Industries (BDI) stated that the revision is "unnecessary."

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