Upcoming legislative requirements

Recent years saw unprecedented dynamics in the European legislation around plastic packaging and sustainability in general, with the overarching goal to support the ambitious targets of the European Union regarding climate neutrality and the circular economy. We have been active participants of these legislative processes by taking part in different working group discussions and drawing position papers to clarify some aspects that are crucial for introducing a truly sustainable and feasible system.


New Europe-wide rules for packaging

The European Commission presented the draft of the new EU Packaging Regulation to the European Parliament and Council on 30 November 2022, and the legally binding regulation is scheduled to follow in mid 2024. As per the draft Packaging and Packaging Waste Regulation (PPWR), all packaging in the EU is to be recyclable by 2030 (our target year for this is 2025). A quota for the use of PCR material in plastic packaging is set to ensure this: the quota will be 30% for PET packaging used for food and contact-sensitive packaging as well as for single-use plastic drinks bottles, 10% for food-grade non-PET plastic packaging, and 35% for all other plastic packaging. Reusable packaging is also to be promoted by means of quotas and mandatory deposit systems. In the future, beverages and food also have to be offered in reusable or refillable packaging. Unnecessary single-use packaging for fruit and vegetables is to be banned immediately, as will miniature packaging in the hotel and gastronomy sector from 2030 onwards. An EU-wide labelling obligation is intended to provide clear information on materials, collection and disposal for all packaging types. In addition, the EU intends to introduce rules for the use, design, disposal and recycling of compostable plastics.

We consider the PPWR proposal of the Commission to be an important step towards a circular economy. However, we emphasised in a position paper that there is a need for clarification and further improvements on certain regulatory aspects, including the equal treatment of all packaging solutions regardless of their material to enable fair ecological competition. Indeed, if targets or legal requirements are just applied to plastic packaging as proposed, the market shifts towards non-plastic packaging solutions with less legal pressure, but no ecological benefit and an even higher CO2e footprint.


Tackling plastic pollution and microplastics in particular

Microplastics are small plastic particles up to 5 mm in diameter. They are coming increasingly into focus due to their long-lasting negative environmental and health impacts: the abrasion of synthetic textiles and car tyres as well as the degradation of plastic waste from either domestic, industrial or agricultural use result in a spread of microplastics into all layers of our ecosystems (including food and drinking water).

In 2020, the EU adopted its new Circular Economy Action Plan, announcing an initiative to address the unintentional release of microplastics into the environment. Among other goals, this aims to develop labelling, standardisation, certification and regulatory measures on the unintentional release of microplastics, including measures to increase the capture of microplastics at all relevant stages of products’ life cycles.

This was followed by the 2021 Action Plan called ‘Towards a Zero Pollution for Air, Water and Soil’, aiming to reduce different types of pollution to levels no longer considered harmful to health and natural ecosystems. One specific target for 2030 is to improve water quality by reducing waste, plastic litter at sea (by 50%) and microplastics released into the environment (by 30%).

To monitor the release of microplastics into the environment, the European Commission plans to introduce a reporting scheme for all producers of plastic materials from 2024 onwards. In line with this initiative, we implemented a plan for our plants to help them achieve zero pellet loss. The programme is based on the voluntary guidelines introduced by the Austrian government to prevent plastic raw materials from entering waterbodies, but ALPLA expanded the initiative to its plants globally. By 2022, we introduced a Zero Pellet Loss policy in 47 of our plants, initiating major changes in our logistics by installing custom-built vacuum cleaners and drainage systems, among other initiatives.

In parallel with the European Union, the United Nations are also working on a legally binding plastic treaty by 2024. In March 2023, representatives of 175 UN Member States committed to end plastic pollution, addressing the full life cycle of plastic, including its production, design and disposal. ALPLA endorses the initiative and actively participates in the Business Coalition for a Global Plastics Treaty, as this could give another boost to the development of the circular economy globally.

Stricter reporting requirements on sustainability

The European Union has initiated a series of legislative acts which require large companies to publish regular reports on the social and environmental aspects of their business, including a detailed risk assessment of their whole value chain. While these acts will only come into force in the upcoming years, we have already started to prepare for the new requirements in order to have adequate processes and data governance in place by the time mandatory reporting will be applicable to ALPLA.

The Corporate Sustainability Reporting Directive (CSRD) and the accompanying new European Sustainability Reporting Standards (ESRS) will enable a consistent assessment of sustainability performance across companies and industries (especially due to the mandatory external assurance of the annual sustainability reports), potentially serving as the basis for future investment decisions.

The EU Taxonomy Regulation also aims to link financial and non-financial performance by developing and maintaining a classification of business activities which are deemed sustainable – i.e. aligned with a net zero trajectory by 2050 and with broader environmental goals – based on a set of criteria. Mandatory reporting on our business activities aligned with EU taxonomy will come into effect in parallel with CSRD. Nonetheless, we are already identifying activities that could be aligned to the strict criteria.

Moreover, the EU is currently working on its Corporate Sustainability Due Diligence Directive (CSDDD), with the focus of identifying and mitigating environmental and human rights-related risks along the whole value chain. This complements CSRD with actual requirements for companies to handle risks and opportunities among their suppliers (upstream) as well as customers and consumers (downstream).

Finally, the European Commission published a proposal of the Green Claims Directive in March 2023, with the ultimate goal to crack down on greenwashing by ensuring that environmental claims are supported by verifiable and audited claims. We are closely monitoring the evolution of this initiative, especially as Member States will be responsible for the monitoring, potentially leading to a non-harmonised approach within the European Union.​