On the 24th of April, euronews.green published an article regarding the Packaging and Packaging Waste Regulation (PPWR), that passed in the European Parliament on that same day. In the article, Matti Rantanen, director general of the European Paper Packaging Association (EPPA) is quoted calling the law “robust and evidence-based.” This claim comes as a surprise considering that EPPA has had a history approving and disapproving with the provisions of the law, and they have contributed as stakeholders in previous revisions of the law. After checking the evidence and studies that stand at the base of the law, and consulting with experts, we assessed that the claim is mostly true.
The source of the claim
The author of this claim, Matti Rantanen, is the general director of the European Paper Packaging Alliance (EPPA), a lobby group that works with European policymakers for policies related to packaging and packaging waste. The EPPA consists of a total of fourteen member companies related to the world of packaging and food consumption, like the Burgo Group, McDonald’s or the Paper Machinery Corporation.
The context surrounding EPPA’s recent activity is related with the European Packaging and Packaging Waste Regulation (PPWR), a revision project from the European Commission in November 2022 that aimed to approve new EU-Wide Rules on Packaging. Firstly, the EPPA disagreed with this proposal, and considered it placed “too much emphasis on reusable packaging”, instead of focusing on other “environmental-friendly options like single-use paper packaging.” But two years later, after the European Parliament announced that they had “provisionally agreed on the new regulations with the Council”, Rantanen and his group welcomed the regulation and said it was “evidence-based”.
The studies behind the claim
First, in order to verify the validity of the statement, we got in contact with Rantanen. He told us that, when he talks about “robust and evidence-based” studies, he is referring to a study commissioned by the European Paper Packaging Alliance (EPPA) and carried out by independent consultant Ramboll (a global architecture, engineering, and consultancy company), named ‘Comparative Life Cycle Assessment (LCA): single-use and multiple-use dishes systems for in-store consumption in quick service restaurants’. Rantanen stands that this study is the “only ISO standardized study made in Europe on the topic” and he says that it is the only one, according to him, that fulfills the requirements appointed by concerned scientists in an open letter they sent to the EU decision makers in September 2023.
Rantanen mentioned another study made by the European Commission’s Joint Research Center (JRC), and named ‘Exploring the environmental performance of alternative food packaging products in the European Union’, that had similarities with the Ramboll one: both of them confirmed the findings that recycling is better than reusing when it comes to environmental impact.
The Packaging and Packaging Waste Regulation
Before getting into the specific studies, it is first important to understand the regulation in question. The main goal of this regulation is to reduce packaging waste and ensure a more sustainable and circular economy when it comes to all packaging. A first proposal for the Packaging and Packaging Waste Regulation has been drafted in 2022, and it came as an amendment to the previous directive on the same topic. A directive being changed to a regulation means that all of its provisions go from suggestions to strict rules that have to be enforced by every Member State. The Committee on the Environment, Public Health and Food Safety was in charge of the regulation, appointing Frederique Ries as the rapporteur for it as well. The law passed in the Parliament on the 24th of April with 476 votes for, 129 against and 24 abstaining. Before this final decision, the law has gone through controversial debates, gaining attention in the media, after pressure from different lobby groups (such as the EPPA) and environmental NGOs.
The controversies tied to this law are not surprising, because the law’s targets will affect a lot of packaging manufacturers and big catering companies. The targets that the law is proposing are meant to reduce the waste that each EU citizen is generating by 5% by 2030, 10% by 2035 and 15% by 2040. In order to do this, the packaging manufacturers in each state have to follow the strict provisions of the law. They include cutting down on plastic use when it comes to packaging and investing in more sustainable materials that are usually more expensive, which will have an impact on the manufacturers profits, hence the backlash on the law. The regulation is closely tied to the European Green Deal, bringing up the conversation about Climate Change and taking action towards a more environmentally friendly EU.
The role of research studies in environmental regulations
Research studies have been an essential part of the Packaging and Packaging Waste Regulation’s (PPWR) fundamental components. These studies are the foundation for setting high goals to reduce package waste, increase recyclability, and promote reusable packaging options. Policymakers use these studies’ thorough data analysis and detailed evaluations to establish the targets that we have discussed earlier and ensure they are in line with the EU’s sustainability goals.
Environmental rules are significantly impacted by standards established by the International Organisation for Standardisation (ISO). ISO standards offer globally accepted systems for evaluating and controlling environmental consequences. Adopting ISO standards will help legislators ensure that regulations are transparent, consistent, and founded on best practices, which will promote compliance and international cooperation.
Another important method for developing environmental legislation is the life cycle assessment (LCA). Life cycle assessment (LCA) is a technique used to measure the environmental impact of products or activities using specialised equipment. It considers every facet of production, from sourcing raw materials to ending with disposal. The Life Cycle Inventory (LCI), which collects data on materials, energy use, and emissions, and the Life Cycle Effect Assessment (LCIA), which evaluates this data to create an environmental effect map, are two crucial LCA procedures.
An environmental profile with a list of the main consequences and where they occur in the life cycle is produced by an LCA research. This makes comparing possibilities and figuring out how to make them greener easier. The recommendations for conducting Life Cycle Assessments (LCAs) provided by ISO standards like ISO 14040 and ISO 14044 establish a connection between LCA and ISO. These guidelines provide uniformity and dependability, which improves the transparency, comparability, and legitimacy of LCA results for various goods and sectors.
Moreover, research findings, ISO standards, and LCA together strengthen legislation by establishing technical specifications for packaging materials. Policymakers use actual data and standardized procedures to set clear standards for recyclable, reusable, and environmentally friendly packaging. This approach ensures environmental integrity, fosters innovation in packaging design, and supports the PPWR in advancing the EU’s sustainability objectives and promoting a circular economy.
What do “evidence based” and “backed up by science” stand for?
These adjectives, used by Rantanen to defend the veracity of the studies that sustain the law, refer to practices or programs that are supported by a large amount of scientific research. In the case of the PPWR regulation, the indicators that can be appointed in the studies are the ones defined by a group of scientists in the open letter sent to EU decision makers back in September 2023.
We found and checked these requirements by reading and locating them in the Ramboll (‘Comparative Life Cycle Assessment (LCA): single-use and multiple-use dishes systems for in-store consumption in quick service restaurants’ review) and JRC (‘Exploring the environmental performance of alternative food packaging products in the European Union’, 2024) studies, the ones backing the source of the claim, in order to confirm that they are “backed up by science”. Both studies fulfilled the eight requirements, which are:
- Is a peer-reviewed, independent study conducted using the ISO 14040 and 14044 frameworks.
- Respects steps laid out in ISO standards, starting with clear scope definition and comprehensive description of inventory data.
- Assesses the highest possible number of environmental indicators.
- Includes the full life-cycle of the product reviewed.
- Includes clear hypotheses and assumptions on breakage rate, return (trip) rate, weight and end of life strategies.
- If assumptions or lower quality data on parameters have been used, performs a sensitivity analysis.
- Considers different business model configurations for the use and end of life phases.
- Integrates static comparisons with dynamic ones such as the evaluation of the environmental break-even points.
Skepticism coming from environmental scientists
Once we had checked the robustness of these two studies following the eight-point criteria established in the open letter from September 2023, we got in touch with one of the signators of this document, Dario Cottafava, researcher at the University of Turín, in order to find out what he thinks almost eight months later when the PPWR passed in the European Parliament.
He qualified the Ramboll study as “misleading” and invited us to read another open letter published in the International Journal of Life Cycle Assessment made by some signatories from the open letter and published on the 11th March 2024. The letter provided recommendations for ensuring the scientific robustness of comparative LCA studies that evaluate single-use and reusable packaging. Contrary to the open letter from September 2023, this one provided an eleven-point criteria that the LCA studies should follow to guarantee scientific robustness. The Ramboll study did not fulfill three of them (it was not an independent study and a conflict of interest is assumed, there is no transparency of inventory data and there is no environmental break-even points analysis), and partially fulfilled another four criteria. For this reason, the authors recommended that the results of this study should be viewed with caution by decision-makers.
In relation to mentioned letter, Cottafava as the leading author said that he can’t be satisfied with the PPWR because “some targets have been clearly watered down due to the lobby received by the paper and fast-food industries and much derogation have been introduced, for example if a recycling target of 90% will be achieved, no minimum target on reuse will be required”.
Even though the Ramboll and JRC studies fulfill the eight-point criteria from the initial open letter, this kind of affirmations and the eleven-point criteria comparative study reflect that there is a part of the scientific community that is skeptical of the PPWR, and the reliability and robustness of evidence that informed it.
In that comparative study they even conclude that from now on, “future comparative studies must fulfill the (eleven) above listed requirements”, and that “any report that assesses the environmental impacts without respecting the characteristics listed above lacks robustness, reliability and impartiality”. But, since the Ramboll and JRC studies were done before the publication of this comparative study, they fulfilled the previous eight requirements flagged by the scientists in the open letter from September2023.
Conclusion
It is important to point out that the source of the claim is the president of the EPPA, an association that is part of the stakeholders consulted in the Revision of the Packaging and Packaging Waste Regulation, and a lobby group that represents big food companies which have a big interest in the outcome of the regulation. By saying that the PPWR is “evidence-based” and “backed up by science”, Matti Rantanen (Director General EPPA) referred to the two studies – the LCA study commissioned by the European Commission, and the Ramboll study commissioned by the EPPA. Both studies were considered in the final revision of the PPWR that passed in the European Parliament. Our research showed that both of the studies brought up by the EPPA comply with the ISO 14040/44 and the 8 point criteria which were listed in the open letter signed by environmental scientists in September 2023.
However, another letter to the editor of The International Journal of Life Cycle Assessment from March 2024 signed by nine scientists suggests eleven LCA criteria, and states that four studies on single-use and reusable systems for dine-in and food take-away sector – including the Ramboll one – do not fulfill all or some of the crucial criteria. In conclusion, because of the skepticism shown by the scientific community, and the evidence that to an extent scrutinizes the methodology, transparency and reliability of these studies, we assess the claim to be mostly true.
RESEARCH | ARTICLE © Màrius Lamor, Autonomous University of Barcelona (Barcelona, Spain) | Timea Fekete – Babes Bolyai University (Cluj, Romania) | Louis Wouters, Thomas More University of Applied Sciences (Mechelen, Belgium) | Mariam Qavshibaia, Georgian Institute of Public Affairs (Tbilisi, Georgia) | supervised by Assistant Professor Petra Kovačević, University of Zagreb (Zagreb, Croatia)
This factcheck was produced during the Blended Intensive Programme EU Elections Lab at the School of Journalism in Utrecht, The Netherlands.
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