On 6 September, Ecommerce Europe together with Bundesverband E-Commerce und Versandhandel e.V., the German digital commerce association, jointly organised a roundtable on “SMEs and the transition towards sustainable e-commerce packaging”. The meeting gathered e-commerce sellers with a representant from the European Commission for a fruitful exchange of views on the upcoming Packaging and Packaging Waste Regulation.
Highlighting the importance of the subject for our sector, this event represented an opportunity to discuss the state of play of the negotiations as well as the challenges that lie ahead for smaller businesses operating online. While The Commission reaffirmed its ambition for the new rules, participants exchanged on a balanced way forward for this Regulation and presented their day-to-day experience with packaging.
The Packaging and Packaging Waste Regulation was proposed by the European Commission on 30 November 2022 to update the EU legislative framework on packaging and packaging waste. This new Regulation will aim at defining an ambitious framework for improving the sustainability of packaging and reducing packaging waste in a unified manner throughout Europe.
As the proposal is currently in the process of being discussed within the European Parliament and the Council of the EU, policymakers are considering various options on a series of subjects that will have a big impact on the e-commerce sector. Some of which were thoroughly discussed during the roundtable.
40% empty space ratio
With the Packaging and Packaging Waste Regulation proposal, the European Commission suggested to set a maximum empty space ratio of 40% for e-commerce packaging. MEPs are still considering different options, including applying the maximum void space as an average of all packaging placed on the market by an operator on a yearly basis, or providing for some exemptions where the empty space ratio could be exceeded. At the roundtable, the 40% empty space reduction target was extensively discussed.
Sellers showcased their void-space reduction and packaging minimisation efforts. They further demonstrated the scale of the burden that such target would represent for companies to implement and monitor. Indeed, the ability of sellers to reduce void space in e-commerce packaging depends on the product sold and its physical characteristics like dimensions, fragility, form, or portability. It also depends on the shipment conditions, and the type of packaging used to ship it.
Therefore, participants highlighted the need for flexibility to ensure that the rules do not lead to additional packaging being needed to comply with the rules, which would in turn undermine the environmental objective of the commission’s proposal.
Participants also discussed examples of reusable packaging systems in e-commerce. The European Commission is suggesting setting reuse target for all types of packaging, including e-commerce packaging. The EC is suggesting 10% reusable e-commerce packaging by 2030 and 50% of reusable e-commerce packaging by 2040. On the reuse target, MEPs are divided between maintaining or increasing targets for reuse, and lowering the target (including removing the target for 2040, and allow for a later re-assessment).
We heard from the company Memo AG, which created the reusable packaging system Memo Box, which now represents 24% of all packaging sent to customers by Memo AG. We also heard about the challenges to grow beyond this share of reusable packaging, because of the overall costs of operating such systems (especially when trying to grow cross-border), customers’ willingness to pay more for this type of packaging, and finding the right incentives to ensure the boxes are return, etc.
Extensive Producer Responsibility (EPR)
As one of the most important barriers to cross-border trade for smaller companies in the EU today, difficulties resulting from the fragmented Extensive Producer Responsibility (EPR) European landscape were also discussed. Retailers selling cross-border explained that to be compliant under the current regime, they have to go through very burdensome and numerous procedures in order to register in every single Member States they operate in. Today, a small seller selling online will have to pull out from some market because the level of complexity for the registration and compliance is too high, and the cost and administrative burden would be completely disproportionate.
Ecommerce Europe believes that the PPWR proposal, and the current discussions in the EP and Council lack ambition to address the core of the problem, which is the complexity of the current systems, and are instead discussing possible solutions, involving online platforms, which would impact further sellers in the EU.
This is why participants advocated for a more ambitious approach and an even more harmonised system with solution that could facilitate a single point registration across all Member States. Such a solution would relieve small companies of this burden and extra costs while lifting a considerable barrier to the free circulation of packaging and cross-border trade in Europe.
While the European Parliament and Council continue their negotiations and work towards adopting their final positions, Ecommerce Europe will follow through with its advocacy efforts on the above-mentioned concerns to ensure a balanced text for businesses of all sizes. Here you can find our full position paper highlighting the main concerns and key recommendations from our sector on the Packaging and Packaging Waste Regulation proposal.
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