Europe’s packaging directive – getting it right for the coatings sector

06 November 2023

Alina Selivanova, PPG Global Strategic Sourcing Manager, discusses what implications the European Commission’s proposal for Packaging and Packaging Waste Regulation could have on the coatings sector and the need for amendments for certain sectors

Like many industries, the coatings industry is an important contributor to the sustainability goals of the European Green Deal. Coatings protect an enormous variety of products and surfaces, increasing service life and reducing maintenance and waste. PPG supports the Green Deal objectives and we are committed to innovating for more sustainable products and manufacturing processes to ensure a transition to a more circular and resilient EU economy.

One of the key elements of the Green Deal is the European Commission’s (EC) proposal for Packaging and Packaging Waste Regulation (PPWR). This is an important commitment to ensure circularity for packaging placed on the market.

PPG is already a leader in this area. The company’s architectural coatings packaging in Europe has up to 80% recycled content. In Denmark, we recently shifted our architectural product packaging from virgin plastic to entirely post-consumer recycled plastic. PPG is also developing initiatives and partnerships with organisations focused on circularity to find ways to divert waste paint and packaging from ending up in landfills.

However, there are some areas of concern within the PPWR as it relates to the coatings sector. Coatings protect an underlying substrate from corrosion or other degradation mechanisms presented by the environment. The coatings mixing and application process is extremely contact-sensitive to external contaminants and a contaminant-free mixing and application environment is essential to ensure that the coating delivers the required durability and protection.


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The current legislative proposals, which include recycled content for packaging of up to 65%, could be problematic for certain applications in the coatings sector, because for contact sensitive products to maintain their performance, it is key to retain control of potential contamination via contaminant migration from the packaging material to the coating. Up until today, only virgin packaging has been deemed suitable in certain industrial applications, such as in automotive or aerospace, in order to provide the required stability.

The PPWR also lays out re-use targets for the transport and delivery of products to the end-user, including the requirement for transport packaging to be reusable in certain cases. These rules apply to many of the common types of packaging used by our industry, such as pails and drums, intermediate bulk containers and canisters. The rules are also problematic for certain sectors, given that they could lead to the introduction of external contaminants from the surface of the transport packaging into the coating.

Another concern is lack of clarity around the method for calculating the recycled content. This oversight could impede the development of the recycling sector and hence, the availability of suitable packaging with recycled content. PPG supports proposals from the chemical and plastic industries to use a mass balance approach to accurately calculate and verify the amount of recycled content allocated to products.

As such, we are recommending amendments to the PPWR proposal to reflect the specificities of certain sectors of our value chain. These include an amendment to the PPWR proposal to consider contaminant-sensitive coatings and application environments in the scope of contact-sensitive packaging, and exempt contaminant-sensitive coatings from recycled content obligations and re-use targets.

This approach, along with a clearer method of ensuring the recycled content of packaging, would help prevent issues regarding contamination of contact-sensitive products, and better support coatings and packaging circularity to meet the long-term goals of the EU Green Deal.

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