17 Oct 2022

Circular Economy Package: Round 2

In March this year, the European Commission published the first part of its Circular Economy Package, introducing proposals for an Ecodesign for Sustainable Products Regulation (previously called Sustainable Products Initiative), for new rules to empower consumers in the green transition, an EU strategy for sustainable and circular textiles and a proposal for a Regulation laying down harmonised conditions for the marketing of construction products.

The second part of the Circular Economy Package is now expected to be published on 30 November 2022 and will include, amongst other things, the long-awaited proposal for a revised Packaging and Packaging Waste Directive (PPWD).

The proposal for the revision of the PPWD is expected to put forward a change of legal instrument, turning the current Directive into a Regulation, and to substantially revise the content of the current Directive to introduce measures on waste prevention, reuse, recyclability, recycled content, compostable packaging, and other enabling measures.

The review of the PPWD can be a real game-changer, taking packaging sustainability to the next level, and represents a unique opportunity to introduce a coherent policy framework able to scale up investments in new technologies and infrastructure, and to develop innovative packaging solutions. However, this can only be achieved if it provides a future-proof regulatory framework, based on ambitious but also enforceable provisions. The revised PPWD must also enable a functioning Single Market for sustainable packaging, recycling, reuse, and also for secondary raw materials, where packaging is no longer treated as waste but as a valuable resource.

While the move from a Directive to a Regulation increases the potential for harmonisation across Member States, its core requirements shall be clearly detailed in the legislative proposal and not left to secondary legislation, and the internal market legal basis preserved. Arbitrary bans and targets should not be introduced unilaterally by EU Member States. The economies of scale and operational costs savings generated by the Single Market enable investments in sustainable solutions but fragmentation of the Single Market due to divergent national measures is undermining the implementation of a successful circular economy for packaging.

Stay tuned!


  • 30 March 2022: Publication of Circular Economy Package I


  • 30 November 2022: Publication of the European Commission Circular Economy Package II, including a proposal for the revision of the PPWD and:
    • A proposal for a Regulation on substantiating environmental claims using the product/organisation environmental footprint methods (green claims)
    • A communication for a policy framework for bio-based, biodegradable and compostable plastics
    • A proposal for measures to reduce the release of microplastics in the environment
    • An initiative on sustainable consumption of goods – promoting repair and reuse (right to repair)