12 Jul 2021

Sustainability aspects specific to packaging must be exclusively governed by the PPWD

Announced in the New Circular Economy Action Plan presented in March 2020, the Sustainable Products Initiative (SPI) aims to make products fit for a climate neutral, resource efficient and circular economy, in line with the objectives of the European Green Deal. This initiative, co-led by DG Energy, DG Environment and DG Internal Market, will entail the revision of the Ecodesign Directive and the widening of its scope beyond energy-related products. It will also propose “additional legislative measures as appropriate”.  

Whilst the Commission made it clear that the initiative will address products such as electronics and ICT equipment, textiles, furniture, steel, cement and chemicals, it is still not clear, to date, to what extent packaging will be addressed. The assessment of the possible inclusion of packaging is still ongoing and the Commission is likely to take a decision only once the Impact assessment is completed (Q4 2021).   

The Packaging and Packaging Waste Directive (PPWD) is the EU regulatory framework that determines the conditions for placing packaging on the EU market. These include sustainability criteria, which play a key role in enabling the uptake of climate neutral and circular packaging solutions. The ongoing review of the PPWD is focused on translating these goals into concrete regulatory measures.  

To avoid policy inconsistency and to ensure compliance with the EU Better Regulation agenda, given the intrinsic role of packaging in relation to the packaged product, it is crucial to exclude packaging from the scope of the SPI.  Sustainability measures specific to packaging need to continue to be governed by the PPWD, and any implications of product specific legislation on packaging should be duly assessed to avoid risks of undermining packaging functionalities.  

Similarly, a Digital Product Passport should not apply to packaging but only to the product it contains. The dematerialisation of information currently placed on packaging could be a positive aspect of the Digital Product Passport as it would reduce the space needed on packaging and for accompanying instructions that provide certain product-related information.  


  • The work on the Sustainable Products Initiative was launched in 2020. The European Commission held a public consultation on the initiative from March to June 2021.  
  • The Commission’s consultants (consortium led by Trinomics) organised a series of stakeholder workshops in April-May 2021 to present the initiative, its objectives and timeline, and gather initial feedback on several elements of the SPI, including the Digital Product Passport, social aspects related to the initiative, and the revision of Ecodesign rules.  
  • The last two scheduled workshops, on the economic and administrative impacts of the policy options, and on the market surveillance and enforcement of the SPI, were cancelled. 
  • The Impact assessment study is due to be finalised by the Commission in autumn 2021. 


  • Q3-Q4 2021: Finalisation of the Impact Assessment study. The legislative proposal will be adopted at Commission level by the end of 2021, in conjunction with the legislative proposal on Substantiating Green Claims. 

EUROPEN members: Do not hesitate to visit the dedicated members’ area of our website here to know more about our work on the Sustainable Products Initiative.