PPWR: European glassmakers are speaking out
In a note sent on November 21 to European Commission President Ursula von der Leyen, Executive Vice President Teresa Ribera, Executive Vice President Stéphane Séjourné, and Commissioners Valdis Dombrovskis and Jessika Roswall, FEVE officials warned of the urgent need to introduce simpler rules on packaging reduction in order to promote the competitiveness, creativity, and innovation of the European glass industry.
“As CEOs of Europe’s leading hollow glass manufacturers,” the statement emphasizes, "we are writing to express our deep concern about the significant negative impact that the packaging minimization requirements set out in the new Packaging and Packaging Waste Regulation (PPWR) are likely to have on the global competitiveness of key European industrial value chains that depend on glass packaging, including the food, wine, spirits, cosmetics, perfumery, beer, non-alcoholic beverages, and other design-focused sectors. These provisions risk undermining the Clean Industrial Deal and efforts to strengthen Europe’s industrial competitiveness by maintaining its global leadership in innovation and circular performance.
It also points out that "with 130 sites in 21 EU Member States and thousands of customers, from large multinationals to SMEs, the glass packaging industry employs 50,000 people and contributes to 825,000 jobs across Europe in industries that sell products packaged in glass. Our industry’s commitment to manufacturing excellence and sustainability defines the quality, creativity, and design of European packaging around the world. Glass-packed products embody the world’s most successful and recognized European brands, combining superior quality with cutting-edge manufacturing, supporting millions of jobs, and boosting exports worldwide. These products alone account for €140 billion in EU exports each year, representing nearly 6% of the Union’s total trade. Collectively, we stand at the crossroads of culture, craftsmanship, and circular innovation, continually investing in sustainability while preserving the quality, safety, and distinctiveness that define European production."
As an energy-intensive sector, the statement continues, European glass manufacturers are investing heavily in decarbonization, energy efficiency, and furnace modernization, while also being at the forefront of circularity. Glass is infinitely recyclable, with very high collection (80.8%) and recycling (74.9%) rates across Europe. Recycled glass is already the main raw material used in the production of new glass containers, and we are ready to support the adoption and growth of reuse systems across the EU."
“However,” the statement insists, "all these efforts depend on a clear, favorable, and consistent regulatory framework. While our industry is actively working to ensure the successful implementation of the PPWR, there is growing concern about the impact of the extremely rigid packaging reduction requirements contained in Article 10, Recital 60, and Annex IV of the new regulation on the ability of European design-led industries to continue to innovate and compete globally."
It particularly emphasizes the PPWR requirement that all packaging must be reduced to the “minimum necessary” weight and volume by January 1, 2030, without taking into account marketing, brand differentiation, product presentation, and consumer acceptance, must be reconsidered as it unduly restricts packaging design and innovation in Europe, with extremely harmful commercial consequences for entire European value chains and the ability of EU brands and SMEs to compete globally.
"While realistic packaging reduction measures, combined with other ambitious sustainability requirements, can lead EU industries to further improve the eco-design of packaging, promote lightweighting, and reduce excessive packaging waste, the communiqué emphasizes that “the current wording of the above provisions is disproportionate, creates significant legal uncertainty in the market, discourages investment and innovation in design and manufacturing, and risks shifting production and value creation outside the EU.”
The Commission is therefore asked to adapt Article 10 and related provisions of the PPWR through the next environmental omnibus or other legal tools in order to provide clarity, proportionality, and legal certainty to our industry and our customers. “This is necessary to ensure compliance, restore consistency between environmental ambitions and industrial competitiveness, and preserve investment, innovation, and skilled jobs in Europe.”
"The pragmatic adjustments we are advocating (see box below) are essential to recognize the important role that key drivers of economic competitiveness, such as marketing, brand differentiation, product presentation, and consumer acceptance, play in ensuring the leadership of European brands and high-quality products in today’s globalized world. This is crucial to avoid dull uniformity on store shelves and prevent the erosion of European leadership in glass packaging and product design, creativity, and high-end manufacturing in a number of key industries such as beverages, spirits, gourmet products, cosmetics, and perfumery."
It concludes that “the EU’s circular economy goals can only be achieved if its industries remain strong and competitive in the internal market. We stand ready to work with the European institutions to make this a reality.”
FEVE’s main requests regarding packaging reduction
Main concerns regarding the current wording of Article 10, Recital 60, and Annex IV of the PPWR.
1. Overly rigid packaging reduction criteria overlook the real drivers of global competitiveness
Article 10 requires all packaging to reduce its weight and volume to the minimum necessary by 2030, in accordance with the performance criteria listed in Annex IV. These criteria exclude marketing, product presentation, brand identity, and consumer acceptance, which are essential elements for the global competitiveness of European products packaged in glass. For sectors such as wine, spirits, cosmetics, perfumery, beverages, and gourmet products, freedom of design is essential.
2. Lack of legal clarity on key concepts such as “functionality” and “shape”
The PPWR does not clearly define the ‘functionality’ or “shape” of packaging, leaving room for divergent interpretations among Member States and rendering the provision unenforceable from a compliance perspective. The term “functionality” is defined inconsistently: Article 3(1) includes product presentation as a function, while Recital 60 and Annex IV explicitly exclude marketing, consumer acceptance, and brand identity as valid justifications. Similarly, the lack of a definition of “shape” risks leading to divergent interpretations within the single market and disproportionately affects glass packaging, whose shape and design are integral to product identity and consumer recognition.
3. Insufficient protection of intellectual property and innovation
Article 10(2)(a) only protects designs and trademarks registered before February 11, 2025. This cut-off date is highly problematic: all new packaging placed on the EU market from now on would not be able to benefit from meaningful intellectual property protection, which would discourage innovation and creativity in the field of glass packaging. Furthermore, design rights are not absolute and are often contested, while many products are regularly redesigned, meaning that renewals could invalidate existing exemptions. These limitations restrict brand identity and hinder innovation, thereby weakening the competitiveness of Europe’s most creative and high-end glass-packaged products.
4. Risk of setting rigid maximum limits in terms of weight and volume
Article 10(3) allows for the setting of harmonized standards to establish maximum weight/volume thresholds for “the most common types of packaging.” These fixed limits contradict the case-by-case approach of Article 10, do not reflect the diversity of products, and would significantly limit innovation and design freedom in the glass sector.
FEVE recommendations
1. Ensure a fair balance between packaging minimization and design freedom
Article 10(2) (and the corresponding recital 60) should be revised to recognize that reduction must coexist with marketing, product presentation, brand identity, and consumer acceptance, particularly for high value-added sectors where design is an integral part of the product. Annex IV should also broaden the concept of “functionality of packaging” to cover cases where design is an integral part of consumer expectations and brand experience, particularly (but not only) for high-end products.
2. Strengthen intellectual property protection and review the 2025 deadline
Article 10(2)(a) and Recital 60 should be revised to review the February 11, 2025 deadline, which would leave designs registered after that date unprotected and discourage innovation. This is essential for sectors where design cycles are short and creativity is the driver of competitiveness. Exemptions should also apply to redesigned or renewed products, as regular updates are essential to competitiveness in sectors such as cosmetics, perfumery, and premium beverages.
3. Amend references to maximum weight/volume limits
References to maximum weight, volume, wall thickness, or empty space in recital 62 and Article 10(3) should be amended. Harmonized standards should provide assessment methodologies, not fixed thresholds. The rules must remain flexible, applicable, and consistent with the product-specific and case-by-case approach provided for in Article 10(1). Rigid limits are inapplicable to glass packaging, which is used for a wide variety of products with different needs, and would compromise design freedom, innovation, and product differentiation. This would be the only way to preserve innovation while ensuring that the regulation remains applicable in practice.
