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Unpacking Packaging and Packaging Waste

Friday, 17 February 2023
Position Paper Food & Drink Sustainability

HOTREC is presenting its position paper on the European Commission’s proposal on Packaging and Packaging Waste.

While the European Commission’s intent to prevent packaging waste goes in the right direction, its ambition to ban single-use packaging unilaterally and abruptly in HORECA is concerning.

We believe the coexistence of the two systems – single and multiple-use packaging – should be preserved to:
• Safeguard food safety and hygiene principles in HORECA as well as the health of our personnel and consumers.
• Limit unintended negative externalities such as economic, climate and environmental harms.
• Take into consideration the heterogeneous nature of the hospitality industry, seasonality, national specificities, and consumer behaviours.
• Appreciate the nature of our sector: a service-centred industry aiming to create positive experiences and provide the best options and choices to its customers.
• Allow the use of disposable packaging in HORECA while eating in under special circumstances e.g., health crisis, disruption of supply chains or when this is the most environmental and climate-friendly alternative.
• Prioritise small HORECA operators not capable of embracing integrated re-use systems due to a lack of finances, space, resources, time and staff.
• Consider the context in which the hospitality industry is operating while dealing with the economic crisis, the aftermath of the COVID-19 pandemic and unprecedented labour shortages.
• Take into account markets in the EU where the industry has massively invested in recycling and would welcome higher recycled targets.

HOTREC believes that the current proposal should be clarified and recalibrated so that the final law is future-proof and flexible enough to mitigate ongoing and future crises. We, therefore, call on the EU Member States and the European Parliament to address the following issues further elaborated in this paper.