Our PPWR priorities

Updated: 14 February 2024

Natural Mineral Waters Europe (NMWE) supports the Packaging and Packaging Waste Regulation (PPWR) in its pursuit of a circular economy and packaging waste reduction. Balancing ambition with practicality is key, safeguarding the vitality of SMEs and maintaining convenience and healthy choices. As trilogue negotiations commence, finding solutions which reflect a collective commitment to a circular economy is imperative.


We support complementarity between reuse and closed-loop recycling targets. From an environmental perspective, the benefits of one approach versus the other depends heavily on the context. For producers operating in rural areas, the obligation to bottle at source will be an important factor due to the distances from the source to the point of sale. A recent study from the Norwegian Institute for Sustainability Research found that their highly effective recycling system performed better than all reusable packaging models, due, in large part, to the increased transport and carbon footprint associated with reusable packaging.

A flexible approach also acknowledges the value chain's sustained investments in closed-loop recycling, and the threat a rigid stance poses to the viability of many companies, especially our many SMEs.

Our ask: Allow complementarity between reuse and recycling for packaging materials and formats, based on environmental footprint.

Reuse Targets

While significant investments are required for producers to shift to reusable packaging, in expensive new bottling lines and reverse logistics, there is no assurance that retailers will adopt products from every producer. This would pose a threat to the small and medium-sized enterprises (SMEs) which form the backbone of our sector.

Keeping the same reuse targets, but lifting them from on individual producers, would maintain the same level of ambition, without putting SMEs at risk.

Our ask: Lift reuse targets from individual producers to uphold ambition without putting at risk the viability of SME producers.

Grouped Packaging

Plastic films are necessary to facilitate handling at all distribution stages. This is particularly the case for milk and water, which consumers typically purchase in six-pack bundles, supporting their basic daily nutrition and hydration needs. From a sustainability perspective, shrink films for grouped packaging are the most efficient solution. Banning shrink film for bottles would introduce logistical hurdles for retailers and inconvenience for consumers, without providing eco-friendly alternatives.

Our ask: Allow grouped packaging for natural mineral water and spring water, considering their role in sustainability and consumer convenience.

Deposit and Return Systems (DRS)

Deposit and Return Systems have consistently outperformed Extended Producer Responsibility (EPR) schemes in the EU, achieving 40% higher collection rates on average. Along with access to recycled material, high rates of separate collection and recycling are essential to meet PPWR and Single-Use Plastics Directive (SUPD) targets. DRS provides more efficient collection and is a key enabler for achieving recycled content targets.

Our ask: Mandatory DRS, with exemptions limited to very high-performing EPR systems.

Priority Access

Beverage producers should be afforded priority access to recycled material from their bottles. This ensures material isn't diverted into non-recyclable applications. Preventing downcycling in this way is a crucial step to enabling compliance with mandatory recycled content requirements, such as the 30% target set by the SUPD for 2030 for our sector’s packaging. This principle should apply to all producers who become subject to mandatory recycled content targets.

Our ask: Priority access to recyclates for all sectors with mandatory recycled content targets, preventing downgrading of materials.


The success of the PPWR relies on a pragmatic framework which supports sensible change and provides the right legislative tools to the producers implementing policy. As stakeholders engage in trilogue discussions, we stand behind the integration of DRS, priority access to recycled material, complementarity between reuse and recycling, protection for SMEs, and allowing grouped packing for large format natural mineral water and spring water, reflecting our commitment to environmental goals while considering practical and economic realities.