Our proposal for a clearer chemical safety and transparency regime in the PPWR revision.

We from WECF welcomes the EU Commission’s proposal to revise the EU Packaging & Packaging Waste Regulation (PPWR). The European Commission’s proposal for a new PPWR contains good approaches, but it is not yet ambitious enough and leaves out several important points. WECF calls on EU authorities to tighten up rules on harmful chemicals in packaging. As an international ecofeminist network of 250 women’s and civil society organisations (NGOs) committed to a healthy environment and actively and progressively working towards a toxic-free future at EU level, WECF calls on the EU authorities to promote more consistent protection of the climate, resources, environment and health – especially the most vulnerable groups such as pregnant women, children and young people – also in the field of packaging policy.

WECF e.V. (Germany) is a member of the German alliance Exit-Plastik and co-author of the submission [1] on the PPWR amendment of Exit-Plastik (via HEJSupport). WECF support all the demands made there:

  1. Packaging avoidance as top priority
  2. Development of multi-purpose pool systems geared to the public good
  3. Clear rules on chemical safety and transparency
  4. Ensure ability of circularity while complying with the waste hierarchy
  5. Removing fake solutions such as “bio” plastic
  6. Reinforcing extended producer responsibility

As an NGO working mainly on chemicals policy, with this submission we would like to highlight the focus on chemicals in packaging, the gender aspect and the urgent need to take these aspects into account in the revised PPWR.

Harmful chemicals in plastics

We at WECF are calling for a clear regulation on chemical safety and transparency under the PPWR revision. The PPWR proposal so far leaves out the risk of hazardous chemicals in packaging. Chemicals are an important part of packaging and therefore of packaging policy and are too often ignored as such. Chemicals are used in the manufacture and processing of (plastic) packaging, which are harmful to both the environment and human health. Hazardous chemicals, e. g. in plastics and plastic products, can enter the human body and cause diseases such as diabetes, obesity, breast cancer, testicular cancer, neurological damage, fertility disorders or developmental disorders. [2] Plastic-typical chemicals such as plasticizers, bisphenols, and PFAS have been detected in human monitoring studies in sometimes questionable doses. [3]  Many of these substances are endocrine-disrupting. In particular, such diseases, which are influenced by hormones, continue to increase. The decline in fertility by more than 50% in the last 50 years [4], as well as the increase in hormone-related cancers, are particularly worrying.

Women, pregnant women, children, young people are particularly vulnerable. Children and adolescents are still developing; women more easily accumulate fat-soluble chemicals in their body; Pregnant women inadvertently pass on their cocktail of chemicals to their children, via the placenta before birth and during breastfeeding after birth. For this reason, men, women and particularly vulnerable groups are affected differently by (hazardous) chemicals. In addition, social gender roles or gender-specific consumer behaviour determine exposure to pollutants. This also applies to the packaging sector and material. Gender- and gender-differentiated assessment of chemicals therefore is essential [5]. This must be taken into account.

The PPWR lacks provisions and incentives to avoid hazardous chemicals in packaging [6]. However, this is fundamental for the health of people and the environment, as well as for a safe circular economy that does not want to recycle pollutants again and again into new products. This needs to be improved.

Clear regulation for chemical safety and transparency

The revised PPWR must include the following aspects:

  1. Provisions for the avoidance of hazardous chemicals in packaging (not just minimisation)
  2. Mandatory provisions to protect human health and the environment from hazardous chemicals for recycled and compostable material.
  3. Clear link with the REACH Restriction Procedure and the EU Chemicals Strategy for sustainability throughout the life cycle of packaging
  4. In Article 5. 1. the word “minimised” should be replaced by “prevented” or “avoided”, as hazardous chemicals should not be contained in packaging under any circumstances. Especially not the group of chemicals referred to here by definition. They all have a very harmful effect on human health and the environment. The current proposal is far too weak in this respect and falls far short of the requirements of the EU chemicals strategy for sustainability.
  5. Protection from hazardous chemicals is particularly important with regard to exposed groups such as workers along the entire value chain as well as already mentioned above particularly vulnerable groups such as children and young people in development and pregnant women.

Contact: Johanna Hausmann | Senior Policy Advisor, Chemicals & Health | WECF Germany e.V. | johanna.hausmann@wecfconsultant.org



[1] EXIT PLASTIK (2023) https://exit-plastik.de/wp-content/uploads/2023/04/EXIT-PLASTIK_Kommentierung_PPWR.pdf

[2] https://www.who.int/ipcs/publications/new_issues/endocrine_disruptors/en/

[3] https://www.hbm4eu.eu/wp-content/uploads/2022/05/HBM4EU-Newspaper.pdf

[4] Swan, Shanna (2021). Countdown

[5] WECF, Gender just Chemicals Policy (2021) https://www.wecf.org/de/wp-content/uploads/2018/10/Gender-and-Chemicals-Backgroundpaper.pdf

[6] EXIT PLASTIK; Chemikalien in Plastik (2022) https://exit-plastik.de/wp-content/uploads/2022/10/Positionspapier-Chemikalien-in-Plastik_Exit-Plastik.pdf