Packaging LCA: PPWR, recycled content and the functional unit

Packaging is one of the most frequently mis-modelled product groups in environmental assessment. The reason is conceptual rather than technical: packaging is a means, not an end. Measuring a package's environmental performance on its own is like measuring an insulation material without accounting for the building it serves.

Functional unit: the product protected

The correct functional unit is not 'one package' but 'one litre of beverage delivered undamaged' or 'one kilogram of food protected through its shelf life'. That change of definition can reverse the result: a heavier but more protective package can reduce total impact by cutting spoilage.

In food packaging that effect is large. The production footprint of a kilogram of beef is two orders of magnitude above that of the packaging around it. Cutting packaging weight by thirty per cent while raising spoilage by one per cent is a net loss. Light-weighting decisions taken without that calculation can be well-intentioned and wrong.

PPWR and circularity requirements

The Packaging and Packaging Waste Regulation (PPWR) introduces binding design rules for packaging on the EU market: recyclability criteria, minimum recycled content shares, limits on over-packaging and reuse targets. These are direct design obligations, independent of any LCA result.

The tension between compliance and optimisation starts here. Recyclability criteria exclude multi-layer barrier films; but a mono-material alternative may need to be thicker and may shorten shelf life. LCA is the only way to quantify that trade-off — though the regulation, not the LCA, makes the final call.

How recycled content is accounted for

How to attribute the environmental benefit of recycled content is one of the most contested methodological questions in LCA. There are two basic approaches, and they give different answers for the same package.

• Cut-off — recycled input carries only collection and reprocessing burden; primary production burden stays with the first user
• End-of-life recycling (avoided burden) — the recycling credit goes to whoever sends the material for recycling
• EN 15804+A2 uses the cut-off approach and reports recovery potential in a separate module
• Mixing the two approaches in one study produces double counting
• Which one was chosen must be stated explicitly in the report

The trap in material comparisons

There is no universal answer to glass versus plastic, or carton versus aluminium. Glass is heavy so transport impact is high, but it is infinitely recyclable. Plastic is light but fossil-based with low collection rates. Aluminium recycles very efficiently but its primary production is electricity-intensive.

Three parameters decide the outcome almost every time: transport distance, recycling rate and number of reuses. All three are local, which is why importing the conclusion of a Northern European study into Turkey is misleading.