Czy system kaucyjny obejmie kartony wielomateriałowe?

Will the deposit scheme cover multi-material cartons?

Czy system kaucyjny obejmie kartony wielomateriałowe?

Will the deposit scheme cover multi-material cartons?

The Ministry of Climate and Environment does not rule out extending the deposit system to further fractions, including multi-material packaging. The issue is currently under discussion between the ministry and the bottling industry. Possible changes can be expected no earlier than 2027.

MEP asks, MEP answers - discussion on multi-material packaging in the deposit system

The issue of including multi-material cartons in the deposit system was raised by MEP Grzegorz Matusiak in an interpellation addressed to the Minister for Climate and Environment. He pointed out that there is a current trend in the market to „escape” from the bail system - large beverage producers are switching from the mono-material packaging previously included in the system to alternative packaging that does not belong to the system. According to reports from the trade press the most common choice for producers in this situation is the difficult-to-recycle multi-material cardboard packaging, for which no deposit is charged.

In its response, the climate ministry confirmed that it recognises the phenomenon, but that it is, as indicated, of marginal scale, so does not require immediate action. However, the Ministry of the Environment is constantly analysing the industry's demands, including those regarding the inclusion of so-called tetraps in the deposit system, and still plans to decide on a possible legislative initiative in 2026.

Multi-material packaging is not a priority - take care of the fractions listed in the law first

The answer to the interpellation by the Undersecretary of State at the Ministry of Climate and Environment, Anita Sowinska, shows that at the moment the ministry is focusing on the development of infrastructure and reverse logistics those types of beverage packaging that have been part of the deposit system since its inception. Sowinska also pointed out that the imposition of a deposit on another fraction would result in a an additional burden on retail outlets and a reduction in the already greatly reduced waste stream going into the municipal system. In addition, it would require significant changes to the return infrastructure that has just been set up. One element of this is the bottle dispensers installed at collection points, which have not been adapted to collect waste from multi-material packaging.

Do exemptions to the bail system restrict competition?

In his interpellation, Grzegorz Matusiak also raised the problem of entire packaging segments being excluded from the deposit system. At first it was milk and dairy products, and after the launch of the system - beer and other beverages in reusable glass bottles. While the possibility to exclude beer packaging is only temporary (until the end of 2028) and the use of it has been made conditional by the Ministry of the Environment on the operation of an alternative collection system, for milk and dairy products there is no other collection system in place, nor is there a timetable set for their future inclusion in the central system. In the Member's view, such aim at restricting competition between marketers of packaged beverages, and the validity of their use should be reviewed by the IOC.

Read also: Glass bottles, however, outside the deposit system >>

As a restriction of competition in the market, the Member also points to the phenomenon of PET bottles and aluminium cans being replaced by multi-material cardboard packaging, which, due to the absence of a deposit and the need to return them, is a cheaper and more convenient alternative for consumers.

The Ministry did not directly address the issue of a potential restriction of competition. However, Minister Sowińska stressed that the purpose of the deposit system was not to promote the use of multi-material cardboard packaging, but to meet the high EU targets for separate collection levels of packaging waste. She added that the effectiveness of the system and its impact on the environment and the competitiveness of bottlers would only be able to be reliably assessed after an analysis of the reports for the first full year of operation of the deposit system.

Read also: Will there be an umbrella institution in the bail system?

 

Sources:

  1. Interrogatory No. 16100 to the Minister for Climate and Environment on the deposit system and the types of beverage packaging covered, https://www.sejm.gov.pl/sejm10.nsf/InterpelacjaTresc.xsp?key=DSHE6Y
  2. Reply to MEP Grzegorz Matusiak's interpellation on the deposit system and the types of beverage packaging covered, K10INT16100, https://sejm.gov.pl/INT10.nsf/klucz/ATTDSWJ5B/%24FILE/i16100-o1.pdf

Contact

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    MKiŚ nie wyklucza powołania instytucji parasolowej w systemie kaucyjnym

    The MoE does not rule out the establishment of an umbrella institution in the deposit system

    MKiŚ nie wyklucza powołania instytucji parasolowej w systemie kaucyjnym

    The MoE does not rule out the establishment of an umbrella institution in the deposit system

    So far, the Polish deposit system has operated without an umbrella institution. However, this may soon change - in the latest statements and communications from representatives of the Ministry of Climate and Environment, one can read that the ministry is currently analysing the legitimacy of creating such an organisation. We will have to wait a little longer for information on the chosen direction of the deposit system - the final decision on this matter should be made as early as June.

    Will the amendment spread the umbrella over the bail system?

    The Ministry of Climate and Environment is considering the possibility of setting up an umbrella institution to bring together participants in the Polish bail system. Information about the ministry's plans was provided by Deputy Climate and Environment Minister Anita Sowińska during the European Economic Congress in Katowice.

    At present, the Ministry of the Environment is trying to support all those involved in the operation of the bail system and to address so-called 'baby-age' issues on an ongoing basis. At the same time the ministry is working on an amendment to the law on the bail system, The scope of which should be known in June.

    Anita Sowinska added that if an umbrella organisation is established, it should include all stakeholders in the Polish bail system and state institutions. Operators are of a similar opinion, advocating the establishment of a body that brings together representative bodies, trade representatives and waste and recycling industry organisations. However, they rarely mention state institutions in this group.

    Minister Sowinska: agreements between operators as a basis for setting up an umbrella organisation

    Demands for the creation of an umbrella organisation emerged already at the initial stage of work on the law introducing the bail system in Poland. Supporters of such a solution cited as an example mainly german bail system, where all operators are brought together by one organisation, Deutsche Pfandsystem GmbH. However, this idea was rejected and the umbrella organisation provisions were not included in either the original version of the law or its 2024 amendment.

    According to the Ministry of Climate and Environment, in 2024, stakeholder expectations about the shape and role of the umbrella organisation were very different. After the first few months of operation of the deposit system, the situation is much clearer. What is more, the operators have already concluded agreements between themselves governing the most important issues, which can now be expanded and legally sanctioned.

    According to Tomasz Suligowski, CEO of OK Operator Bail, if the MoE decides not to establish an umbrella organisation, it should be established by the operators themselves. The bottom-up establishment of an umbrella organisation has also been considered in the past, and even written into the contract that the five bail bond operators concluded in December 2024. According to the provisions of the contract, the institution was to ensure that the principles of security were maintained and that all stakeholders were treated equally. With the development of the bail system, the needs of its participants have evolved somewhat - nowadays operators and industry representatives expect the umbrella organisation to step in as an arbitrator, which would verify problems, enforce compliance with guidelines and rectify any irregularities. An important task of the organisation would also be the standardisation of processes, which could become a remedy for problems in the handling of separate collection and the selection of bottle dispensers.

    Read also: Will the deposit scheme cover multi-material cartons?

    What is an umbrella institution in a bail system?

    An umbrella institution, also known as an umbrella organisation, is a an independent body that oversees various aspects of the operation of the bail system and enables dialogue between its stakeholders. It can be established either top-down - by legislation - or bottom-up - in the execution of agreements between those participating in the deposit system. Past practice shows that such an organisation usually brings together an operator (or operators) and representatives of producers and the trade.

    Today, umbrella institutions operate in both single-operator and multi-operator systems. In practice, their importance is growing especially where multiple operators, numerous networks and outlets and a wide range of producers are involved in the deposit system, i.e. in situations where effective coordination of common operating rules is necessary. In many countries, umbrella organisations also play a stabilising role - reducing the risk of disputes over competence, enhancing the transparency of the deposit system and facilitating its further development.

    The objectives of establishing an umbrella institution in the bail system include:

    • ensuring equal treatment of all stakeholders,
    • ensuring the tightness of the system, e.g. by introducing uniform security standards and improving them,
    • monitoring financial flows and preventing fraud,
    • establishing and enforcing rules and standards for separate collection, packaging counting and deposit accounting,
    • conducting audits of the activities of individual stakeholders,
    • creation of standards for labelling and recognition of packaging in bottle-makers,
    • moderating dialogue and arbitrating between stakeholders.

    The exact scope of the umbrella institution's tasks depends either on the laws of the country concerned or on contractual provisions.

     

    Sources:

    1. The bail system: what an umbrella organisation would change, https://forsal.pl/gospodarka/artykuly/11241003,system-kaucyjny-co-zmienilaby-organizacja-parasolowa.html
    2. Anita Sowinska wants an umbrella organisation for the bail system, https://portalkomunalny.pl/anita-sowinska-chce-organizacji-parasolowej-dla-systemu-kaucyjnego-599982/

    Contact

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    biuro@interzero.pl


      Shrinkflacja w praktyce – konsekwencje dla konsumentów, producentów i rynku opakowań

      Shrinkflation in practice - implications for consumers, producers and the packaging market

      Shrinkflacja w praktyce – konsekwencje dla konsumentów, producentów i rynku opakowań

      Shrinkflation in practice - implications for consumers, producers and the packaging market

      Shrinkflating is one of the most commonly used, but rarely communicated, cost optimisation strategies in the B2C sector. While on the surface it can be a good solution, it sometimes becomes a double-edged sword that will stab the manufacturer the hardest. What is the mechanism of the phenomenon and how do consumers react to it?

      Shrinkflation - what is it and why does it happen?

      Shrinkflation is the phenomenon whereby the contents of packages are reduced (change in quantity, volume, weight of products) while maintaining the previous size of these packages and price goods on the shop shelf. It is a kind of hidden inflation - results in an increase in commodity prices per unit.

      Shrinkflations most common in the FMCG sector, where consumers:

      • make purchasing decisions based on the price of the product on the shelf,
      • do not always glance at the unit price written in small print.

      At the heart of shrinkflation is the assumption that consumers are more sensitive to the transaction price of products than to changes in their package size. For this reason, entrepreneurs struggling with rising production costs prefer to reduce the amount of product in the package rather than raise prices on shop shelves. Furthermore, research shows that many consumers do not read product labels, especially if they are already familiar with them and buy them regularly.

      It can be assumed that producers are aware of consumers' low knowledge and lack of ingrained habit of reading labels on products, and they are counting on this - keeping the original price and size of the packaging, while reducing its content.

      Source: UOKiK, Downsizing in the assessment of Polish consumers. Survey report, https://uokik.gov.pl/Download/641.

      Shrinkflation is also sometimes referred to as shrinkflation or downsizing, which the consumer may find somewhat confusing. The term downsizing is commonly used in the automotive industry, where it means reducing the displacement of internal combustion engines while maintaining or even increasing their power output. Such downsizing aims to reduce emissions and consumption of fossil fuels, which brings environmental benefits. Downsizing in the FMCG industry seems to have the opposite effect.

      Is less is more? The environmental impact of shrinkflation

      Related to shrinkflation a reduction in the weight of the product does not usually go hand in hand with a reduction in the weight of its packaging (so-called. lightweighting). Producers tend to forgo any changes in packaging dimensions and appearance in order not to arouse consumer suspicion, to maintain their current position on the shop shelf and to avoid the costs associated with redesigning sales packaging, bulk packaging and the entire packaging line. As a result the weight of packaging material per unit of product increases and the weight of packaging waste generated per kilogram, litre or piece.

      An additional factor contributing to the increase in packaging waste is the change in consumer shopping habits forced by the reduction in product weights. In order to maintain the current level of consumption, the customer needs to buy more packs of the product, and this in turn leads to an increase in the total mass of waste generated from this packaging. Given that shrinkflations typically involve products that are consumed or used in large quantities (e.g. food, beverages, cosmetics, household chemicals), the increase in the mass of packaging entering the waste stream can be significant.

      However, the environmental impact of shrinkflation does not end with the need to manage more waste, but also extends to the entire life cycle of packaging and the range of environmental responsibilities associated with its use.

      • Production of additional packaging quantities requires increased consumption of raw materials and energy and leads to increased emissions.
      • The environmental burden of transport is also increasing slimmed down products in unchanged packaging - to deliver the same amount of product to a shop or household, transport companies and consumers have to travel more kilometres using more fuel and emitting more greenhouse gases.
      • More weight of packaging introduced means higher charges on account of ROP. At the moment in Poland, they boil down to a higher price for a packaging recovery organisation to take over the recycling obligation, but this state of affairs will not last forever. The government is still working on a new ROP model, and increases in fees for each kilogram of packaging introduced are rather inevitable.

      Back to the question in the headline - yes, less product (usually) means more. More waste, more emissions, more raw materials used and... more dissatisfied consumers.

      About consumers

      Research clearly shows that consumers are not indifferent to shrinkflations - In a recent survey by the European Association of Paperboard and Cardboard Manufacturers, Pro Carton, 39% of them declared that they were „very concerned” about reducing the amount of product in a pack without changing the price. Even more, 80% of those surveyed would look unfavourably on a brand that had quietly slimmed down its product. In practice, this means that:

      • 50% consumers will start looking for alternative products with a better price/weight ratio,
      • 31% will immediately switch to another brand's product,
      • 11% will continue to buy the same product,
      • 8% is not sure what it will do.

      At the same time, as much as 21% consumers will stop buying the slimmed down product[i].

      Such unequivocal reactions mean that a manufacturer planning shrinkflation needs to think carefully about its communication strategy. The public does not accept the clandestine downsizing of products - instead, it demands reliable information not only about the application itself downsizing, but also about the reasons for doing so. What is more, there are bodies on the side of consumers defending their interests - the The UOKiK is sensitising manufacturers to clearly communicate the change in the existing product weights. Otherwise, such actions may be considered as deliberate misrepresentation. In some EU countries (e.g. France and Italy), regulations explicitly oblige manufacturers to inform about shrinkflations.

      Shrinkflation vs. legislation - will PPWR affect the downsizing trend in FMCG?

      Probably yes. However, the new regulations will not limit the scale of slimming products, but make it easier for consumers to see the difference in their quantity, weight or volume. PPWR Regulation This is because it establishes a requirement to minimise packaging, whereby a possible downsizing will include not only the product itself, but also its packaging. In addition, it introduces the reduction of the void ratio in commercial packaging to the minimum necessary, which should eliminate from the market packaging with double walls, double bottoms and other features designed only to conceal a real change in the quantity or volume of the product resulting from shrinkflation.

      Out of concern for the brand's good name and consumer perception, it will be good practice in the coming years to combine shrinkflations with eco-design of packaging „slimmed down” product and with communication of the changes and the underlying causes. This attitude can bring many benefits to entrepreneurs:

      • cost reduction related to the production process and reduce the consumption of raw materials,
      • maintaining the current shelf price as the most important factor influencing consumer purchasing decisions,
      • compliance with legal requirements, including those arising from the PPWR,
      • increasing the recyclability of packaging resulting in a reduction in environmental charges.

      [i] Pro Carton, The Power of Packaging What Makes European Consumers Trust, Stay, or Switch?, https://www.procarton.com/wp-content/uploads/2026/03/Pro-Carton-Consumer-Study-2026-Final-Edit-1.pdf

      Contact

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      biuro@interzero.pl


        Oznakowanie opakowań zgodne z PPWR – JRC przedstawiło propozycję nowych etykiet segregacji

        PPWR-compliant packaging labelling - JRC to propose new segregation labels

        Oznakowanie opakowań zgodne z PPWR – JRC przedstawiło propozycję nowych etykiet segregacji

        PPWR-compliant packaging labelling - JRC to propose new segregation labels

        The EU is once again moving closer to the introduction of uniform labelling on packaging to facilitate waste separation. On 13 January 2026, the European Commission's Joint Research Centre (JRC) will launch a joint project on packaging labelling. Joint Research Centre, JRC) published a report JRC technical proposal for harmonised EU waste sorting labels under the Packaging and Packaging Waste Regulation, which presents standardised labelling templates and colour codes for individual packaging materials.

        PPWR standardises waste segregation labels

        The Joint Research Centre (JRC) report proposes the following new harmonised waste separation labels throughout the EU developed based on the conclusions of research with consumer and expert groups. They have been designed in response to Article 12(1) and (6) of the PPWR, which:

        • oblige manufacturers to display on all packaging labels informing about the material composition,
        • require Member States to place on all containers for separate collection waste marking to facilitate segregation,
        • oblige the EC to adopt implementing acts establishing harmonised segregation labels no later than 12 August 2026.

        From as of 12 August 2028. a new, uniform labelling system for packaging for all EU Member States is intended to replace the local markings and symbols currently used for segregation. The aim of the EU legislator was to eliminate the information chaos caused by the parallel operation of different inconsistent labelling models and to remove barriers to the internal market. The harmonisation of separation labels is also expected to increase the quality of separate waste collection and facilitate the transition towards GOZ.

        Basic principles of a PPWR-compliant packaging labelling system

        The technical proposal for PPWR-compliant labelling presented in the JRC report was based on several assumptions:

        • priority for material composition, and not the collection system - the label refers only to the packaging material,
        • identical symbols on packaging and waste containers - make it easier to assign packaging waste to the appropriate stream, which will improve the quality of separate collection,
        • EU-wide harmonisation - elimination of existing labelling systems in favour of a uniform set of symbols and colours,
        • evidence-based design from the research - the final proposal for labels based on the results of the behavioural and participatory research,
        • informational and visual minimalism - the label provides clear and easy-to-understand instructions for waste separation; it includes: pictograms, colour coding and a minimum amount of text,
        • linguistic universality and inclusiveness - the system can be understood by audiences from different groups and with different languages,
        • the basis of the physical label - the most important sorting instructions are directly on the label, and digital media, including QR codes, are only a supplement.

        The assumptions made by the JRC are consistent with the guidance provided by the PPWR and its preamble, which emphasises that:

        The most important guideline in the design of labels should be the need for a harmonised labelling system that is recognisable to all citizens, regardless of their situation, including their age and language skills. Such a system can be achieved by using pictograms with a minimum of linguistic elements

        Read also: Ecomodulation in PPWR - how will eco-design affect packaging charges?

        11 colours instead of 5 - differences between the Polish JSSO and the JRC proposal

        An important element of the labels developed by the JRC is the new colour coding system for individual materials:

        • blue - paper and cardboard,
        • green - glass,
        • yellow - plastics,
        • orange - multi-material packaging,
        • dark grey - metal,
        • brown - compostable waste,
        • magenta - textiles,
        • turquoise (cyan) - ceramic,
        • beige - wood, cork,
        • purple - mixed waste,
        • red - packaging for hazardous substances.

        Some similarities and differences to the colour codes used in Poland since the introduction of JSSO can be identified here. The common points in the JRC proposal and the Polish JSSO are the colours: blue for paper and cardboard, green for glass, brown for the compostable fraction (bio) and yellow for plastics. A complete novum are the colours orange, dark grey, magenta, cyan, beige, red and purple.

        For the Polish consumer, the biggest and most incomprehensible changes may be the assignment of the colour purple to mixed waste (instead of the previously used black) and a separate grey colour code for metal packaging, which under the JSSO were marked with yellow symbols. Confusion can also be caused by the red marking of containers - currently this colour is reserved for electro-waste and infectious medical and veterinary waste, and according to the JRC, in future we should only mark packaging of hazardous substances with this colour.

        Importantly, the JRC proposal does not require waste to be separated into 11 fractions - The PPWR regulation allows several different markings on one bin. Waste from plastic, metal and multi-material packaging is likely to continue to be disposed of in the same bin, except that it will be colour-coded yellow, dark grey and orange, rather than just yellow as before.

        Discussion and controversy surrounding the proposal to label packaging under the PPWR

        The proposal to extend the packaging labelling scheme to include further colours not previously used has long been a concern for experts. They argue that the implementation of additional colour coding in a situation where Polish consumers still have problems sorting their waste into the 5 fractions may cause dissatisfaction and confusion. On the other hand, the introduction of a harmonised labelling system is a way out to meet the expectations of these same consumers. In the 2023. Interzero study Are we getting into trouble? until 60% respondents favoured the existence of a single standard packaging label, which will be mandatory for all manufacturers. Only 12% respondents had a different opinion.

        The inclusion of a text message on segregation labels that would have to be translated into up to 24 official EU languages. Implementation of the JRC's proposed labelling scheme would therefore remove one barrier to intra-EU trade and introduce another in its place.

        It should be stressed that the report's proposal for labels to facilitate waste sorting is not a source of legislation - it is merely a starting point for the development of a target labelling system for packaging. The Commission has until 12 August 2026 to adopt implementing acts establishing harmonised labels. By the same date, the EC should adopt acts indicating the methodology for determining the material composition of packaging.

        Source: Bruns, H., Borsello, A., Dupoux, M., Hamarat, Y., Milios, L. et al, JRC technical proposal on EU harmonised waste sorting labels under the packaging and packaging waste regulation, Publications Office of the European Union, Luxembourg, 2026, https://data.europa.eu/doi/10.2760/8070242, JRC141706.

        Contact

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        biuro@interzero.pl


          Ryby, grzyby i recyklat PP – jak będzie wyglądać przyszłość opakowań do żywności

          Fish, mushrooms and PP recyclate - what will the future of food packaging look like?

          Ryby, grzyby i recyklat PP – jak będzie wyglądać przyszłość opakowań do żywności

          Fish, mushrooms and PP recyclate - what will the future of food packaging look like?

          Food packaging has been undergoing quite a revolution recently - on the one hand, there is increasing regulatory pressure and weight reduction requirements, and on the other hand, consumers are looking more and more closely at the materials in which products are packaged. As a result, manufacturers are looking for more sustainable alternatives to the plastics used so far, and researchers are trying to meet their needs. This is how packaging innovations are being developed, which could soon change the entire industry.

          Category 3 waste packaging - biopolymer for contact applications

          Researchers in Brazil have developed a new type of transparent, flexible barrier coating produced from fish industry waste. As a basis for its production used fish skin from the hybrid species Tambatinga, which has a naturally high collagen content. When hot water and acid were added to the fish waste, the researchers obtained a gelatine with a high amino acid content and very good film-forming properties. Thus The resulting gelatine was then combined with the plasticizer glycerol, which increased the material's strength and flexibility. This has resulted in a biopolymer with a uniform, smooth structure, which is suitable for contact with food products, effectively blocks UV radiation below 300 nm and provides a better vapour barrier than other biodegradable gelatine films.

          Due to its natural sensitivity to moisture, the amino acid coating has limited applications for the time being. mainly suitable for packing dry or low-moisture products. However, scientists are constantly working on improving its water resistance and testing combinations with other biopolymers, aiming to extend the applications of biofilm to other types of packaging as well.

          Read also: Plastic-free catering packaging - Delicious.co.uk carries out large-scale implementation >>

          Will mycelium replace film?

          Promising work is underway overseas on a natural hydrophobic coating that could find application in single-use packaging previously made from plastic. University of Maine researchers have developed a new type of biofilm using edible fungal mycelium and a cellulose fiber suspension. After mixing mycelial hyphae with cellulose nanofibres, they obtained a biologically active material that can be „grown” by applying it to the surface of paper, wood or fabric.

          The growth of the material takes several days, during which the mycelial hyphae gradually form an increasingly dense network. The whole process takes place under controlled conditions and produces a coating with natural hydrophobic properties, which can be used not only for disposable packaging, but also for impregnating technical textiles or manufacturing construction materials with special properties.

          Recyclate better than virgin plastics - the new generation of PP film

          Eurocast is developing an innovative multilayer polypropylene cast film (Castfol RPP). Work on it started in 2025 and will continue until 2030. The aim of the R&D project is to create a film with a high proportion of recycled raw materials, which will have performance characteristics comparable to materials made from virgin raw materials. In parallel with the development of the technology Eurocast wants to promote its solution in foreign markets, creating room for increased exports in the future.

          Castfol RPP film has contain up to 60% recycled PP and at the same time be suitable for food contact. It will comprise a minimum of five layers, each responsible for performing a specific function (e.g. mechanical strength, weldability and the use of recycled material). The project also includes a reduction in film thickness from 40 to 30 µm, which will reduce the consumption of raw materials and reduce the amount of packaging waste generated throughout the product life cycle. The biggest challenge, however, is to ensure high optical quality film, essential for packaging applications, particularly in the food segment. A feature of most recycled plastics is lower transparency, loss of gloss and a decrease in mechanical properties. Eurocast wants to reverse this trend and, in addition, make it possible to increase the material efficiency of packaging by up to approximately 33%.

          Meet Recythen® and Procyclen® - innovative recycled plastics with impressive properties >>

          Paper will replace laminate in spice packaging

          Currently, the most common answer to the question „where to dispose of spice packets” is: in the mixed. This may soon change - Mondi, the global leader in paper packaging in partnership with Prymat developed innovative paper packaging for spices, which is intended to replace the currently difficult-to-recycle laminates of paper, plastic and aluminium.

          New packaging creation from Mondi FunctionalBarrier Paper Ultimate, which contains a minimum of 80% paper coated with a special barrier layer to ensure a high degree of product protection. As a result, the spice bag effectively prevents the penetration of oxygen, moisture and grease, It achieves performance comparable to traditional laminates. At the same time, it fits in with the requirements of a circular economy - according to Mondi, packaging has a lower carbon footprint and is optimised for recycling.

           

          Sources:

          1. Katarzyna Oleksy, Biodegradable packaging made from farmed fish skin waste, https://foodfakty.pl/biodegradowalne-opakowania-z-rybiej-skory-bedacej-odpadem-hodowlanym
          2. Katarzyna Oleksy, Scientists develop natural, fungal water-resistant coatings - an alternative to plastic, https://foodfakty.pl/naukowcy-rozwijaja-naturalne-grzybowe-powloki-odporne-na-wode-alternatywa-plastiku
          3. PP film with up to 60% recyclate for food contact, https://www.plastech.pl/wiadomosci/Folia-PP-z-zawartoscia-do-60-recyklatu-do-kontaktu-z-21908
          4. Mondi and Prymat introduce groundbreaking paper packaging to the Polish spices market, https://www.rynekpapierniczy.pl/artykul/mondi-i-prymat-wprowadzaja-przelomowe-opakowania-papierowe-na-polski-rynek-przypraw-5286


          Pyszne.pl znalazło sposób na opłaty SUP. Białka roślinne zastąpią plastik w opakowaniach gastronomicznych

          Pyszne.co.uk has found a way to SUP charges. Plant proteins will replace plastic in catering packaging

          Pyszne.pl znalazło sposób na opłaty SUP. Białka roślinne zastąpią plastik w opakowaniach gastronomicznych

          Pyszne.co.uk has found a way to SUP charges. Plant proteins will replace plastic in catering packaging

          Poland's largest online food ordering service, Pyszne.pl, is introducing innovative food packaging that is plastic-free and SUP-compliant. The new boxes are made exclusively from paper and natural plant proteins, so they are not subject to a consumer charge.

          New catering packaging debuts: plastic-free but with Morro™ Coating

          Following the successful implementation of innovative packaging in Austria and Germany, the owner of the Pyszne.pl platform, Just Eat Takeaway.com, is also introducing a new type of packaging for takeaway food to the Polish market. The aim is to replace plastics with a more sustainable alternative, ensuring packaging meets strict regulatory requirements and will allow restaurants working with Pyszne.pl to more easily comply with the EPR regulations.

          Thanks to the use of sustainably sourced corrugated paper and Xampla's special Morro™ Coating, Pyszne.pl packaging can be processed through existing waste management processes and without the need to first separate the additives from the plastic. Confirmed by the UK's National Physical Laboratory (NPL), the lack of use of plastics means that the new packaging meet the definition of alternative packaging under the SUP Directive and are not subject to the charge for the issue of disposable packaging to the consumer (end user).

          As the representatives of Xampla and Pyszne.pl emphasise, the implementation of the new type of packaging does not take place as part of tests or pilots, but constitutes a part of a broad expansion covering 10 European markets, on which Just Eat Takeaway.com operates.

          For us, this expansion is a matter of scale. Morro™ coating works; we are now deploying it in 10 European countries in partnership with one of the largest food delivery platforms on the continent. If we want to replace plastics, we need to do so in large-scale and high-performance applications such as food delivery. This deployment demonstrates that natural materials can compete - and win - in just such conditions. - reports Xampla CEO Alexandra French. - Source: press materials

          Plastic-free catering packaging part of Just Eat Takeaway.com strategy

          The implementation of the new type of packaging is part of Just Eat Takeaway.com's sustainability strategy. The company aims to provide its partner restaurants with the widest possible range of plastic-free packaging for a variety of meals and dishes.

          From an operational perspective, the transition from legacy packaging to non-SUP packaging should not be a challenge. As assured in the press release, the new food boxes fully integrate into existing restaurant production processes, which minimises the barriers and obstacles to their large-scale use.

           

          How did delicious.co.uk achieve barrier-free plastic?

          This is thanks to the British company Xampla, which develops modern packaging materials. It is its experts have created a plant-based Morro™ coating in 100%, which has almost identical barrier properties to standard plastic coatings. It has been formulated from natural, chemically unmodified plant proteins to provide high barrier properties while eliminating the undesirable effects of plastics.

          In the latest Pyszne.pl packaging Morro™ coating is applied to cardboard boxes manufactured by Huhtamaki. This has resulted in a number of benefits that are felt both during the use of the packaging and when it becomes waste.

          • During use packaging maintains rigidity and keeps food warm, which was previously almost impossible without the use of plastics. As a result, they can be used to package a wide range of foods and dishes, even those that are moist and oily.
          • Waste from Huhamaki packaging with Morro™ coating not only recyclable, but biodegradable and compostable even at home. Once fully decomposed, they leave no harmful substances in the environment.

          The latest packaging implemented by Pyszne.co.uk is not the first of its kind in the brand's range. The company has already successfully used cardboard food boxes produced by Notpla, in which the plastic layer was replaced with a vegan alternative created from seaweed.

           

          Sources:

          1. Ecological packaging, https://www.pyszne.pl/zrownowazonyrozwoj/ekologiczne-opakowania/
          2. New Pyszne.pl boxes enter Poland. No SUP fee, https://www.dlahandlu.pl/technologie-i-wyposazenie/nowe-pudelka-pyszne-pl-wchodza-do-polski-bez-oplaty-sup,167773.html
          3. pl introduces sustainable packaging in Poland. World's first takeaway boxes made from plant protein, https://e-restauracja.com/artykul/16505/pyszne-pl-wprowadza-zrownowazone-opakowania-w-polsce-pierwsze-na-swiecie-pudelka-na-wynos-z-bialka-roslinnego/


          Szklane butelki jednak poza systemem kaucyjnym

          Glass bottles but out of deposit system - amendment will change the rules for returning reusable glass

          Szklane butelki jednak poza systemem kaucyjnym

          Glass bottles but out of deposit system - amendment will change the rules for returning reusable glass

          Brewers and other producers of beverages in reusable glass bottles will not be compulsorily covered by the deposit system, or at least not until the end of 2028, as the Senate adopted an amendment to the Packaging and Packaging Waste Management Act on 21 January 2026, which allows private bottle return systems to continue.

          A sudden turnaround on returnable bottles - glass, however, outside the central system

          From 1 January 2026, reusable glass Beverage bottles were supposed to be covered by a central deposit system. They were supposed to be, but probably won't be, or at least not all of them. As late as 2025, some breweries have received interpretations from provincial marshals allowing the sale and return of reusable glass under the „old” rules. In addition, on 19 December 2025. A parliamentary draft amendment has been submitted to the Sejm. Packaging and Packaging Waste Management Act, which provided for the possibility of the continued time-limited operation of private bail schemes. Already on 9 January 2026, the amendment was passed by the Sejm, and on 21 January 2026 it was adopted by the Senate. A day later, the law was sent to the President for signature.

          What does the amendment to the Bail Law change?

          Amendment allows introducers to choose how to fulfil their obligation to separately collect beverage packaging - They may either join the central deposit system or operate their own packaging collection systems under the current rules. This applies only to producers of beverages in reusable glass bottles who established and operated such systems prior to the entry into force of the Act establishing a deposit system in Poland.

          As indicated in the explanatory memorandum to the draft amendment, such a change is intended to ensure:

          a stable and predictable legal framework for the continued operation of existing, market-based return systems for reusable glass bottles.

          One of the conditions for the continued operation of private deposit systems is that the Minister of Climate must be notified of the collection within three months of the first placing on the market of packaged products collected outside the central system, i.e. by 31 March 2026.

          At the same time the possibility to set up new private collection schemes is excluded for packaging subject to mandatory separate collection under the deposit system. All companies starting to operate on the Polish market will therefore have to join the deposit system operated by the representative entity right away.

          Collection levels and obligations of introducers unchanged

          Following the entry into force of the amendment to the Packaging Act, the provisions relating to the direct introducer of beverage packaging products, excluding the provisions relating to the deposit system, will apply to entrepreneurs operating their own deposit systems.

          There will be no change in the obligations of beverage introducers in reusable glass bottles. They will still need to achieve minimum collection rates packaging calculated in accordance with the methodology indicated in the Act (i.e. as a percentage of the ratio of the quantity of packaging of the same type collected by the introducer in a given year and the quantity of packaging placed on the market by this introducer in a given year).

          Check how the bail system works in Poland >>

          Return of bail without receipt - new rules in old bail schemes

          From the consumer's point of view, the most important change resulting from the adopted amendment is the following the possibility of returning glass bottles, even those belonging to private schemes, at any collection point and without the need to show a receipt. This is a considerable improvement - until now, the conditions for accepting reusable glass bottles largely depended on the rules adopted by individual shop owners. In most cases, the deposit could only be collected at the point of sale where the beverage in question was purchased and only on presentation of the receipt.

          The aim of the amendment was to remove barriers by unification of the rules for the return of all deposit packaging, regardless of the type of deposit system to which these packages belonged. This is because inconsistent practices and differences between the conditions for collection of different types of packaging at the point of sale have caused confusion for consumers and discouraged returns. Importantly, there will also be no differentiation deposit amount for reusable glass bottles belonging to private systems and to a central system - in each case the consumer will pay and then recover the same amount.

          Arguments for excluding reusable bottles from the central deposit system

          The possibility of excluding reusable glass bottles from the central deposit system has long been sought by those introducing beverages in this type of packaging, especially brewery owners. The current amendment to the Packaging Act is a way to meet their expectations. What is more, Proponents of the bill have taken up much of the bottling industry's argumentation - Indeed, in the explanatory memorandum to the bill, they indicated that:

          • The efficiency of private return schemes is now over 90%,
          • Returnable packaging circulates within a closed loop and is used several times a year,
          • Private bail systems have efficient logistics and short supply chains to reduce emissions,
          • Operators of private deposit systems use record-keeping mechanisms that allow for the precise calculation of separate collection levels,
          • the provisions involving the abolition of well-functioning private return systems were an example of „gold-plating”, i.e. excessive implementation of EU law beyond its requirements.

          Read also: Will the deposit system increase the carbon footprint of PET bottles?

          Further developments in the legislative process can be followed on the Sejm website.

           

          Sources:

          https://www.sejm.gov.pl/Sejm10.nsf/druk.xsp?nr=2112


          Odpady opakowaniowe w UE w 2023 r. – spadek masy i wzrost recyklingu, lecz do celu na 2030 r. jeszcze daleko

          EU packaging waste in 2023. - Decrease in weight and increase in recycling, but still a long way from the 2030 target

          Odpady opakowaniowe w UE w 2023 r. – spadek masy i wzrost recyklingu, lecz do celu na 2030 r. jeszcze daleko

          EU packaging waste in 2023. - Decrease in weight and increase in recycling, but still a long way from the 2030 target

          The latest Eurostat figures show that in 2023, a total of 79.7 million tonnes of packaging waste was generated in all EU Member States, of which 67.5% was recycled. Thus, the recycling rate increased to the level recorded before the pandemic, while the mass of waste generated continued its downward trend. Let us look at the detailed data on packaging waste in Poland and the EU.

          European Union: 67.5% recycling of packaging waste in 2023.

          Of the 79.7 million tonnes of packaging waste generated across the EU, 53.8 million tonnes or 67.5% were sent for recycling. Significantly, only 4.67 million tonnes of waste were recycled outside the EU - despite the crisis in the plastics recycling industry, as much as 49.13 million tonnes passed through installations on the Old Continent. Furthermore, as much as 40.96 million tonnes of packaging waste was recycled directly in the country of generation, with the remaining 8.13 million tonnes going for recycling in other Member States.

          Highest recycling rates overall packaging waste occurred in Belgium (79.7%), the Netherlands (75.8%), Italy (75.6%) and the Czech Republic (74.8%). Overall 7 EU Member States to achieve recycling rates above 70% in 2023, meeting the minimum criterion for 2030. On the opposite side were the countries with the lowest recycling rates in the whole community: Romania (37.3% in 2022), Hungary (42.8%), Malta (44.4%) and Greece (48.0%).

           

          Poland on track to meet 70% packaging recycling target in 2030.

          According to the latest Eurostat data, in terms of recycling packaging waste, Poland performs surprisingly well. In 2023, there will be approximately 184 kg of packaging waste per statistical Pole, of which 116 kg will be recycled. Thus, the recycling level of total packaging waste for 2023 was 67.4%, which ranks Poland 12th in the EU. Furthermore, for the period 2018-2023 our country increased the recycling rate of packaging waste from 58.7% to 67.4%.

           

          Paper the packaging industry favourite, plastic below 20% by weight

          Paper and cardboard packaging accounted for 40.4% of the mass of packaging waste generated in the EU throughout 2023. They dominated in 26 of the 27 community countries, reaching a share ranging from 29.4% in Romania to 49.1% in the Netherlands. The exception to the EU trend appeared to be Bulgaria, where plastic packaging was much more popular (28.4% compared to 25.5% for paper and board).

          The material distribution of packaging waste generated in the EU in 2023 was as follows:

          • 40.4% paper and board (32.3 million tonnes),
          • 19.8% plastics (15.8 million tonnes),
          • 18.8% glass (15 million tonnes),
          • 15.8% timber (12.6 million tonnes),
          • 4.9% metals (3.9 million tonnes),
          • 0.2% other materials (0.2 million tonnes).

          The highest share of wood packaging waste was recorded in Finland (27.8%). Glass, on the other hand, proved to be the domain of Croatia (26.8%) and metals in Greece (9.2%).

           

          Plastic packaging recycling still under pressure

          Eurostat has also summarised the recycling rates for plastic packaging. Recall, That the 2030 target is to treat 55% by weight of collected plastic waste. Meanwhile The EU average for 2023 was 42.1%, and the worst performing countries were Hungary (23.0%), France (25.7%), Austria (26.9%) and Denmark (27.8%). In addition to these, exceptionally low (<30%) recycling rates for plastic packaging were also recorded in Croatia, Sweden, Finland and Ireland. In contrast, the 55% recycling target was exceeded by 2 countries: Belgium (59.5%) and Latvia (59.2%).

          The data presented by Eurostat is particularly relevant in the context of the new obligations under the PPWR, which will revolutionise the EU packaging market. It not only maintains the recycling targets for plastics at the levels established in Directive 94/62/EC, but also introduces a number of additional requirements, including minimum levels of recyclate content and new design criteria for recycling (design for recycling). In practice, this means that countries that are already below EU targets could face a shortage of the recyclate needed to produce PPWR-compliant packaging. You can read more about future risks and strategies in the face of the recyclate crisis in the report: CIRCULAR PACKAGING 2030: Strategies for action in an era of shortage of recyclate

           

          Sources:

          1. Eurostat, Statistics on packaging waste, https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Packaging_waste_statistics
          2. Eurostat, Plastic packaging waste in the EU: 35.3 kg per person, https://ec.europa.eu/eurostat/web/products-eurostat-news/w/ddn-20251022-1


          Od 2026 r. zmiany w EPR we Francji – ekomodulacja i system bonus-malus

          From 2026, changes to EPR in France - ecomodulation and bonus-malus system

          Od 2026 r. zmiany w EPR we Francji – ekomodulacja i system bonus-malus

          From 2026, changes to EPR in France - ecomodulation and system bonus-malus

          On 1 January 2026, eco-modulation will be introduced in the French EPR system with a bonus-malus model. The financial burden on producers will be modulated due to the recyclate content of packaging and products, but not all of them - as the new rules only apply to 8 of the 22 product categories covered by the EPR rules in France.

          The polluter pays and the recycler receives a bonus

          The French EPR regulations will be extended to include ecomodulation, a mechanism that makes the amount of the fee subject to (product, ROP) on the environmental impact of the product in question. To encourage manufacturers to use recycled materials, the French government has decided to introduce a financial bonus scheme known more widely as bonus-malus. From January 2026. producers will receive a bonus for each tonne of recyclate consumed in the manufacture of selected EPR products.

          In France, the eco-modulation scheme will be covered:

          • wrapping and packaging, printed paper (except books) and graphic paper,
          • packaging used in the B2B sector,
          • electrical and electronic equipment,
          • chemical products and packaging from chemicals (e.g. adhesives, silicones, solvents, paints, varnishes and impregnants, plant protection products, fertilisers, dyes, pigments and inks),
          • furniture, including upholstered furniture and textile decorative articles,
          • toys,
          • sports and leisure goods,
          • DIY products and gardening equipment and accessories.

          Read also: Ecomodulation in e-commerce: what do online shops and packaging manufacturers need to know?

          Producer bonuses are to be financed entirely by extended producer responsibility levies. They will be granted on the basis of information on the quantities of recyclate in products and packaging provided by producers and subsequently verified by producer responsibility organisations (PBOs). éco-organismes).

          The changes to the French EPR system result from the decree of 5 September 2025 establishing the modulations applicable to the financial contributions paid by producers when they contain recycled plastics (fr. Arrêté du 5 septembre 2025 fixant les modulations applicables aux contributions financières versées par les producteurs lorsqu'ils incorporent des matières plastiques recyclées), which will enter into force on 1 January 2026.

           

          Between €450 and €1,000 rebate for using recyclate

          The cited regulation also sets out the rates of bonuses of which the the amount depends on the origin of the recyclate and the complexity of the recycling process, where the secondary raw material in question was produced.

          Producers subject to EPR obligations can receive a rebate of:

          • 550 EUR per tonne of recyclate used, if obtained from the processing of products of the same type, as the product introduced by the manufacturer,
          • EUR 450 per tonne of recyclate used if it comes from the processing of other products covered by the EPR scheme in France,
          • EUR 1,000 (EUR 550 in 2026 and 2027) per tonne of used recyclate derived from waste plastics that are considered technically difficult to recycle. This category also includes plastics for contact applications, which include, among others, recyclates of PET (excluding raw material obtained from recycled PET bottles), EPS (excluding foamed polystyrene), PP, HDPE and LDPE.

          For most products and packaging covered by the EPR no minimum percentage or weight level of recyclate has been set, on which the rebate will be calculated. A producer can therefore receive a premium even for products containing only minimal amounts of recyclate (e.g. in 1%). From this rule however, there are two exceptions - These include plastic beverage bottles made of transparent, coloured and opaque PET and HDPE. For both types of packaging, the regulation establishes an obligation to use certain levels of recyclate, amounting to:

          • for PET bottles - 25% until 31 December 2029 and 30% from 1 January 2030,
          • for HDPE bottles - 0% until 31 December 2029 and 30% from 1 January 2030.

          In the case of these packages, the ecomodulatory the premium will only be charged on quantities of recyclate exceeding the minimum indicated.

          Read also: Ecomodulation in the PPWR - what will modulated packaging charges look like?

           

          Efficient recycling and the proximity principle as additional bonus conditions

          In addition to the use of recyclate, it will also be necessary to realise all stages of waste management and new product manufacture for the eco-modulation bonus to be awarded:

          • within a radius of no more than 1 500 kilometres from the centre of France as described in the act in the form of geographical coordinates,
          • in another EU Member State or in a third country meeting equivalent EU environmental standards.

          In addition, products made from composites, plastics containing additives or substances that make it difficult to recycle, recycled PVC or recyclate obtained from an insufficiently efficient recycling process (recovery of less than 50% by weight of waste) will be excluded from the bonus scheme.

          Find out more about the principles of ecomodulation in France >>


          Elektroniczne wnioski i dokumenty DPR i EDPR – zmiany w BDO od 1 stycznia 2026 r.

          Electronic DPR and EDPR applications and documents - BDO changes from 1 January 2026.

          Elektroniczne wnioski i dokumenty DPR i EDPR – zmiany w BDO od 1 stycznia 2026 r.

          Newsletter

          From 1 January 2026, all applications for DPRs and EDPRs must be submitted electronically. The Ministry of Climate and Environment has launched the Confirmation Module, which allows not only the application, but also the electronic issuing of DPRs and EDPRs.

          From 2026, DPR and EDPR documents only in electronic form

          On 22 December 2025, the website of the Database on Products and Packaging and Waste Management (BDO) was updated with the following information. the launch of the Confirmation Module, which is expected to eliminate the use of paper-based recycling documents. According to the announcement, the DPR module is available to all BDO system users from 1 January 2026.

          From the beginning of 2026, therefore, via the Confirmation Module should be drawn up:

          • documents confirming the recycling of packaging waste (DPR),
          • documents certifying the export of packaging waste or the intra-Community supply of packaging waste for recycling (EDPR),
          • applications for these documents.

          Paper applications submitted in 2026 and covering a period after 1 January 2026 will not be considered.

          Do you have unnecessary documents? Get a quote for the repurchase of DPR and EDPR >>.

          How do I apply for DPR and EDPR in the BDO system?

          Below you will find instructions for requesting DPR and EDPR documents:

          1. Log in to an individual account in the BDO system.
          2. From the side menu select Confirmations -> Applications, then click on the name of the document you wish to request (DPR, DPR GD, EDPR).
          3. Once in the window List of applications click on the green button + New application, which you will find in the header section.
          4. Complete the data in the form online (year, data of the waste holder/entity requesting the DPR/EDPR), data of the addressee of the request, data of the entity for which the document is intended, waste code and information on the NOP associated with the requested document - if applicable).
          5. If you are submitting a DPR/EDPR document to Interzero, you will in the section Data of the entity for which the document is intended, enter the address data Interzero.
          6. If necessary, edit the mass of waste from the KPO by selecting Options -> Edit.
          7. Confirm the application using the yellow button Submit an application.
          8. Confirm that you wish to send the document by clicking on the green button Submit.

          Your application will then appear in the List of applications assigned to the type of document you are requesting (DPR, DPR GD, EDPR) with a status of Submitted. Once the application is approved, you can download the finished document by clicking on the Options -> Download button.

          Not everything online - list of documents produced outside BDO

          Despite work on the Acknowledgements Module that has been ongoing for several years, not all of the planned functions have yet been made available to users. As a result, some documents still have to be produced in paper form.

          As BDO's official website reports from 1 January to 31 December 2026, the following should be prepared on paper:

          • documentary evidence of recycling or non-recycling recovery of waste from products,
          • applications for documents certifying recycling or non-recycling recovery processes for waste from products,
          • certificates for collected waste portable batteries or waste portable accumulators,
          • certificates for treated waste batteries or waste accumulators,
          • certificates for waste electrical and electronic equipment (WEEE) issued by a treatment facility operator,
          • WEEE recycling certificates issued by the recycler,
          • applications for WEEE recycling certificates,
          • certificates confirming non-recycling WEEE recovery processes issued by a non-recycling recovery operator,
          • applications for certificates confirming non-recycling WEEE recovery processes issued by a non-recycling recovery operator.

          For more information, go to the instructions for the Confirmation Module for:

          Source:

          1. Confirmation module for DPR and EDPR, https://bdo.mos.gov.pl/news/modul-potwierdzen-w-zakresie-dpr-i-edpr/