An open letter has been written by different LCA (Life Cycle Assessment)-scientists urging the Members of the European Parliament to treat the results of some Environmental Impact Assessments with caution, this with regard to the current debate on the PPWR (*).

The goal of this statement is to discuss some of the recent reports on the benefit of single-use packaging, which, as mentioned by the experts, do not account for the full complexity of environmental impacts.

LCAs are snapshots of a products’ environmental impacts. The scientists remarked the fact that, especially because they are snapshots, their results depend on how they are framed. Small variations in assumptions and incomparable functional units can change the results.

The number of reuses has been highlighted as one of the main topics of the discussion, together with the weight of reusable products, the washing and transport logistics. These factors will change as systems of packaging evolves, so the impact of different packaging options will evolve also.

Some critics have been placed against LCA studies comparing single-use packaging and reuse packaging to demonstrate that single-use is invariably better. Reason here is the lack of sensitivity analyses or breakeven points.

The writers advise the EU institutions to check the methodology in case of other LCAs used to make policy decisions, applying some important points, such as among others:

•  The respect of steps laid out in ISO standards, starting with clear scope definition and comprehensive description of inventory data.
•  The full life cycle of the product to be reviewed.
•  If assumptions or lower quality data on parameters are used, a sensitivity analysis should be performed.
•  To consider different business model configurations for the use and end of life phases.
•  …

Any report which assesses environmental impacts without transparency of data, a peer-review process or respect for established frameworks cannot be considered a good environmental impact assessment and so caution should be exercised when considering the results and recommendations.

IBE-BVI members can obtain by simple request a copy of this letter.

(*) Packaging & Packaging Waste Regulation

Post 6/11/2023