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ATIEL & UEIL Joint Sustainability Committee 7 Packaging


Packaging plays a crucial role in the lubricant supply chain, from production to end-user delivery. However, at the end of a lubricant’s life, packaging, whether it be plastic containers, metal drums, or Intermediate Bulk Containers (IBCs), can contribute significantly to environmental challenges, such as waste generation, plastic pollution, and inefficiencies in material recovery. For lubricants manufacturers, optimizing packaging processes and materials is an essential step towards achieving sustainability goals and aligning with regulatory pressures. This section provides guidance on sustainable packaging strategies, upcoming regulations and best practices.


7.1 Key Challenges and Opportunities


The main sustainability challenges associated with lubricant packaging include the use of non- recyclable materials, high levels of waste, and inadequate systems for packaging recovery and reuse. Addressing these challenges presents an opportunity to reduce environmental impacts, complywith emerging regulations, and meet customer expectations for greener products.


7.2 Regulatory Landscape


The whole packaging industry is subject to increasing examination as sustainability and circular economy principles gain importance in the regulatory environment. Several upcoming and existing European regulations will significantly impact how packaging is produced, used, and managed at the end of its life. Important regulations can be on the EU level, such as: “Waste Framework Directive (WFD)”, the “Circular Economy Action Plan (CEAP)” and the “Packaging and packaging waste regulation (PPWR)”, or local such as the plastic packaging taxes in UK and Spain. Since the PPWR will have by far the biggest impact in the coming years, you can find below an extraction of its upcoming changes.


7.2.1 European Union Packaging and Packaging Waste Regulation (PPWR)


The wording of the PPWR has been officially accepted and the regulation entered into force on February 11, 2025. It is a cornerstone of the EU's efforts to reduce packaging waste and promote recycling. The PPWR aims to ensure that all packaging is reusable or recyclable in an economically viableway by 2030.


Following you can find some key requirements:


• Mandatory Recycled Content: Packaging materials, including plastics and metals, must contain a minimum percentage of recycled content. This regulation is particularly relevant for plastic lubricant containers, which must include a minimum of Post- Consumer Recycled (PCR) content.


• Waste Reduction Targets: Packaging producers must minimize the use of excessive packaging and reduce overall waste generated. This can impact large-scale packaging formats like drums and IBCs, as well as small packages such as bottles and cans.


• Design for Recyclability: Packaging must be designed to be easily recycled. The use of composite materials with combination of non-separable different materials or multi- layered plastics that hinder recycling processes will soon be restricted.


• Reusable Packaging Targets: Companies are encouraged to design packaging that can be reused, particularly for industrial packaging like drums and IBCs. Producers will need


Version 11.06.2025 © ATIEL and UEIL Lubricants & Greases End of Life, Sustainable Best Practices Page 19 of 42


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