In 2023, many different regulatory impulses will affect companies in the packaging industry, some of which, such as the Packaging Waste Regulation (PPWR) or the new regulation of “green claims”, are still being hotly debated. Others, such as the new reporting obligation of the Corporate Sustainability Reporting Directive (CSRD), have been law since January 05, 2023 and are gradually coming into force. So that your company can face the challenges of the new year with a good feeling, we recommend the 6-point plan for “Regulation-Readiness”.
#1 – Professionalize resources and capacities
Fundamentally, the resources and capacities in the company for sustainability must now be professionalized and strengthened. The topic of sustainability is now so complex that it is often no longer sufficient for the quality manager or the assistant to the CEO to do this in addition to their normal tasks. The tasks must be seen as a full-fledged job. You should either qualify an employee internally or look for someone on the job market, although this might be difficult. Either way, it should now be clear that sustainability is becoming a compliance issue (just as it has been a customer issue for several years). The topic of sustainability must be given sufficient time and also financial resources in the company.
#2 – Check sustainability communication
Critically review your sustainability communications. For example, do you proclaim product- or company-based sustainability claims on your website or in your customer communications? If so, can you substantiate all your claims in a credible and accepted way (with life cycle analyses, footprint assessments or certifications based on an ISO or DIN standard)? If so, then continue to build your sustainability communications. If you can’t substantiate the claims, then you either need to create the corresponding prerequisite for each claim or drop the claims.
#3 – Carry out climate risk analysis
You have done a greenhouse gas inventory but not a climate risk analysis? One of the central building blocks of the new CSRD (Corporate Sustainability Reporting Directive) is the very holistic reporting on the topic: impact of climate change on the company. Both mitigation (i.e. a transformation strategy within the framework of the 1.5 degree target) and clear adaptation measures with a climate risk analysis for the company’s locations and its value chain are required. Start the preparatory work for CSRD reporting requirements this year. After all, building a climate risk management system doesn’t happen on the side. It requires both resources and expertise.
#4 – Approach CSRD Gap Analysis
For most companies, the CSRD will not become relevant until 2026 in the context of reporting on the year 2025. But the reporting standard requires a lot of assessments and data that were not required for most companies until now. For this reason, you should do a gap analysis in 2023. What data do we already have, what data do we still need, and how can we collect it in a pragmatic and cost-effective way? The most important tool for this work is an updated dual materiality analysis formalized by clear legal rules. This means that not only is the impact of the stakeholders assessed, but there is also a financial assessment of the sustainability topics and their impacts.
#5 – Supply chain risk assessment is without alternative
The topic of supply chain risk assessment is a long-running issue and has been with us for quite a while now. Companies that have not yet taken appropriate steps and measures should urgently set priorities here! For the required climate strategies as well as for national and European reporting obligations, adapted supply chain management is a central pillar – including the new risk topics of climate change impacts and labor and human rights. By completing these tasks, you are also preparing the company for the EU’s “Human Rights Due Diligence Regulation” under discussion.
#6 – Sustainability of the products not forgotten
Product sustainability is also the focus of regulations. Examples include the planned recycling quotas in the new PPWR or levies on single-use packaging as in the UK and France. In some cases, single-use packaging is being banned altogether. A critical look at the product portfolio now helps twice. Firstly, to identify risks and secondly, to develop opportunities. Design for recycling should become the focus of innovation. Efficient reuse models will find a market that will expand greatly with EU regulations. The search for producers of demonstrably sustainable packaging will increase greatly.
Advice and action
Admittedly: There is a lot to do in 2023 – and the issues are not a freestyle, but a mandatory program. With our 6-point plan, you are at least well on your way to mastering the challenges. At B+P, we are happy to help you beyond that and support you in implementing the priorities that are most important to you.
