PPWD: Reality-check

The re-usable targets of the Packaging and Packaging Waste Directive (PPWD) for the European countries are controversial. The EU countries are at a completely different infrastructural, technological and economic level. Consumer behaviour is also different. Many other factors have to be taken into account in order to be able to use reuse in a really meaningful way. Reusable doesn’t really make sense in every application, says Tobias Bielenstein, Public Affairs Sustainability Manager at Genossenschaft Deutscher Brunnen.

PETplanet: On the German mineral water market there has been glass reuse as well as PET reuse for a long time. The word single-use is not popular in Germany as the recycling and return rate is around 99%, which is why the term PET circular is used. How did Germany manage to successfully set up this overall system? What special challenges did it face and how much time did it take?

Bielenstein: Germany has a re-use tradition since many decades. The first deposits for re-use bottles were introduced at the beginning of last century. So, when the mandatory deposit for single-use beverage containers – which includes PET and glass-bottles as well as cans – was introduced in 2003, it was not necessary to explain to German consumers how to return containers with a deposit. In fact, our numbers show that around 50% of German consumers still believe today that all bottles with a deposit are re-use bottles – while the market share of reuse is only around 43% in the beverage market. This is also because returning a bottle with a deposit is very easy to consumers. No matter whether it is re-use or single-use, most RVMs (reverse-vending machines) are set-up at the POS and they will accept both types of bottles as well as crates. It is only the two big discounter-chains that don’t sell nor accept returning re-use bottles.
Of course, there were challenges in operational terms when the DRS was introduced. This included set-up of RVMs and a clearing-mechanism and -institution for deposits. But this was solved after a short transition period. Today it is easy for consumers. And this is key in my view: no matter whether it is re-use or single-use with a deposit – it must be easy and convenient to consumers to become a success.

PETplanet: What exactly does the PPWD provide for and what problems arise specifically for the German system as a result of the targets set? Especially since Germany already has a higher value of recycled content than the EU demands.

Bielenstein: The PPWR draft as well as the amendments discussed in the European Parliament are putting our successful re-use systems at risk and will lead to higher operational costs, which will weaken them in competition. The reason is that the commission has defined too specific requirements regarding the management of re-use systems. This poses a huge issue for existing and future re-use systems in Europe. There are many varieties among re-use systems. A re-use system for to-go-beverages is very different to a system of re-use bottles filled in an industrial production. The current draft does not reflect these differences. It would be more effective in regulatory terms if we would have a good framework and less detailed regulation in the PPWR to allow for effective governance and options for innovation for re-use systems.
If this is not reflected, we will pledge for an exception of markets that exceed the goals of the regulation – like we do in Germany. But this is definitely only the second-best choice.

PETplanet: Re-usable is a system – not just a package in itself. It is made up of the producers, the retailers and of course the consumer. What challenges do you see in introducing and implementing this in any EU country?

Bielenstein: Re-use systems need to be simple and easy for consumers and effective for all other stakeholders involved. Therefore they have to build on consumer behaviour and the structure of retail in each country. And we all know these structures are very different from country to country within Europe. This is again a call for a strong regulatory framework and space for individual implementation in each country. Europe and EU are not about harmonisation in every details. In our view it is most important to be “united in diversity” – which should be also the guideline when it comes to re-use systems.

PETplanet: Which SUP beverage applications make sense in which EU countries and why? Do you have any suggestions or assessments?

Bielenstein: In Germany, most mineral water companies have a mix of re-use and single use packaging offers. This give brands space to be relevant to all consumers in all consumption situations. As an example: you might prefer a glass re-use bottle if you have guests at home for dinner, but you will go for a PET bottle whenever you are on the road or doing sports.

PETplanet: You are in regular contact with Brussels regarding the PPWD. What are the main criticisms you have of the directive? And what are your recommendations?

Bielenstein: First: we are convinced that the regulation is the right approach. We welcome the current directive to become a regulation. We also support the goals of the regulation: all packaging should become recyclable and should be re-use whenever this makes sense. This means to be sustainable in environmental, social and economic terms. Our main criticism is the too detailed approach. This is not only the case regarding the governance of re-use systems. It is also e.g. that there are paragraphs regarding hygiene and food safety. No question: this hygiene and food safety is of highest importance. But the packaging regulation is the wrong place to regulate that. There are two more important things: re-use needs a transition period regarding recyclate rates. And PPWR needs to cover the return of re-use container in an appropriate way.

PETplanet: What innovative & new types of packaging or materials do you see in the beverage packaging sector? Do you see reusable as an opportunity here?

Bielenstein: Our next task is to rise the rPET share of our reusable bottles and to further reduce our carbon footprint on production and logistics of the re-use containers. Anything that’s helps to reach these goals is welcome. And: we should not limit ourself to beverages. PET is a wonderful material: we should further explore how to apply it for re-use packaging solution in other food- and non-food-packaging whenever this makes sense in environmental terms. It is our job to share our learnings in the beverage sector to make this a success.

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