Revision of the EU Packaging and Packaging Waste Regulation
The EU Commission published new rules on packaging and packaging waste on 30 November. These include a mandatory deposit system for plastic bottles and aluminium cans, design criteria for all packaging to increase recycling rates, and labelling on all packaging to help consumers separate waste correctly, as well as appropriate labels on recycling containers to make it clear where to take each package. There are also new targets for waste reduction in member states and mandatory reuse or refill targets in areas such as retail and catering.
The industry association Unesda already published a reaction to the new targets yesterday. Nicholas Hodac, Director General of Unesda Soft Drinks Europe, comments: ‘’The published proposal is ambitious and contains several important enablers for Europe’s journey towards increased collection and recycling, and the integration of more reuse. However, further improvements are necessary to support our sector in achieving full circularity and integrating more reuse.’’
Particularly, Unesda states that the proposal needs to urgently address the issue of downcycling of food-grade materials into non-food-grade applications: It currently fails to include a priority access mechanism or right of first refusal that grants fairer access to the necessary amount of recycled content to those sectors that are required to use food-grade materials to comply with EU food safety requirements. This is a key enabler for further promoting closed-loop recycling, while preventing downcycling of food-grade recycled materials. Sectors that are not required to use food-grade materials must also be incentivised to invest in efficient collection and recycling systems that can achieve true circularity for their own products, says Unesda.
In addition, Unesda takes the position that the proposal places reuse targets only on the beverage sector and on each of its manufacturers, distributors, and in each Member State: The PPWR needs to take into account the huge diversity of economic operators in the beverage sector, the different sizes of the companies and the different types of consumption experiences of Europeans. Many businesses may become unsustainable due to an ineffective use of recycling technology investments, Unesda warns, which will be made redundant with the necessary additional reuse investments in each country; the proposal also does not state how the circularity of recyclable beverage packaging, achieved through mandatory investments in deposit return schemes, will be protected, says the association.
There is also lack of evidence that the proposed approach for reuse targets will lead to the intended environmental outcomes, says Unesda. That’s why the association reaffirms the need for the targets to be based on a thorough environmental and cost impact assessment to ensure that reusable beverage systems are only put in place when and where they make the most sense for our environment and are cost-efficient.
