Reducing packaging waste presents a huge opportunity for circularity – so let’s seize itTudy
By Tudy Bernier, Senior Policy Manager, UNESDA
For our industry, packaging is a means to an end. Soft drinks companies use a range of different packaging materials and formats to meet different consumer demands and drinking occasions: aluminium, glass, plastics and cartons – and single-serve, multiserve, resealable packaging etc.
The EU is now reviewing the rules around packaging by revising the Packaging and Packaging Waste Directive (PPWD). The Commission aims to improve design for reuse, promote high quality recycling and reduce packaging waste generation in general. It is critical to get this review right and to set a clear direction for businesses to make investments and speed-up the transition towards a circular economy.
UNESDA has contributed to the EU consultation on the inception impact assessment on reducing packaging waste. You can read our full submission here. We agree more needs to be done. Our members have committed to use 100% recyclable plastic packaging and a minimum 25% recycled plastic content by 2025 and are ready to go way beyond this target.
New requirements must have a positive environmental impact
To reduce its environmental footprint, drinks packaging must be recyclable, recycled and use recycled content. We support the EU review of the essential requirements and use of lifecycle analysis (LCAs) to move this agenda forward and UNESDA was a contributor to the JRC study on comparative LCAs of alternative feedstocks.
The soft drinks industry is committed to using more reusable packaging where it makes environmental and economic sense – and this will always be conditional on having in place a collection scheme such as a Deposit Return Scheme (DRS), where citizens return their packaging to collection points. When set up properly, DRS can lead to very high rates of recycling and reuse and hence contribute to reducing greenhouse gas emissions from drinks packaging, increasing resource efficiency, lowering landfilling with valuable PET packaging and also reducing the potential negative impact of unrecycled packaging waste on air pollution – eg. from incineration.
UNESDA is also in favour of complementing existing mechanical recycling technologies with new innovative enhanced recycling in order to deliver the beverage packaging of the future – with a low environmental footprint and 100% sustainable.
Optimising recyclability, collection and recycling and building a competitive market for secondary raw materials
As the Commission has rightly assessed, if Europe is to boost the uptake of recycled content it will need a competitive secondary raw materials market. Efficient collection and sorting will increase both the availability of food-grade quality recycled PET (rPET) and the sustainable recycling of aluminium and glass. DRS can be effective in meeting both collection and recycling targets and we would welcome Commission guidance to drive proper implementation and functioning across the EU.
Soft drinks producers need assurance and legal certainty in order to incentivise greater uptake of recycled content and long-term investment in infrastructure. Today the beverage industry is the only sector with mandatory collection and recycling targets – but food-grade quality rPET is not available in sufficient quantities as we compete for it with many other sectors. To reach our targets, and also avoid downcycling, we need a dedicated closed loop recycling system for beverage containers. We encourage the European Commission to develop guidance to promote circularity of materials – especially to ensuring that the obliged industry has direct access to food-grade quality rPET.
Reducing the generation of packaging waste
Rather than setting absolute targets for packaging waste we should instead view waste in the wider context of reducing food waste, boosting product shelf-life and upholding safety. Drinks packaging needs to be fit for purpose and must consider functionality, transportation, the consumer experience and of course safety and hygiene. All materials and variations can play a part and we need minimum common requirements to promote the use of only circular packaging while also ensuring adequate freedom for innovation and circular solutions. And packaging legislation must also be futureproof and able to adapt to new material developments and waste management options.
On the subject of overpackaging, we believe the EU should set one clear definition of what it is and what it isn’t. Multipacks for example are not necessarily overpackaging – they are functional, easy to transport and appreciated by consumers. Similarly, at the other extreme is underpackaging, which also needs to be avoided. Surely the goal is to ensure that packaging fulfils its intended role: delivering products to consumers in a safe, hygienic and sustainable way.
In sum, we are convinced that all packaging that is easily recyclable, collected and recycled should be a part of circular thinking. Recyclable packaging needs a clear definition –not too prescriptive and with a technology-neutral definition of recycled content so as not to stifle innovation. As a founding member of the European PET Bottle Platform, we believe its ambitious guidelines could perhaps form the basis of the Commission workplans.
It goes without saying that all measures must uphold the principles of the internal market and avoid fragmentation. They must also be implemented and enforced in a transparent way that offers predictability to businesses in complying and reporting.