Reducing packaging waste – let’s not lose the momentum

By Ornella Cosomati, EU Public Affairs Manager, PepsiCo & Chair of UNESDA Packaging WG & Tudy Bernier, Senior Policy Manager, UNESDA

As we submitted UNESDA’s response to the Commission’s public consultation on reducing packaging waste last month, it got us thinking. This is a huge initiative – wide in scope and with the opportunity to set a new direction for the way in which future generations deal with packaging waste.

The 2018 Circular Economy Action Plan already provides an excellent springboard for this next phase and our soft drinks industry considers it vital that its core principles are upheld and elaborated in order to accelerate the transition to a circular economy.

Take waste as a resource to start with. We want to reduce the amount of packaging we use – but waste from essential packaging must be considered a resource. Soft drinks packaging that is designed to have the least environmental footprint, is collected, sorted, recycled or upcycled is a resource and must be considered a legitimate part of circular thinking. A closed loop, where every beverage bottle is collected and reused as recycled content in a new bottle, could be achieved through well-designed deposit return schemes. This is why it is so important that the Commission develops guidelines for minimum requirements for such systems by 2022.

Today, too much packaging is neither collected nor recycled. Nevertheless, PET beverage bottles are Europe’s most recycled plastic item – at least 60% collected in 2018, compared to an estimated 41.5% of plastic packaging waste recycled that year, according to Eurostat. Proper implementation of the SUP Directive will help increase collection and recycling rates and we believe higher collection will boost the uptake of recycled content and reduce litter – including aluminium cans and glass bottles. However, we think that setting specific targets linked to consumption or sales reduction contradicts the premise that packaging waste can be circular.

Let’s not forget that packaging is there for a reason and its functionalities are important for hygiene and food safety, among others. For example, should a soft drinks multi-pack be regarded as over packaging or instead recognised as an important tool in providing consumers with smaller pack sizes that support portion control? We are moving towards the development of a more sustainable food system that includes more circularity of packaging and also better nutritional standards and portion control measures.

We want to design packaging in a way that has the least impact on the environment. Leaving room for innovation will be key to facilitate and boost circular solutions. For this reason, it is important that any revision of the eco-design rules for packaging provides enough incentives for business to explore innovative packaging design and recycling solutions. This also means unleashing optimum recycling potential: EU authorities need to validate pending authorisations for mechanical recycling and provide a regulatory framework for enhanced recycling and other innovative solutions to ensure full recycling potential within the EU.

Beyond upholding principles, there are some specifics. Firstly, recyclability. Today, over 90% of the primary packaging used by the soft drinks sector is recyclable – a precondition of circularity. We support strengthening the definition of recyclability and any definition needs to be technology neutral and harmonised across the EU27.

We also recognise the need to be realistic and to look at those sectors that have some existing regulatory restrictions that make it harder to achieve full use of recycled plastic.

The soft drinks sector has mandatory targets for collection and recycled material use under EU law, but food-grade quality rPET is not readily available and competition with other sectors is strong. Those operating in sectors obliged by EU legislation to reach a certain threshold need to be given access to this high-quality material in sufficient quantity, without compromising on safety standards. Bottle-to-bottle recycling should become the norm so we can reach our targets and also avoid downcycling – but to achieve that, our industry needs priority access to food grade recycled content.

We are also committed to using more reusable packaging. That means ‘refillable’ for us. This has to be conditional on having infrastructure in place right along our supply chain and so will require a lengthy transition phase to accommodate the systemic changes that will be needed. The truth is that we have yet to find the reusable model that makes sense from an environmental, socio economic and supply chain point of view – but it is of paramount importance that the one that emerges is built on evidence.

Finally, we need customers to share in our packaging reduction mission. An important element here will be consumer information – on-pack and/or via digital means – to both inform people on how best to sort their waste and to ensure that we retrieve packaging for recycling. To guard against overloading packaging with information that is likely to confuse people, we need a thorough impact assessment. One that will guide the Commission in developing a best-in-class labelling system. This has the potential to not only help citizens make informed and sustainable choices about what they buy, but to also boost packaging collection for recycling and reuse right across the EU.

So that’s the task ahead, and not an easy one: defining new, ambitious rules to boost circularity, without using a punitive approach that will disincentivise innovation, can be a real head-scratcher. But there is broad support and momentum to find solutions, compromises and a way to deliver this agenda, so let’s seize the opportunity. Carpe Diem!