UNESDA statement on the European Parliament’s Environment Committee’s vote on the proposal for a Packaging and Packaging Waste Regulation

A step is made towards circularity, but more work is needed to achieve an ambitious, yet realistic and pragmatic legislation

The European soft drinks sector, represented by UNESDA, has deep concerns with the outcome of today’s vote by the European Parliament’s Committee on Environment (ENVI) on its amendments to the draft EU Packaging and Packaging Waste Regulation (PPWR). While the Environment Committee makes several critical improvements to the Commission’s proposal to support the circularity of beverage packaging, UNESDA believes there is also a considerable setback to the EU’s efforts to create a single market for circular beverage packaging.

Nicholas Hodac, Director General of UNESDA, comments: ‘’We welcome the very strong stance taken by MEPs in favour of circularity by promoting closed-loop recycling of beverage bottles and a wider rollout of Deposit and Return Systems (DRS). However, it is alarming to see MEPs support higher reuse targets without any further impact assessment and to give Member States the flexibility to go even beyond these increased targets. Is the EU serious about pushing for a patchwork of national targets that will have devastating consequences on Europe’s competitiveness? The EU should not set targets without any evidence justifying them.’’

UNESDA deplores ENVI’s vote on the compromise amendment (CA 10) on reuse and refill. While reuse and refill are part of the solution to reduce packaging and packaging waste and our sector continues to invest in reusable solutions, reuse and refill should only be implemented where and when it makes sense from an environmental, economic and consumer perspective. That’s why ensuring the complementarity between reuse, refill, and recycling is key.

UNESDA is therefore disappointed to see that ENVI did not approve exemption mechanisms to the reuse and refill targets. In the context of increased targets, this would be a critical condition to avoid unintended adverse effects of the targets on currently well-functioning circular systems and to respect the complementarity between reuse and refill, and recycling.

Increasing the reuse and refill targets without any further impact assessment and allowing Member States to go even beyond these increased targets is not the right approach. This goes directly against the objective of the European Commission to promote harmonisation and risks fragmenting the EU Single Market by creating a patchwork of national targets that will have a considerable impact on Europe’s competitiveness, including for SMEs. This would also increase the complexity of the implementation of the targets and the reporting obligations of businesses.

Reuse and refill targets must be based on a sound impact assessment that properly analyses the costs and benefits that the proposed targets will involve. Without a thorough impact assessment, there won’t be any guarantee that the proposed reuse measures will lead to the desired outcomes. Furthermore, the EU cannot disregard the substantial investments that the industry has made in circular solutions that promote the collection and high-quality recycling of beverage packaging.

We therefore strongly call upon MEPs and Member States to preserve the EU single market and provide beverage producers with the necessary flexibility to invest in the best packaging mix. It is fundamental not to increase the targets without further impact assessment and to provide some form of exemption to operators if certain environmental/waste management criteria are met.

UNESDA, however, acknowledges that there are some very positive elements in the ENVI’s vote that contribute to enabling the circularity of beverage packaging.

In particular, UNESDA welcomes the ENVI’s support for a wider rollout of DRS across Europe and for a mechanism of priority access to certain feedstocks for recycling. This is a crucial condition to avoid the downcycling of food-contact packaging in non-food applications and enable closed-loop recycling whenever this makes sense from an environmental and technical perspective. We ask MEPs and Member States to support this priority access right, which will provide beverage producers with access to sufficient recycled materials to be able to meet the EU mandatory recycled content targets.

Finally, UNESDA is pleased to see ENVI’s support for a mandatory separate collection target of 90%. That’s a necessary step towards enhancing packaging circularity.

The European Parliament will formalise its position on the PPWR in plenary in the end of November and Member States are expected to adopt their position by the end of the year. UNESDA remains committed to further engaging with MEPs and Member States to make the EU PPWR more pragmatic and realistic and to enable the industry to achieve fully circular beverage packaging.


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