Will the European Parliament use the EU Packaging and Packaging Waste Regulation to set the right course for fully circular beverage packaging?
By Nicholas Hodac, director general of Unesda Soft Drinks Europe
The EU is defining the future of circular beverage packaging as we speak. We have entered now an intense legislative cycle with thousands of amendments being tabled by the European Parliament to the proposal for an EU Packaging and Packaging Waste Regulation (PPWR).
The European soft drinks sector is determined to support the EU’s objective in ensuring that “all packaging on the EU market is reusable or recyclable in an economically viable way by 2030” and therefore aims to achieve fully circular beverage packaging by 2030.
However, our ability to deliver on this commitment is highly dependent on a more workable PPWR. It seems we are not the only ones with this idea… The fact that so many amendments have been tabled highlight the strong interest of MEPs in transforming the proposal released by the European Commission last November and contribute to the circularity transition.
Will the proposed amendments help designing a final EU PPWR which is ambitious enough, innovation-friendly and will support the industry’s transformation to deliver on its goals? Let’s take a look at where we stand and reflect upon some of the most relevant articles for our sector.
Art. 43, Art. 44 and Annex X – Enable closed-loop recycling through Deposit and Return Systems (and much more!)
Deposit and Return Systems (DRS) have a key role to play in achieving high collection and high-quality recycling of beverage packaging in the EU. UNESDA therefore very much welcomes the proposal for a wider roll-out of DRS in Europe (Art. 44) as well as the development of minimum requirements (Annex X) to ensure those systems are set up and run in the most effective and cost-efficient way.
Our sector has joined forces with the NGO community to advocate for DRS as one of the most effective ways to boost collection rates of our packaging and help us fulfill our commitment to reach 90% collection of all our packaging (PET bottles, glass bottles and aluminium cans) by 2030.
That’s why we are concerned by the number of amendments suggesting for DRS to become voluntary rather than mandatory (AMs 2350-2354) and by those proposing a reduction of the threshold for an exemption from the DRS obligation (if a Member State’s collection rate is at 85% or less) such as AMs 178 or 2406 for example. These amendments, if they pass, will have a negative effect on our collection efforts and would also not be consistent with the targets set in the Single-Use Plastics Directive (SUPD), that is, mandatory 90% collection rate for PET bottles by 2029.
The additional benefit of DRS is the quality of the materials collected. The PPWR proposal already recognises that DRS will contribute to the increase of the supply of good quality secondary raw material suitable for closed-loop recycling. However, the text does not include any concrete measure which actually support closed-loop recycling to avoid downcycling. It is therefore key to fully support the various amendments to Art. 43 and Annex X proposing the set-up of a priority access to the food-grade feedstock for recycling for use in food applications (AMs 2657, 2666 and 2669 (Annex X) and AMs 175, 2342, or 2345 for example (Art. 43)). This is the only way to ensure that our plastic bottles are recycled into new beverage packaging in a closed-loop system rather than being downcycled into non-food applications.
Art. 3 – Prevent downcycling by supporting a clear definition of high-quality recycling
Facilitating high-quality recycling is a key enabler to put an end to the downcycling of PET bottles and promote true circularity. The PPWR proposal states that Member States shall ensure that systems are set up to provide for the return and separate collection of all packaging waste in a way that facilitates its preparation for re-use and high-quality recycling (Art. 43.1). However, the proposal does not include any definition of what high-quality recycling actually is.
We are therefore pleased to see numerous amendments aimed at fixing this gap and proposing a definition of high-quality recycling in Art. 3. We, however, note with concern that some proposed definitions are not worded in a way that would actually prevent food-grade feedstock for recycling from being downcycled in non-food applications. Several amendments state that the material must be able to replace “primary materials” but they do not refer to the “primary or a similar application” (AMs 702-709). This is an essential clarification that MEPs should make to ensure that high-quality feedstock for recycling will be used in similar applications in a closed-loop system (food-grade to food-grade for example). That’s the only way to achieve true circularity and this is why we welcome amendments already including this essential element (AMs 64, 683, 697 and 701).
Art. 7 – Be consistent with existing legislation and adopt a more realistic recycled content calculation
Another crucial element in the PPWR proposal requiring further consideration is the calculation method for the proposed recycled content targets. The starting point should be existing legislation, such as the SUPD, which has recently been adopted and where recycled content is calculated on average within the territory of a Member State. Why should we change the rules when we are half way into their implementation?
We notice we are not the only ones missing the logic behind the Commission’s proposal to place the PPWR targets on each unit of packaging. Many amendments are indeed challenging this approach by proposing alternative calculation methods, such as per format, per plant, per Member State or per manufacturer at EU level. We believe that a good compromise is to calculate recycled content per manufacturer per Member State, as proposed by some MEPs (AMs 1096, 1097, 1101 and 1158).
We also see wide support from MEPs for the recycled content targets to be set on plastic packaging and not on the plastic part of packaging, as currently formulated in the PPWR proposal. In our view, these are valid amendments that would bring further consistency with the approach taken in the SUPD and which MEPs should support.
Art. 26 – Ensure the necessary complementarity of recycling and reuse
Packaging sustainability can be achieved through a range of complementary solutions, including packaging reduction, recycling, reuse and refill.
As a sector, we support reuse but we believe it should complement the efforts already made – and yet to be pursued – to reduce and recycle packaging. We should not discard the massive investments that beverage producers are making in circularity through collection and high-quality recycling of their packaging.
Moving towards more reusable beverage packaging requires major operational changes and investments (e.g. new bottling lines, more storage space), as well as new consumer habits. Furthermore, some studies have shown that reusable packaging does not always bring environmental benefits compared to its single-use recycled counterpart.
The environmental and economic impact of reuse should therefore not be ignored and this has clearly been a matter of great concern for a vast majority of EU Environment Ministers and MEPs. They question the lack of evidence and data in the European Commission’s impact assessment to justify the proposed reuse targets and have asked for guarantees about the positive environmental impact of shifting away from single-use packaging.
Given the strong diversity among Member States, it is important to ensure that reusable packaging is introduced where it makes more sense than its recyclable single-use counterpart.
A large number of MEPs tabled amendments providing for derogations from the reuse and refill targets should some environmental criteria be met. It is indeed key to provide for a flexible approach, with well-designed exemptions, to allow manufacturers to invest in the packaging mix that makes the most sense from an environmental, economic, and consumer perspective, and which is based on the complementarity of recycling and reuse.
Art. 26 – Recognise ALL reuse and refill solutions
Offering convenient packaging solutions to consumers will be the key to change purchasing patterns and realise a circular economy in practice. There are already different types of reusable and refill solutions on the market, and they all contribute to reducing the amount of beverage packaging and beverage packaging waste, which is the objective pursued by the PPWR.
We are therefore concerned to see several amendments removing the possibility for “systems enabling refill” to account for the achievement of the reuse and refill targets (AMs 135, 1781-1783, and 1926 for example).
It is key to consider all solutions for the achievement of the EU’s reuse and refill targets because:
- A too narrow definition of reuse and refill would hinder innovation in the field of package-less solutions and would not be future-proof.
- Offering convenient and attractive solutions to consumers will be the key to change purchasing patterns.
- A traditional returnable bottle may not always, and under all conditions, be the best solution from an environmental perspective.
- Offering traditional returnable bottles only represents a major investment for beverage companies and the retail sector.
- Finally, systems enabling refill have a huge potential in terms of packaging reduction. Those systems can dispense a high volume of beverages without any, or with a limited amount of packaging.
We cannot afford missing the opportunity to make the right amendments to the EU PPWR proposal. We will continue our constructive engagement with EU policymakers and we ask them to support us on our journey to fully circular beverage packaging.