The proposed packaging regulations by the European Union (EU) represent a positive step forward. However, it has so far faced criticism and calls to establish a comprehensive framework that supports producers in achieving a closed-loop approach to packaging.
Last year, the European Commission unveiled its Packaging and Packaging Waste Regulation (PPWR) proposal, outlining measures aimed at reducing packaging waste. For consumers, this meant providing reusable packaging options, reducing unnecessary packaging, and using clear labels for recycling. For industry, it means creating new business opportunities for smaller companies and decreasing reliance on virgin materials.
While this proposal lays a solid foundation for a more circular economy, many believe it falls short in providing some of the necessary mechanisms to fully close the loop on their packaging materials.
The proposal’s inflexible approach to reuse was also seen to pose risks to the investments made by the value chain in recycling efforts, threatening the viability of numerous companies, particularly small and medium-sized enterprises (SMEs).
In May, the European Parliament lawmaker negotiating a new law, MEP Frédérique Ries, removed several packaging reuse targets from the proposal. Ries justified her move by stating that the environmental benefits of reuse in the food and drink takeaway sector are difficult to prove and there is a lack of a large-scale system within member states.
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Proposed amendments put forth by Ries offer significant progress in addressing concerns. However, further action is still required to enable circularity and resource efficiency, specifically in the realm of beverage packaging.
Collection and access of recycled materials
Both the Single Use Plastics Directive and the Commission PPWR outline targets for achieving 30% recycled content in PET (polyethylene terephthalate) beverage bottles by 2030. But, meeting these targets requires that producers have access to an adequate supply of recycled PET (rPET).
Currently, this is not the case due to insufficient packaging collection in most EU countries that lack a deposit and return system (DRS), such as the Danish Dansk Retursystem scheme. Another major concern for beverage producers is the use of rPET bottles by other industries for non-recyclable applications, removing them from future use.
Two crucial measures are needed to ensure the availability of rPET:
- The mandatory implementation of DRS, as proposed by the Commission. DRS has proven to achieve collection rates that are, on average, 40% higher than standard extended producer responsibility schemes (EPRs). These systems should be operational across the EU two years prior to the implementation of any recycled content targets.
- Beverage producers must be granted priority access to the recycled material obtained from their bottles. This should be considered a minimum requirement for both DRS and EPRs, as suggested by MEPs Toia and Joron, the Rapporteurs for the ITRE and IMCO committees, respectively.
An area that promises transformation is the proposed measures for reusable packaging. MEP Ries’ draft report suggests removing mandatory targets for reusable packaging set for individual producers.
This approach aligns with practical and environmental considerations within the industry. Shifting to reusable packaging would require significant investments from producers, with no guarantee that retailers would source their new products. Investments would inevitably compete with ongoing investments in closed-loop recycling schemes and pose a threat to the SMEs that are the backbone of our sector.
From an environmental standpoint, the benefits of reuse (bottles are simply cleaned and reused) versus closed-loop recycling (bottles are recycled and built into new bottles) heavily depend on the context. For natural mineral water and spring water producers operating in rural areas, the obligation to bottle at the source is a critical factor due to the distances involved from the source to the point of sale.
Allowing for complementarity and flexibility between reuse and recycling, as proposed by MEP Patrizia Toia, would enable the industry to collectively pursue a sensible path for reuse.
Progress Must Be Upheld
Sustainability lies at the core of the natural mineral water business, encompassing source protection and packaging circularity.
The Natural Mineral Water Europe (NMWE) fully supports the revision of packaging legislation. While we will advocate for the improvements mentioned in this proposal, it is crucial to safeguard the advancements already included in MEP Ries’ draft report throughout the legislative process.
Achieving packaging sustainability is a complex endeavour that requires collaboration between industry players, policymakers, and NGOs. Ambition, pragmatism, and flexibility must underpin all efforts to address this.
