Interesų grupė
Feedback on the Commission Proposal for a Packaging and Packaging Waste Regulation (PPWR) Position Paper April 2023 Ref. Ares(2023)2845428 - 21/04/2023 2 Position Paper of MIWA on PPWR | April 2023 MIWA welcomes the Commission’s PPWR proposal and its intention to drive the packaging sector and waste towards an increasingly circular economy system while preventing single-use packaging. Setting clear requirements and establishing a common framework for packaging collection, reuse, and refill systems, as well as recycling, is necessary to achieve environmental targets, reduce growing packaging waste generation and ensure compatibility of diverse national approaches.
…targets, reduce growing packaging waste generation and ensure compatibility of diverse national approaches. Although the proposal of the European Commission offers a solid basis for achieving the broad objectives described above, MIWA is concerned that some essential elements, particularly those related to reuse and refill systems, may be omitted in the proposal. This position paper presents views on key issues related to these elements and offers recommendations for the co-legislators, which shall be considered during the legislative procedure. 3 Position Paper of MIWA on PPWR | April 2023 Reuse and Refill Systems MIWA is convinced that reuse and refill systems could provide many potential benefits over conventional linear packaging approaches. Still, ensuring those systems are built on a solid set of principles is crucial.
…linear packaging approaches. Still, ensuring those systems are built on a solid set of principles is crucial. Reuse systems that are carefully designed and implemented offer cost advantage and convenience to consumers, reduce the financial impacts of waste management, and provide new opportunities for entrepreneurs, businesses, and the workforce. When implementing reuse and refill systems, they should be designed and operated to provide environmental, social, and economic benefits over the status quo. A shift from a linear to a truly circular economy is needed. This shift should be initiated and supported by effective and determined policy action at the European Union and Member State levels. The regulatory landscape will be one of the key aspects enabling the successful implementation of reuse and refill systems.
…regulatory landscape will be one of the key aspects enabling the successful implementation of reuse and refill systems. Supportive policy and market conditions should be created to transition from pilot projects to adopting systems at scale.
…policy and market conditions should be created to transition from pilot projects to adopting systems at scale. MIWA thus recommends the co-legislators to consider the following elements when reviewing PPWR: A Addressing the overall environmental impact of reuse and refill properly B Extending reuse and refill categories and setting ambitious targets C Specifying requirements for refill stations D Ensuring retailer engagement in refill systems E Encouraging Member States to take additional measures and incentives 4 Position Paper of MIWA on PPWR | April 2023 A Addressing the Overall Environmental Impact of Reuse and Refill Properly To achieve the best environmental impact and to ensure the effectiveness of the proposed measures connected to reuse and refill systems, the life cycle assessment (LCA) should be explicitly addressed in the PPWR, and transparent monitoring of the impact of…
…of the impact of systems during their operations should be required (for example through smart elements). Any reusable packaging must be durable to withstand the impacts of filling, transportation, or cleaning. To fulfil these objectives, reusable packaging is often heavier and more material- intensive than single-use packaging. This means that if reusable packaging is used just once or occasionally, it has a worse overall environmental impact than single-use packaging. Current technology enables packaging to circulate in well-controlled closed loops with a high end-of-life recovery rate. Thanks to smart elements such as RFID chips, it is possible to monitor how many times packaging (both B2B transportation as well as consumer smart cups) was used and where they are located. It can also incentivise repetitive and frequent use of the packaging (both for businesses and consumers).
…are located. It can also incentivise repetitive and frequent use of the packaging (both for businesses and consumers). This helps minimise single-use packaging across the entire supply chain, including primary, secondary, and tertiary packaging, which can reduce waste generation by 90% and delivers a 71% lower environmental footprint than single-use packaging. Reuse systems must enable a sufficiently high number of uses to be impactful and perform better than an equivalent single-use alternative. As operating reusable packaging also involves reverse logistics and cleaning, packaging pools should be of optimal size, allowing 5 Position Paper of MIWA on PPWR | April 2023 frequent uses while minimising transportation distances. The impact of refill systems might be questionable as many of these systems use single-use packaging.
…distances. The impact of refill systems might be questionable as many of these systems use single-use packaging. It is therefore essential to assess the sustainability of the reuse and refill systems design through LCA and to ensure transparent and continuous monitoring of the impact they deliver. At the same time, it is crucial to acknowledge that momentaneous impact during the first phases of piloting and implementation might not be positive, as these systems need to attain a certain scale to perform environmentally and economically. Therefore, the operators of reuse and refill systems should receive support and be given an adequate testing period to properly evaluate and optimise the final performance and operability of those systems. This shall encourage impactful deployment at a wide scale.
…the final performance and operability of those systems. This shall encourage impactful deployment at a wide scale. Article 10 (Reusable packaging) lays down different conditions for packaging to be considered reusable. Further, Articles 24 and 25 and Annex VI Part A to C set down obligations and requirements for reuse and refill. However, the articles do not explicitly mention the requirement for the systems to perform well in relation to minimising negative environmental impact. LCA should evaluate whether the reuse system is designed to achieve a certain impact, and the systems should allow continuous monitoring and evaluation of whether this impact is being achieved.
…impact, and the systems should allow continuous monitoring and evaluation of whether this impact is being achieved. 6 Position Paper of MIWA on PPWR | April 2023 B Extending Reuse and Refill Categories and Setting Ambitious Targets Deployment of reuse and refill systems is currently possible for a wide range of products while complying with security and hygiene standards. Any future packaging and waste legislation, both at the EU and Member State level, should aim to set ambitious binding reuse and refill targets. MIWA welcomes the Commission’s ambition to gradually decrease waste per capita production set in Article 38 (Prevention of packaging waste) and the provisions targeting reuse as defined in Article 26 (Re-use and refill targets). However, according to MIWA, additional areas and sectors should be considered for mandatory reuse targets.
…targets). However, according to MIWA, additional areas and sectors should be considered for mandatory reuse targets. This includes, for example, dry food, pet food or personal and home care products. Furthermore, it should be ensured that new areas for expanding targets are explored and considered under the binding targets. Moreover, setting ambitious targets would signal to the private and retail sectors that moving away from single-use plastic to some other single-use material is unacceptable. In this sense, the timeframe given must be realistic and adequate to spur action with clear milestones for delivery. 7 Position Paper of MIWA on PPWR | April 2023 C Specifying Requirements for Refill Stations We believe that refill systems may perform even better in terms of efficiency and impact delivered compared to purely B2C reuse systems when designed appropriately.
…in terms of efficiency and impact delivered compared to purely B2C reuse systems when designed appropriately. Therefore, we consider refill to be generally underestimated within the proposal. Additionally, it is crucial to consider certain aspects of traceability and product hygiene, as these factors are essential for the safe and efficient operation of refilling stations. Refill stations usually dispense different types of products from the same station/dispensers, and without proper separation or identification, there may be a risk of cross-contamination or mixing of different products, making it difficult to trace the origin, the batch numbers, expiration dates, quality and safety (i.e., from the point of view of allergens) of each specific product. Refill stations should thus implement labelling systems that provide detailed information about the abovementioned aspects.
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