Interesų grupė
…1 Reloop Position Paper on the Revision of the Packaging and Packaging Waste Directive December 2020 Reloop is a broad platform of like-minded interests that brings together industry, government, and non- governmental organisations to form a network for advances in policy that create enabling system conditions for circularity across the European economy. This paper aims to contribute to the ongoing revision of the Packaging and Packaging Waste Directive (PPWD) and highlights some of the key policy measures needed to achieve the objectives of the revision.
Waste Directive (PPWD) and highlights some of the key policy measures needed to achieve the objectives of the revision. 1) Material-specific waste reduction targets The generation of packaging waste in the EU is growing. The current EU waste legislation lacks binding targets and other concrete measures to stimulate waste prevention. In order to reverse this trend of increasing packaging waste generation and support the EU waste hierarchy, which prioritises waste prevention, there is a need to set binding material-specific waste reduction targets at EU level and eliminate excessive packaging. Targets are generally based on weight, which can be challenging to achieve without resulting in unintended consequences of material substitution that can lead to higher environmental footprint. Therefore the EU should consider impact- or output-oriented targets based on the net CO2 impacts of a…
…impact- or output-oriented targets based on the net CO2 impacts of a package rather than the weight-based targets. 2) Clarification of the term ‘recyclable’ ‘Recyclable’ is a broad term which can lead to different interpretations. While some packaging might in theory be recyclable, this does not necessarily mean that it will actually be recycled in practice, for different reasons such as lack of economic viability / lack of end market. Therefore, ‘recyclable’ should be clearly defined by the European Commission to include both technical and economic viability of recycling in order to make the circular economy a reality. This could be a combination of measures proposed by the Commission, namely the use of recycling rate threshold and qualitative statements and design for recycling standards in order to ensure that the packaging is not only easily recyclable from a technological…
…that has access to separate collection systems, combined with the recycling rate thresholds and design standards. 3) Reuse targets and other measures to promote reusable packaging Reuse is a key element of circular economy and should be further stimulated at the EU level in order to reduce the environmental and climate impact of packaging and address the worrying trend of decline of reusable packaging (e.g. refillable bottles) across Europe. Multiple reports and studies have recognised important environmental, climate, economic and social benefits of reusable packaging (e.g. Ellen MacArthur report ‘Reuse - Rethinking Packaging’). Ref.
…economic and social benefits of reusable packaging (e.g. Ellen MacArthur report ‘Reuse - Rethinking Packaging’). Ref. Ares(2021)84535 - 05/01/2021 2 In addition, Reloop commissioned the Copernicus Institute of Sustainable Development of the University Of Utrecht, to prepare a report1 which aims at understanding the benefits of reuse by evaluating the multi-layered environmental impacts of both single-use and reusable types of packaging through an in-depth comparative analysis of 32 Life Cycle Assessment (LCA) studies. This technical exercise allows for a clearer understanding of the conditions under which reusable packaging is the most environmentally friendly choice. The study considers the conditions for eco-efficiency of packaging and concludes that reusable packaging (consumer & transport) has significant benefits over single-use packaging.
…and concludes that reusable packaging (consumer & transport) has significant benefits over single-use packaging. We are therefore strongly in favour of EU-wide targets on reusable packaging, e.g. refill quotas for beverages, food boxed, pallets etc. Country level taxes on single-use packaging are also an efficient instrument to incentivise reusable packaging. We also support introducing a requirement for mandatory reusable transport packaging, since transport packaging is a sector where reuse systems are already well developed and proven to be effective. One of the main challenges the reusable packaging sector, in particular reusable transport packaging, is currently facing is the lack of legal certainty related to legal title / ownership rights. In particular, in some Member States, reusable transport packaging companies are unable to retrieve their packaging when it is stolen or lost.
Member States, reusable transport packaging companies are unable to retrieve their packaging when it is stolen or lost. In order to address these barriers to reuse, the EU legislation should clarify that those companies are the owners of this packaging and have all the related legal rights to retrieve and protect their assets. This will facilitate the uptake of reusable (transport) packaging and the internal market for reusable packaging. Public authorities also have a key role in stimulating reusable packaging through green public procurement, which should be made mandatory for certain purposes.
…stimulating reusable packaging through green public procurement, which should be made mandatory for certain purposes. 4) Recycled content targets As recognised in the European Plastics Strategy, the use of recycled plastics can reduce dependence on the extraction of fossil fuels and curb CO2 emissions, with the potential annual savings of 3.5 billion barrels of oil per year if all global plastic waste was recycled. In order to promote a well-functioning market for secondary raw materials and address potential market distortions linked to low price of oil / virgin plastics, binding recycled content targets are needed for specific plastic and other non-plastic packaging formats. Currently PET is the only plastic which is EFSA-approved and can be used in food contact materials. Further action is needed to speed up EFSA authorisations for plastic recycling processes for recycled plastic…
…for plastic recycling processes for recycled plastic other than PET to be able to be used in food contact applications. 5) Design for reuse and recycling 1 https://www.reloopplatform.org/reusable-vs-single-use-packaging-a-review-of-environmental-impacts/ 3 Design is a key element in improving the circularity of packaging. It is estimated that over 80% of all product-related environmental impacts are determined during the design phase. Design therefore has a significant potential for reducing the environmental impacts of packaging. This is why more mandatory action is needed to promote design for reuse and recycling, such as a requirement for packaging not to exceed a certain threshold ratios of packaging to product (in terms of volume, weight and surface area). Packaging should be designed not to exceed the minimum volume and weight necessary for its functionality.
…area). Packaging should be designed not to exceed the minimum volume and weight necessary for its functionality. In addition, design has an important role in facilitating end-of-life management of packaging. In order to improve collection, sorting and recycling, the EU should impose a requirement mandating the reduction in the use of polymers used in packaging and reduce the complexity of packaging materials by promoting mono-materials and mono-layers whenever possible. We also support the establishment of positive (green) and negative (red) lists, which would establish the packaging types and elements that are allowed on the EU market and those that are not permitted because they hinder the recycling process. There should also be a requirement for all reusable packaging to be recyclable.
…they hinder the recycling process. There should also be a requirement for all reusable packaging to be recyclable. 6) Labelling requirements Labelling requirements are very important as they allow consumers to make well-informed and sustainable purchasing decisions. Labelling requirements would increase transparency and better inform consumers on the sustainability of their purchasing choices. This is why the EU should require all packaging to be clearly labelled as reusable, recyclable, compostable or not-recyclable, based on the new definition of ‘recyclable’ which will be set. We see digital watermarking for labelling on packaging as a groundbreaking innovation which will significantly improve sorting and recycling. www.reloopplatform.org [email protected]