BGVZ · Trade and business associations · DE
…represented by:Dr Martin GerigManaging Director BGVZUnter den Linden 1010117 BerlinT. +49 30 700 140 420 M. [email protected] Web. www.bgvz.de Web . www.einweg - mit - pfand.de Bund Getränkeverpackungen der Zukunft GbR (BGVZ) Written opinion on the proposal of the European Commission for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC 0 6 .04 .2023 Ref.
…amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC 0 6 .04 .2023 Ref. Ares(2023)2496435 - 06/04/2023 Written opinionon the proposal of the European Commission for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC Summary • Deposit systems for beverage packaging (DRS) make a valuabl e contribution to the prevention of littering, sorted collection and high return and recycling rates. The systems already established or being set up in numerous Member States are a central component of a functioning high - quality circular economy . • A genera l ecological advantage of reusable beverage containers compared to single -use beverage containers within a DRS is not proven by life cycle assessments.
…beverage containers compared to single -use beverage containers within a DRS is not proven by life cycle assessments. Instead, the ecological profile of beverage packaging depends on a variety of factors. As the evaluation of the ecological impact of beverage packaging depends on a case - by -case approach, reuse quotas need to be avoided. • To improve the ecological footprint of beverage packaging and to actually reduce negative effects of this packaging on people and the envi ronment, legislators should rather focus on concepts that promote the ecological optimization of beverage packaging across systems. • The economic and ecological strength of the European beverage industry lies in the coexistence of reuse and single - use DRS. Future regulation should build on existing successful structures in various Member States.
…reuse and single - use DRS. Future regulation should build on existing successful structures in various Member States. Standards achieved should not be jeopardized by disruptive interventions. Bund Getränkeverpackungen der Zukunft (BGVZ) is an association of beverage producers, retailers , packaging and recycling companies that advocates for the consumer - and e co - friendly use of single - use beverage packaging with in a DRS . The majority of BGVZ's shareholders are operating on the marke t in Germany as well as in other European member states and are therefore significantly affected by the regulatory framework for (beverage) packaging at the European level.
…and are therefore significantly affected by the regulatory framework for (beverage) packaging at the European level. Therefore, we would like to comment as follows on the draft proposal of the EU Comm ission for a revision of DIRECTIVE 94/62/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 20 December 1994 on packaging and packaging waste, published on 30 November 2022: BGVZ and its members welcome the objective of the Circular Economy Action Plan that all packaging within the European Union should be either reusable or recyclable by 2030, taking into account the economic feasibility. Some regulations of the draft contribute to this, such as the mandatory introduction of DRS for single - use plastic beverage bottles and beverage cans from 202 9.
…this, such as the mandatory introduction of DRS for single - use plastic beverage bottles and beverage cans from 202 9. We consider this regulation to be an important step towards closing material cycles and therewith towards the improvement of the circular economy. However, there is a need for substantial improvements to the draft. In particular, the introduction of mandatory reus e quotas for beverage producers and final distributors of beverage s for 2030 and 2040 (see Article 26 , paragraphs 4 & 6 ) is neither reasonable from an environmental and climate policy perspective nor economically feasible for the affected companies. In detail: Article 7 - Minimum recycl ed content for plastic packaging • Minimum input quotas for recycled content in the plastic part of packaging can be a suitable instrument for ensuring the demand for high -quality secondary material in the long term.
…packaging can be a suitable instrument for ensuring the demand for high -quality secondary material in the long term. • However, the quota should not be measured per packaging unit, but on the basis of the total q uantity of single -use plastic beverage bottles with deposit placed on the market by a manufacturer. In principle, minimum recycl ed content quotas can be a suitable instrument for ensuring the demand for and the use of high -quality secondary material in the long term . Additionally, it provides companies in the packaging and recycling industry with a security of investment . The use of recycled material is an essential factor for the positive environmental profile of single - use beverage bottle s and cans with deposit . For this reason, there are already far - reaching voluntary commitments by manufacturers , retailers, and bottlers.
For this reason, there are already far - reaching voluntary commitments by manufacturers , retailers, and bottlers. Against this back ground, the BGVZ welcomes the minimum recycling rates of 25 percent from 2025 and 30 percent from 2030 for single -use plastic bottles laid down in the EU Single -Use Plastics Directive. However, instead of specify ing the recyclate content per packaging un it , the reference point should be the total quantity of single - use plastic beverage bottles placed on the market by a manufacturer. This would significantly simplify the collection and communication of the relevant data . Article 26 – Reuse targets • The introduction of reus e quotas is not suitable for achieving the ambitious climate and environmental goals of the European Union.
…of reus e quotas is not suitable for achieving the ambitious climate and environmental goals of the European Union. ISO -compliant life cycle assessment sin Germany show that it is not possible to prove a general ecological advantag e of reusable beverage containers compared to single -use beverage containers with in a DRS . 1 The reason for this is that multiple factors influence the ecological profile of a beverage container. • Instead of reuse quotas, the EU Commission should develop strategies to optimize beverage packaging , to in crease collection, return and recycling quotas and to close material loops . For a n ecological beverage marke t, a mix of already established packaging systems and material fractions is key . Reuse and recycling should be understood as complementary instead o f opposing systems.
…and material fractions is key . Reuse and recycling should be understood as complementary instead o f opposing systems. Reus e quotas do not necessarily lead to the best ecological result The ecological assessment of a beverage package depends on several factors. These include, in particular, the respective consumption scenario of the consumer as well as the packaging weight, the use of secondary material, distribution and, in the case of reusable containers, also the number of rotations and cleaning processes . Various ISO -compliant life cycle ass essments in Germany show that environmental assessments based on the parameters of “single - use” and “ reus e” are not scientifically justifiable.
…environmental assessments based on the parameters of “single - use” and “ reus e” are not scientifically justifiable. A general ecological advantage of a reu se system over other types of packaging and in particular other deposit s ystems for single -use beverage packaging has not been proven by life cycle assessment s . Many EU Member States have been successfully using DRS for single -use beverage containers for years -partly in the form of an overarching deposit system for single - use and reuse (e.g. Denmark), partly as a supplement to existing reusable deposit systems (e.g. Germany). Closed -loop systems, such as those crea ted by a deposit on single -use beverage containers, lead to a strong, measurable improvement in the circular economy .
…by a deposit on single -use beverage containers, lead to a strong, measurable improvement in the circular economy . They almost completely prevent the entry of beverage containers into the environment (littering) and strongly contribute to achieving the EU collection and recycling targets for PET bottles and cans , by ensuring an increased availability of high -quality and climate -friendly secondary material. Furthermore, a DRS for single - use beverage packaging ensures the economic equality of single - use an d reusable ( as consumers pay a deposit for both packaging systems), which can have a fundamentally positive effect on the reusable category.
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