FUNDACION OCEANA

Oceana’s submission to the public consultation on the revision of the EU’s Packaging and Packaging Waste Directive January 2021 Oceana welcomes the European Commission's initiative to revise the essential requirements of the Packaging and Packaging Waste Directive (PPWD). With 174 kg of packaging waste per inhabitant in the EU per year,1 there is an urgent need to reverse this growing trend and put in place measures to help Member States implement solutions that are in line with the EU waste hierarchy, prioritising waste prevention and reuse. Packaging is the largest end-user sector for plastics, accounting for a 39.6 percent share of plastic demand in the EU, well ahead of the construction and automotive industries.

…for a 39.6 percent share of plastic demand in the EU, well ahead of the construction and automotive industries. The packaging sector is also the biggest contributor to plastic waste: 17.8 million tonnes were collected for treatment in 2018.2 According to the most recent peer-reviewed scientific studies, an estimated 15 million tonnes of plastic are dumped into the world’s oceans every year.3 A significant share of these plastics are single-use food and beverage containers. 4 To curb marine plastic pollution, the root causes must first be addressed and the volume of plastics that are produced and discarded, particularly single-use packaging, must be limited. Recycling more plastics is necessary, but it is not a sustainable solution when the total amount of single-use plastic packaging continues to grow.

…but it is not a sustainable solution when the total amount of single-use plastic packaging continues to grow. Likewise, reducing single-use packaging of all materials is also needed to limit the pressure on natural resources and the carbon emissions associated with production, transport, disposal and recycling. The primary focus of the revision of the essential requirements of the PPWD should be to put a much higher priority on and systematically support waste prevention and reuse. Ensuring that single-use products made of one material are not replaced by single-use products made of another material is vital. This means building on Directive (EU) 2019/904 and going a further step in reducing single-use plastics by actively promoting re-use.

…on Directive (EU) 2019/904 and going a further step in reducing single-use plastics by actively promoting re-use. 1 Eurostat, 2018 https://ec.europa.eu/eurostat/statistics-explained/index.php/Packaging_waste_statistics 2 Plastics – the Facts 2020 https://www.plasticseurope.org/en/resources/publications/4312-plastics-facts-2020 3 Forrest A, Giacovazzi L, Dunlop S et.al Eliminating Plastic Pollution: How a Voluntary Contribution from Industry Will Drive the Circular Plastics Economy, Frontiers in Marine Science 6 (2019), 627. 4 E.g. as identified in the impact assessment of the EU Single-Use Plastics Directive (single- use_plastics_impact_assessment.pdf (europa.eu) and numerous other studies on beach and ocean litter. Ref.

(single- use_plastics_impact_assessment.pdf (europa.eu) and numerous other studies on beach and ocean litter. Ref. Ares(2021)139327 - 07/01/2021 Oceana’s recommendations for the review of the PPWD essential requirements: Set targets for reducing packaging waste and for reuse: • Set reduction targets for packaging waste from specific materials, including plastics. • Set reuse/refill targets for specific packaging categories, e.g., beverages, food, transport, e-commerce, etc. • Introduce minimum mandatory green public procurement (GPP) criteria and targets for the reuse of packaging in the public sector. Put in place measures to reduce packaging: • Implement bans on certain types of packaging, such as unnecessary/overpackaging (i.e., one portion-sized sachets, plastic wrapping for fruits and vegetables that have a natural peel, e-commerce “double” packaging, etc.).

…sachets, plastic wrapping for fruits and vegetables that have a natural peel, e-commerce “double” packaging, etc.). • Introduce fees on single-use packaging products, such as bottles, cups, etc. Set measures to support design for reuse: • Establish or improve mandatory container deposit systems for refilling/reusing packaging, e.g., for specific types of packaging. • Establish standardised packaging formats to facilitate reuse and refill solutions and logistics. • Ensure mandatory data collection and reporting on reused packaging and compliance with reuse/refill targets in Member States to increase transparency and accountability. Further background on our recommendations is given below.

…in Member States to increase transparency and accountability. Further background on our recommendations is given below. Reduction and prevention of waste Oceana agrees that the purpose of packaging is to protect products and ensure hygiene, and we believe that this should be done in a way that is as environmentally friendly as possible. The PPWD should address deviations from this core purpose, such as: • Unnecessary packaging. For example, fruits and vegetables that already have a natural protection, such as potatoes, oranges and onions sold in plastic mesh bags, or bananas and apples sold on a tray wrapped in plastic film. • Overpackaging. For example, products that want to give an impression of sophistication or premium quality, such as certain chocolates, biscuits, perfumes and jewellery. • Double packaging.

…of sophistication or premium quality, such as certain chocolates, biscuits, perfumes and jewellery. • Double packaging. For example, e-commerce adding a box and bubble wrap to a product that already leaves the factory inside a box with protective packaging inside. See more on Oceana’s findings and recommendations on e-commerce in Annex 1 below. • Single-use packaging. For example, disposable containers instead of gradually implementing refillable systems, such as in the case of beverages or cleaning products. See more on Oceana’s findings and recommendations on Deposit Return Schemes for refillables in Annex 2 below. Oceana supports overall packaging waste reduction targets, but consideration must be given as to how targets are set.

Oceana supports overall packaging waste reduction targets, but consideration must be given as to how targets are set. If measured solely in weight, this might create incentives to shift from heavier packaging (e.g., cardboard) to more lightweight packaging like plastic, which would not be environmentally beneficial. This trend has already been noted in e-commerce. Therefore, the focus should be on reducing unnecessary packaging and switching to reusable systems. To support packaging waste prevention, Oceana suggest that fees can be gradually imposed on certain packaging, like the fees now associated with plastic bags.

Oceana suggest that fees can be gradually imposed on certain packaging, like the fees now associated with plastic bags. These fees could apply to bottled products (such as beverages, gels and detergents) and food containers to support deposit return schemes, or on packaging for products that do not pose a hygiene risk or are required to protect the product after they have been purchased by consumers (such as clothes and shoes). Consumers should be able to identify the costs of the packaging of the product they are purchasing and be given the option of either avoiding said cost or opting for a refund. Likewise, we believe that green public procurement is essential and that governments should lead by example. Procurement should follow the EU waste hierarchy and prioritise prevention.

…that governments should lead by example. Procurement should follow the EU waste hierarchy and prioritise prevention. For example, tap water should be prioritised over refillable bottles, and refillable bottles should be prioritised over recyclable ones. Excessive and single-use packaging are among the most common plastics found in both shallow and deep waters, as these examples from Spanish Mediterranean: deep-sea crab at -400 m (© OCEANA , 2014), and diver with food packaging (© OCEANA / Enrique Talledo, 2020). Promoting reuse systems When their entire lifecycle is considered, the environmental impacts of reusable packaging are lower than those of single-use packaging.

…lifecycle is considered, the environmental impacts of reusable packaging are lower than those of single-use packaging. For example, a reusable plastic box produces 88% fewer carbon emissions than a single-use cardboard box, and a reusable glass bottle produces 85% less than a single-use one.5 However, this is only true if products are actually reused. With the implementation of the EU Single- Use Plastics Directive, companies are now labelling products as “reusable” to avoid market restrictions. A plastic spoon can be washed and used again several times, but this is not what the product is designed for nor what it will be used for. It is crucially important to prevent labelling from becoming a way to "greenwash" products.

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Addendum: Photographs of packaging considered too much / unnecessary E-commerce cardboard three bags claim sustainable 1 E-commerce cardboard three bags claim sustainable 2 E-commerce overpackaging / double packaging and plastic air pillows Multiple layers reusable claim Unnecessary packaging Ref. Ares(2021)139327 - 07/01/2021

originalus šaltinis (PDF) ↗