EDE · Trade and business associations · BE
…1 Energy Drinks Europe Rue de l’Association 50 B-1000 Brussels 24 April 2023 Submission of Energy Drinks Europe (EDE) on the proposal 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 (Packaging and Packaging Waste Regulation, PPWR) KEY SUMMARY • Energy Drinks Europe (EDE) is the leading representative trade association of European energy drinks producers. • The European Energy Drinks industry is a European success story, contributing billions of EUR in revenue since the invention of the category in Europe over 30 years ago. • Almost all energy drinks are sold in small format aluminium cans, between 250ml to 500ml.
Europe over 30 years ago. • Almost all energy drinks are sold in small format aluminium cans, between 250ml to 500ml. This is because energy drinks are intended as functional beverages for specific occasions (like coffee or tea) for consumption “on the go”. • Due to the damage high pressure washing would do to the lining of aluminium cans, small format reusable aluminium cans do not currently exist for the energy drinks industry. • Consequently, the European energy drinks sector is uniquely affected by mandatory reuse targets considered in the European Commission’s proposal for a Packaging and Packaging Waste Regulation.
…reuse targets considered in the European Commission’s proposal for a Packaging and Packaging Waste Regulation. • The proposed reuse obligations would lead to a perverse incentive to shift to larger PET or glass reusable containers with lower recyclability characteristic, and a significant negative economic impact on a native European industry that has become a global success story worldwide. • The PPWR could be amended to provide an exemption for small format “on the go” containers that meet mandatory circular criteria, supporting the environmental objectives of the proposal while protecting the complementarity of reuse and recycling as equal and self-reinforcing policy solutions. Similarly, Member States with existing or prospective high quality closed loop circularity schemes should be granted the ability to derogate from Article 26 of the proposed PPWR.
…quality closed loop circularity schemes should be granted the ability to derogate from Article 26 of the proposed PPWR. • Alternatively, a sectoral approach for the achievement of reuse targets should be favored, to protect the competitive dynamics of the beverages sector as a whole. EDE members are committed to improving the environmental footprint of their beverage packaging and supporting the objective of the European Green Deal. Thus, EDE fully supports the European Commission’s general ambition to improve circularity included in the proposal for a Packaging and Packaging Waste Regulation (“PPWR”). EDE strongly believes that a transition to a circular economy in Europe will not succeed with a one-fits-all approach to packaging and packaging waste. Instead, various levers based on a mix of complementary solutions is required.
…packaging and packaging waste. Instead, various levers based on a mix of complementary solutions is required. In line with public comments made from other sectoral bodies, we believe that recycling and reuse solutions must exist together to contribute collectively to the most effective approach to the management of packaging waste (and valuable recyclable material) enabled by the PPWR. As currently designed in the draft PPWR, mandatory reuse targets would risk this multi-solution approach and lead to detrimental environmental, economic, competitive, and social impacts, for the reasons explored below. Ref. Ares(2023)2883296 - 24/04/2023 2 Energy Drinks Europe Rue de l’Association 50 B-1000 Brussels FULLY RECYCLABLE SINGLE-USE PACKAGING SUPPORTS PACKAGING CIRCULARITY A.
Europe Rue de l’Association 50 B-1000 Brussels FULLY RECYCLABLE SINGLE-USE PACKAGING SUPPORTS PACKAGING CIRCULARITY A. Reuse is not environmentally beneficial under all circumstances and brings significant economic costs Reusable beverage packaging only makes sense under certain conditions and for certain packaging types. From an environmental perspective, reuse packaging does not always guarantee better environmental results than single use packaging.1 Many factors enter in the ecological assessment of recyclable and reusable packaging such as packaging weight, inclusion of recycled material, transport and distribution ways, consumption habits, or cleaning process. As for reusable packaging, the general advantage of this system is usually only beneficial when the consumption, distribution and washing/refill process take place in the very same limited regional area.
…when the consumption, distribution and washing/refill process take place in the very same limited regional area. EDE has concerns that the economic impact assessment of the European Commission has not fully taken these considerations into account. For example, a report by Price Waterhouse Coopers, commissioned by UNESDA, the European trade association for soft drinks producers, underlines that significant changes would be required compared to the present day with respect to: • Manufacturing processes; • Changes to the set up and operation of bottling lines; • Logistics and reverse logistics arrangements; • Additional lines and or production facilities.
…of bottling lines; • Logistics and reverse logistics arrangements; • Additional lines and or production facilities. Based on these elements, the report goes on to determine that:2 The shift towards more refillable packaging represents major investments and significant changes in the beverage packaging value chain, production, distribution, logistics and retail. In addition, the environmental impact of refillable beverage packaging, compared to its single-use circular alternative, may only prove to be positive in certain situations. The cost of this business model change to the soft drinks sector is estimated to be €18.7bn for a market share of 20% reusable PET bottles by 2030 at EU level: €12.5bn in estimated additional capital expenditure and €6.2bn in estimated additional operating expenditure.
EU level: €12.5bn in estimated additional capital expenditure and €6.2bn in estimated additional operating expenditure. EDE notes that the report was commissioned only with a 20% target for recycled PET as the focus of the study, and therefore does not consider the economic impacts of reuse on other packaging material types at higher rates. For the reasons above, EDE is concerned the impact on can packaging could be significantly higher. Moreover, the above-mentioned factors might vary significantly from one country to another, and from one product category to another. EDE is concerned that the current PPWR Impact Assessment might not reflect accurately the actual real impact in different Member States and on specific packaging formats.
…might not reflect accurately the actual real impact in different Member States and on specific packaging formats. More detailed data is needed at national level to ensure that reuse targets are only introduced where it makes sense from an environmental and economic perspective. 1 See https://www.carbontrust.com/our-work-and-impact/guides-reports-and-tools/carbon-footprint-of-soft-drinks-packaging 2 See UNESDA, https://www.unesda.eu/reusable-packaging/ 3 Energy Drinks Europe Rue de l’Association 50 B-1000 Brussels B. Fully circular single-use packaging is a key part of the energy drink sector’s packaging ambition, for both environmental and consumer safety reasons Energy Drinks are intended mainly for on on-the-go and single-use consumption, in certain occasions, and in small formats (250ml to 500ml).
…mainly for on on-the-go and single-use consumption, in certain occasions, and in small formats (250ml to 500ml). The reason for this choice of packaging for energy drinks, is because small format aluminum cans are: • Indefinitely recyclable with minimal quality loss; • Offer high circularity characteristics (96% recycling yields), when properly collected and sorted; • Are already highly collected and recycled, 76% of all aluminium beverage cans are recycled in Europe;3 • Are light weight in transportation as well as for carrying by consumers, allowing significant reductions in carbon footprint; • Are sanitary, as they provide a total barrier against light and oxygen, and unbreakable, impact resistant and puncture resistant, enabling their use as a safe packaging for the distribution of beverages.
…impact resistant and puncture resistant, enabling their use as a safe packaging for the distribution of beverages. EDE is concerned that a regulatory framework that mandates a transition into different formats will not make sense for all sectors, in all circumstances. Such a “one size fits all” approach undermines carefully considered environmental and product safety considerations. C. One size fits all reuse targets undermine the complementarity of reuse and recycling initiatives In several Member States, collection schemes for beverage containers have been operating successfully for many years. Closed-loop systems support the circular economy as they prevent valuable recyclable material ending up in the environment as litter, or in the general waste stream.
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