European Beer Consumers Union

Reducing Packaging Waste – Review of Rules EBCU position paper on revised EU Rules for packaging and packaging waste This submission is in response to a proposal for a regulation of the European Council and the Parliament on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. About EBCU: The European Beer Consumers Union is a non-political and non-religious organisation representing beer consumers. We are comprised of 17 organisations from 15 countries and represent over 175,000 consumers. The European Beer Consumers’ Union represents the interests of beer consumers and their national representative organisations throughout Europe. Our aim is to encourage the development of a diverse beer sector producing a wide range of high-quality beers.

Europe. Our aim is to encourage the development of a diverse beer sector producing a wide range of high-quality beers. As the voice of the European beer consumer, EBCU seeks to promote high quality beer through dialogue with beer organisations, small and regional brewers, governments (and intergovernmental organisations), and to ensure that beer consumers are well informed and supported by instructive information about quality beers. We welcome to the opportunity to give feedback on the proposal as it affects beer consumers. Summary: EBCU welcomes the intentions of the Commission’s 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. Ref. Ares(2023)2862975 - 23/04/2023 Beer consumers want to see the industry play its part in reducing packaging waste.

Ref. Ares(2023)2862975 - 23/04/2023 Beer consumers want to see the industry play its part in reducing packaging waste. However, this must be fair, proportionate and workable for small and independent producers. Without careful implementation, the policy risks placing unfair and disproportionate burdens on smaller and independent producers with additional costs being passed onto the consumer. Extra costs and regularly burdens could prove too much for smaller brewing businesses which have been responsible for huge growth in the variety of distinctive beers available to consumers in recent years. EBCU does not want to see a reduction in the number of breweries and the range of beers from smaller and independent producers as a result of any of the policies in this proposal.

…and the range of beers from smaller and independent producers as a result of any of the policies in this proposal. Other challenges facing the industry and threatening consumer choice: It is important to think about the context of challenges facing the beer industry and consumers when considering extra regulation. The European Beer Consumers union and its member believe that it is important to be mindful that national consumer organisations report that the brewing sector continues to face tough conditions as a result of Covid, the war in Ukraine hitting supply chains, energy and business costs, and while consumers face a once in a generation rise in their costs of living.

…chains, energy and business costs, and while consumers face a once in a generation rise in their costs of living. We all wish to see a successful policy to reduce packaging waste, but this should not adversely affect consumers or the small and independent breweries that are the backbone to diversity of choice and beer styles across Europe. Consumers will have concerns if this policy leads to excessive additional costs or burdens on businesses, threatening their viability, and/or if those costs are passed onto consumers. EBCU believes that the responsible consumption of beer should remain affordable to all consumers. This will protect the wellbeing benefits of responsible consumption with others which helps to tackle loneliness and social isolation.

…the wellbeing benefits of responsible consumption with others which helps to tackle loneliness and social isolation. Impact on consumer choice: Decision makers must make sure that there are not unintended and negative consequents for consumers as a result of this policy. It would not be acceptable for the range of products available to be dramatically reduced by re-use and re-fill targets. Impact on price: There may be a negative impact on the price of beer if producers pass additional costs onto customers. EBCU believes that the deposit charged must not be excessive, and that the costs of administering the scheme should not be prohibitive for small and medium sized businesses who would be forced to pass costs onto consumers. Viability of small and independent producers: Packaging represents a much higher element of cost for smaller brewers than their larger rivals.

…independent producers: Packaging represents a much higher element of cost for smaller brewers than their larger rivals. The implementation of this policy must ensure that the costs and regulatory burden affordable and proportionate for small producers and importers – otherwise additional costs could put their viability at risk; and with it consumer choice. We would like consideration to be given to a phased introduction of the policy whereby large, multinational corporations launch the scheme with smaller brewers taking part at a later stage. We have concerns that proposals for re-fillable containers would require brewers to operate two different packaging lines for the same product. This would either lead to increases in costs for producers and therefore consumers; or would lead to many brewers being forced to reduce the number of products that they offer.

…and therefore consumers; or would lead to many brewers being forced to reduce the number of products that they offer. This would have devastating consequences for consumer choice. Those breweries with small production volumes are also unable to afford to run their own collection systems for refillable containers. EBCU would like to see an exemption for small and independent brewers from the targets for re-fillable containers considered. The proposals for charging deposits on containers treats all producers the same, regardless of size and the number of containers put on the market. However, the costs will be disproportionately felt by smaller businesses. We believe that in member states that do not already operate a scheme, the consequences for consumer behaviour and environmental impacts will not be fully understood until a deposit return scheme comes into effect.

…behaviour and environmental impacts will not be fully understood until a deposit return scheme comes into effect. A phased introduction of products – for example, levying deposits on products from large multinational producers first – will build consumer understanding, allow the administration and infrastructure to develop and give small and independent breweries more time to prepare for and take part in the scheme. A de-minimis threshold would protect these businesses while the scheme beds in. Fairness across all types of alcoholic beverages: EBCU wants to see fair treatment of the beer and brewing sector compared to other alcohol drinks. We do not believe that wine and spirits should be exempted and should be subject to the same targets on re-use and re-fillable packaging as beer.

…and spirits should be exempted and should be subject to the same targets on re-use and re-fillable packaging as beer. All packaging formats should be treated equitably by this policy regardless of the contents of the containers. Beer is already at a disadvantage under this scheme, as a deposit is charged on each individual container. This means a 6 pack of beer will attract 6 deposits, whereas a bottle of wine or spirits will only attract 1 deposit. The percentage price change on higher-ABV drinks as a result of this proposal is therefore smaller than the price changes on lower ABV drinks. This could have unintended consequences on consumer purchasing behaviour to the disadvantage of beer. Common symbols for recyclable packaging: EBCU supports the concept of common symbols to make it easier for consumers across member states to identify recyclable packaging.

…the concept of common symbols to make it easier for consumers across member states to identify recyclable packaging. However, some of our member organisations have concerns about how this would be implemented where existing successful deposit return schemes operate. Concerns have been raised that any policy in this area should assist consumers and not provide additional complications or potential confusion. Developing alternatives: The Commission, Council and Parliament should also consider the innovation in the beer and brewing sector of developing non-plastic alternatives for trade and transport packaging. Support should be offered to the industry to develop these alternatives. Contact us: For any further information please contact Paul Edgeworth, EBCU Secretary of [email protected] or André Brunnsberg, EBCU Chairman, on [email protected] .

originalus šaltinis (PDF) ↗