Syctom · Other organisations, public or mixed entities · FR
…1 REVISION OF THE PACKAGING WASTE DIRECTIVE SYCTOM POSITION PAPER March 2023 Syctom is a French local public authority and a public service. It is the leading European public operator in municipal waste management. With its 6 sorting centres and 3 Waste-to-energy units, Syctom processes 2.3 million tonnes of municipal waste (namely 10% of French municipal waste) from six million inhabitants of the Île-de-France region, including Paris. Contact person: Caroline Chal Institutional Affairs Manager [email protected] Ref. Ares(2023)2711349 - 17/04/2023 2 Syctom welcomes the adoption by the European Commission of an ambitious Packaging and Packaging Waste Regulation (PPWR). Packaging waste have been steadily increasing over the years1. It is about time to enhance the waste hierarchy and implement measures promoting prevention, reuse and recycling. I.
It is about time to enhance the waste hierarchy and implement measures promoting prevention, reuse and recycling. I. CLARIFYING THE PRACTICAL IMPLICATIONS OF RECYCLABILITY REQUIREMENTS As a public authority in charge of managing municipal waste, Syctom has been a strong proponent of setting recyclability requirements. Indeed, packaging waste can only become a resource through recycling under two conditions: - If the packaging has been appropriately eco-designed. - If there is a market demand for secondary raw materials . Therefore, Syctom strongly supports the introduction of recyclability requirements proposed by the Commission in Article 6, in particular design for recycling criteria and recycling performance grades. To be effectively enforced, the practical implications of these requirements must be anticipated.
…grades. To be effectively enforced, the practical implications of these requirements must be anticipated. As such, Syctom believes several provisions from Article 6 need further clarification. a) Packaging bans Article 6.1 reads as follows : “All packaging shall be recyclable”. Yet, it is not clear whether packaging that would not comply with requirement underlined in Article 6.2 and with a performance grade E (Article 6.5 ) would be banned from entering the single market as of the respective deadlines. Syctom calls on the co-legislators to explicitly ban packaging that will not comply with recyclability requirements.
Syctom calls on the co-legislators to explicitly ban packaging that will not comply with recyclability requirements. b) Redundancy of points a) and d) in article 6.2 Point a) refers to packaging being recyclable if “it is designed for recycling” while point d) says “it can be recycled so that the resulting secondary raw materials are of sufficient quality to substitute the primary raw materials”. 1 Eurostat - Packaging waste statistics, October 2022 3 From an industrial perspective, a packaging designed for recycling is de facto a packaging that will provide secondary raw materials of sufficient quality. To Syctom, points a) and d) seem therefore redundant. Syctom calls on the co-legislators to clarify these provisions. Merging points a) and d) would be a solution.
Syctom calls on the co-legislators to clarify these provisions. Merging points a) and d) would be a solution. c) Potential adverse effects of point c) in article 6.2 Point c) states that a packaging is recyclable if “it is sorted into defined waste streams without affecting the recyclability of other waste streams”. Measuring the impact of one waste stream on others It is unclear how the Commission would assess the impact of one packaging onto the recyclability of other waste streams? What would be the decisive factor leading one waste stream to be separated from others because of its negative impacts ? Syctom calls on the co-legislators to request clarification about this issue to the Commission. Potential impact on national waste collection systems Syctom also considers that this provision might allow the EU to standardize national waste collection systems by specific waste streams.
…that this provision might allow the EU to standardize national waste collection systems by specific waste streams. - For example, in France, cardboards are sorted jointly with other waste packaging (plastics; paper; cans; etc.). This is different in Nordic Member States where carboard are sorted separately because their rules differ on the expected carboard purity rate. Syctom recalls that commingled collection (collecting different waste streams together) is allowed by the Waste Framework Directive (Article 10). Syctom calls on the co-legislators to request clarification about this issue to the Commission. 4 II. ALLOWING MEMBER STATES TO OPT-OUT FROM DEPOSIT RETURN SCHEMES The European Commission presents deposit return schemes (DRS) as a one-size-fits-all solution to increase the collection rates for single-use plastic beverage bottles and metal beverage containers.
…to increase the collection rates for single-use plastic beverage bottles and metal beverage containers. While it is true that Member States with DRS achieve high separate collection rates for single- use beverage packaging, it is also true that high collection rates can be achieved on selected streams without DRS (such as metal cans in France or PET in Belgium2). Moreover, DRS seems to have little effect on strengthening the waste hierarchy : - On recycling : according to the Joint Research Center, data3 suggest that a DRS would only increase overall municipal solid waste recycling rates by 0.34%, and the overall packaging recycling target would increase by about 0.7%. - On reuse : according to the German Federal Environment Agency, for beverage packaging subject to a deposit return scheme, the share of reusable packaging has been steadily decreasing, from 70,4% in 2000 to 41.8% in 2019.
…return scheme, the share of reusable packaging has been steadily decreasing, from 70,4% in 2000 to 41.8% in 2019. - On waste prevention : over the last two decades, singly-use beverage plastic packaging has increased from 29.6% to 58.2% in Germany to reach a total of 18.9 billion single-use plastic bottles consumed. Syctom is convinced that Member States should be given the possibility to choose the most efficient collection systems according to their local specificities. Syctom would therefore like to propose the following amendments : - Incentivize rather than oblige Member States to implement DRS (Article 43.1). - Strengthen the provisions related to possible exemptions (Article 44.3 points a and b): • Making points a) and b) exclusive and not cumulative • Going from a 90% to a 80% target while aligning the deadline related to this objective with the implementation date for DRS.
…from a 90% to a 80% target while aligning the deadline related to this objective with the implementation date for DRS. A DRS could be considered as an option mandated by the Commission only if a Member State consecutively fails to reach a given collection target after 2029. Please find in the annex below Syctom’s amendments on DRS along with their justifications. 2 Unesda - PET collection rates across Europe, 2021 3 JRC Study on Separate Collection of municipal waste is focussed on Ireland when it comes to DRS 5 ANNEX I : SYCTOM’S AMENDMENTS AND JUSTIFICATIONS – PROVISIONS RELATED TO DRS IMPLEMENTATION AND EXEMPTIONS Commission’s proposal – Article 44 Amendments – Article 44
– PROVISIONS RELATED TO DRS IMPLEMENTATION AND EXEMPTIONS Commission’s proposal – Article 44 Amendments – Article 44 1. By 1 January 2029, Member States shall take the necessary measures to ensure that deposit and return systems are set up for: (a) single use plastic beverage bottles with the capacity of up to three litres; and (b) (b)single use metal beverage containers with a capacity of up to three litres. 2. The obligation laid down in paragraph 1 does not apply to packaging for: (a) wine, aromatised wine products, and spirit drinks; (b) milk and milk products listed in Part XVI of Annex I to Regulation (EU) No 1308/2013
…products, and spirit drinks; (b) milk and milk products listed in Part XVI of Annex I to Regulation (EU) No 1308/2013 3. Without prejudice to paragraph 1 of this Article, a Member State will be exempted from the obligation under paragraph 1 under the following conditions: (a) the rate of separate collection as required under Article 43(3) and (4) of the respective packaging format as reported to the Commission under Article 50(1) point (c) is above 90% by weight of such packaging placed on the market on the territory of that Member State in the calendar years 2026 and 2027. Where such reporting has not yet been submitted to the Commission, the Member State shall provide a reasoned justification, based on validated national data, and description of the implemented measures, that the conditions for the exemption set out in this paragraph are fulfilled. (b) at the latest 24 months before…
…that ensure the achievement of the 90% separate collection rate by weight of the packaging referred to in paragraph 1. 4. Within three months of receipt of the implementation plan submitted pursuant to paragraph 3, point (b), the Commission may request a Member State to revise that plan, if it considers that it does not comply with the requirements set out in point (c) of that paragraph. The Member State concerned shall 1. By 1 January 2029, Member States may take the necessary measures to ensure that deposit and return systems are set up for: (a) single use plastic beverage bottles with the capacity of up to three litres; and (b) single use metal beverage containers with a capacity of up to three litres.
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