Interesų grupė
…1 To: European Commission Public consultation website Reducing packaging waste – review of rules 27th March 2023 Re: The European Commission's proposal for a regulation on packaging and packaging waste. In November 2022, the European Commission presented its proposal for a new regulation on packaging and packaging waste. The proposal must now be negotiated between the EU member states and the European Parliament. In the Nordic region, we have a long experience with these issues concerning beverages: In all the Nordic countries we have deposit and return systems with collection and recycling rates at such high levels that one can still only dream of internationally. We fully support the Commission's aim that all packaging should be recycled rather than end up as waste, but based on our experience we must express our deepest concerns about the Commission's proposal.
…than end up as waste, but based on our experience we must express our deepest concerns about the Commission's proposal. Our breweries and bottling plants already lift their producer responsibility for their bottles and cans by collecting and recycling them via the Nordic deposit systems. In addition, we are determined to ensure that our bottles and cans are recycled in a "closed loop", so that collected bottles and cans are used to produce new bottles and cans for beverages, so that we avoid "down-cycling" of the materials. Deposit and return systems in all EU Member States It is very positive that the Commission is proposing that all EU Member States must set up deposit and return systems for certain beverage packaging, as we already have in the Nordic countries.
…must set up deposit and return systems for certain beverage packaging, as we already have in the Nordic countries. According to the Commission's proposal, a Member State is exempted from this obligation if it already has a separate collection above 90% for such packaging. The reasoning for this exemption may be that the added environmental benefit from changing from one collection system to a deposit based collection system may not be justified by the costs of such change. Ref. Ares(2023)2200021 - 27/03/2023 2 With the same reasoning, the already established and well-functioning deposit and return systems, such as those we have in the Nordic countries and which collect 90% or more, should be exempted from the proposed minimum requirements. In the same way, recycling at a high level (+90%) in "Closed loop" should be exempted from the proposed reuse targets.
In the same way, recycling at a high level (+90%) in "Closed loop" should be exempted from the proposed reuse targets. The Commission must present independent analyzes which document the benefit of reuse compared to high-level recycling, and which document that the environmental benefit is proportionate to the cost of switching. The Nordic deposit and return systems work well. The consumers have a high level of trust in them, they are efficient both environmentally and economically, and they are in fact the only collection systems that can supply the market with "post-consumer" recyclable material of such a high quality that the collected material can be used again to produce new food contact packaging.
…material of such a high quality that the collected material can be used again to produce new food contact packaging. Protect the national deposit labels The Commission also proposes that the national deposit labels, which the consumers already know very well, must be replaced with an EU harmonized deposit label. Over many years, we have invested significantly in achieving a high level of awareness among consumers of the existing national deposit labels, and we are now harvesting the benefits in the form of very high return rates. We risk considerable draw backs if the existing national deposit labels are replaced with a new and unknown EU deposit label. The Commission has not presented any documentation that the return rate will increase by replacing the existing and well-known deposit labels with a harmonized EU deposit label.
…return rate will increase by replacing the existing and well-known deposit labels with a harmonized EU deposit label. Right of first refusal to the collected material Furthermore, in order to ensure recycling at high level, we recommend that producers and importers, who must collect their packaging via a mandatory deposit and return system, and who supply the market and the deposit systems with high-quality recyclable materials, can get their recyclable materials back so they can use the collected material again to produce new bottles and cans and thus ensure closed loop recycling. It will be necessary if they also must meet the Commission's proposal for increasing recycled content in their packaging. Bottles and cans with a deposit must not end in waste We support the Commission's proposal to introduce a harmonized "waste pictogram" on packaging.
…must not end in waste We support the Commission's proposal to introduce a harmonized "waste pictogram" on packaging. A waste pictogram on the packaging will help consumer to sort their used packaging into the correct waste container, and therefore the same label must also appear on the relevant waste container. 3 However, bottles and cans with a deposit label must not be disposed of in household waste. Instead, they must be returned in the vending machine so the consumer can get back the deposit amount, and the can and the bottle can be collected and recycled via the deposit system. On bottles and cans with deposit, the deposit label is the only relevant "sorting instruction" and not a waste pictogram. The consumer will lose the deposit amount if the bottle or can ends up in waste, and the result will be a reduced return rate.
…will lose the deposit amount if the bottle or can ends up in waste, and the result will be a reduced return rate. For this reason, bottles and cans with a deposit should not have both a waste pictogram and a deposit label on them, as the Commission is proposing. We also recommend that it should be voluntary to use the proposed label on the packaging's "reusability". Reuse quota Today, consumers can choose to buy their beers and soft drinks in different types of packaging with the certainty that the used packaging will be collected and recycled, regardless of whether it is a can, a plastic bottle, a disposable glass bottle or a refillable bottle. The freedom of packaging choice also means that a brewery can choose to only sell its beers in, for example, cans and opt out of other types of packaging.
…that a brewery can choose to only sell its beers in, for example, cans and opt out of other types of packaging. It is, among other things, due to the freedom of packaging choice and the deposit systems that we have experienced a veritable explosion in the number of new microbreweries over the last 10 – 15 years. Consumers have never had such a large and wide range of exciting new beers, soft drinks and water and in a great variety of packaging formats to choose from. It is characteristic that all microbreweries have chosen to produce and sell their beer only in single use packaging, which is collected and recycled via the single deposit systems, rather than choosing refillable bottles, which they must collect and refill and eventually recycle themselves. The same is true for small bottling plants that produce soft drinks, cider, bottled water and juice.
…themselves. The same is true for small bottling plants that produce soft drinks, cider, bottled water and juice. The reason is that the production volume of small producers cannot possibly match the required and large investments needed to set up and run their own collection systems. Therefore, the Commission's proposal that all producers must sell a certain proportion of their beer and/or soft drinks in refillable bottles will at once eliminate the economic basis for the existence of most microbreweries and small bottlers. A suggestion that micro companies can be exempted until they reach a certain size is seen as another barrier for growth. The proposal will also erode the deposit systems' investments in increased recycling.
…as another barrier for growth. The proposal will also erode the deposit systems' investments in increased recycling. For deposit systems, which already have high collection rates, and which recycle all the collected material, a mandatory reuse quota will require a very large restructuring throughout the supply chain from production, distribution and sales, and such a restructuring will also be a challenge for the recycling industry that is already short of recyclable “food grade” material. It is very surprising that the Commission proposes to introduce reuse quotas for packaging for beer and soft drinks, when we already lift our producer responsibility for the bottles and cans and collect 4 them through the deposit systems, and that the Commission at the same time proposes significantly lower reuse targets for wine and completely exempts spirits.
…the Commission at the same time proposes significantly lower reuse targets for wine and completely exempts spirits. We are happy to engage in a dialogue on how to increase reuse, but increased reuse must make sense both environmentally, technically and economically. Reuse targets must be long-term and realistic, and the industry must be able to meet such targets through partnerships and voluntary measures and for the category as such, and of course the targets must ensure a level playing field and not discriminate between competing product categories. As the proposal looks now, it will impose very large conversion costs on the Nordic deposit systems and, in addition, will weaken our high return and collection rates, without it being likely that this conversion will have any positive environmental effect – perhaps even the opposite.
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