Recycling Europe

…23 July 2020 1 European Recycling Industries’ Confederation ● Europäischer Bund der Recyclingindustrien ● Confédération Européenne des Industries du Recyclage Transparency Register number : 764633015511-42 EuRIC comments on the Inception Impact Assessment on the review of the requirements for packaging and other measures to prevent packaging waste The European Recycling Industries’ Confederation (EuRIC) strongly welcomes the Inception Impact Assessment on the review of the requirements for packaging and other measures to prevent packaging waste and fully supports the initiative’s aim to tackle the limited competitiveness of secondary materials from recycled packaging relative to virgin feedstock. The review should also ensure to include measures to amend the essential requirements to improve design for reuse and promote high quality recycling, as well as additional measures to reduce…

…should be incorporated as essential requirements for packaging products placed on the market to improve their design: 1) Suitability for automated sorting: It is important to enable a simple separation of individual component parts during the sorting process as well as being compatible with automated material recognition. For example, the size of plastic sleeves and labels used on plastic bottles should be small enough to allow for proper NIR recognition of the bottle itself.

…and labels used on plastic bottles should be small enough to allow for proper NIR recognition of the bottle itself. 2) Suitability for high quality material recycling: To achieve high quality recycling, several steps need to be taken such as the fact that only minimal additives and colors should be used in the primary polymer item as well as having methods that enable good messaging to consumers, but also protect and provide a ‘careful stewardship’ of the core plastic material. For example, clear plastic yoghurt pots with strippable cardboard wrap-around. Additionally, packaging which are free of hazardous substances should be rewarded since it is instrumental that hazardous substances rendering recycling more difficult should be phased out at design stage.

…it is instrumental that hazardous substances rendering recycling more difficult should be phased out at design stage. 3) Cross-cutting criteria: A sufficient degree of harmonization across Member States is needed to ensure that pan-European branded items are ‘scored recyclable’ in a similar manner within the whole EU. Additionally, effective waste treatment operations which are coherent with the circular economy should be prioritized. 4) Recycled content: Pulling the demand for recycled plastics in packaging is instrumental to provide the certainty operators need to invest throughout the packaging value chain to increase its circularity. Additionally, it is important to reward the well-documented environmental benefits of packaging recycling.

…circularity. Additionally, it is important to reward the well-documented environmental benefits of packaging recycling. For example in terms of GHG and energy savings that the market fails to reward and which severely impact the economic viability of European recyclers when virgin material prices are low, as currently the case with virgin polymers due to the collapse of crude oil prices. More information can be found in our position paper on essential requirements for packaging. For further information, please contact [email protected] The European Recycling Industries’ Confederation - is the umbrella organisation for recycling industries.

European Recycling Industries’ Confederation - is the umbrella organisation for recycling industries. Through its Member Federations and Companies from 21 EU&EFTA countries, EuRIC represents across Europe over: § 5,500+ companies generating an aggregated annual turnover of about 95 billion €, including large companies and SMEs, involved in the recycling and trade of various resource streams; § 300,000 local jobs which cannot be outsourced to third EU countries; § Million tons of waste recycled per year (metals, paper, glass, plastics, WEEE, ELVs, tyres, textiles and beyond). By turning wastes into resources, recyclers play a key role in bridging resource efficiency, climate change policy and industrial transition. Recyclers play a key role in bridging resource efficiency, climate change policy and industrial transition. Ref. Ares(2020)3896301 - 23/07/2020

originalus šaltinis (PDF) ↗