FERVER · Trade and business associations · BE
FERVER Fédération Européenne des Recycleurs de Verre European Federation of Glass Recyclers Boulevard Auguste Reyers 80 – 1030 Brussels [email protected] tel: +32 2 757 91 70 Direct tel. : +32 229 15 05 www.ferver.eu 1 FERVER POSITION ON THE PPWR 1. Introduction FERVER is the European Federation of Glass Recyclers. Our federation currently consists of 24 members spread across 13 EU- Member States and 3 other countries. They recycle around 70% of the packaging glass waste collected in Europe. The European glass recyclers welcome the publication of the proposal for a Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/2020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC as well as the Impact Assessment Report (accompanying the abovementioned proposal).
…and repealing Directive 94/62/EC as well as the Impact Assessment Report (accompanying the abovementioned proposal). 2. General Comments FERVER notes that in the text of the proposed Regulation, the EU Commission makes references to delegated acts, that would establish criteria. FERVER does not support this delegation of design to the European Commission through delegated acts. The proposed Regulation should contain the most important elements of the PPWR, including criteria in order to ensure legal certainty for the glass recyclers. What is recyclable is not always recycled. That’s why FERVER has already developed a recyclability guide. Producers such as users and bottlers are paying increased attention to the sustainability of their glass packaging. This recyclability guide describes the best practices in the glass recycling sector and based on this knowledge, helps glass producers…
…being collected via the used collection systems for household packaging put in place in each European Member State. 3. Specific FERVER comments. A. Article 5.2 and 5.5 – Requirements for substances in packaging As lead is strongly fixed in the glass matrix (in crystal glass) the existing rules as set in Decision 2001/171/EC and extended by decision 2006/340/EC are not limited in time. Ref. Ares(2023)2809998 - 20/04/2023 FERVER Fédération Européenne des Recycleurs de Verre European Federation of Glass Recyclers Boulevard Auguste Reyers 80 – 1030 Brussels [email protected] tel: +32 2 757 91 70 Direct tel. : +32 229 15 05 www.ferver.eu 2 FERVER supports the continuation of this unlimited validity. In case of need, to ensure the same level of approach between the different waste streams, FERVER asks for at least a long-term validity for such measure taken in accordance with article 5.5.(b).
…waste streams, FERVER asks for at least a long-term validity for such measure taken in accordance with article 5.5.(b). A transitional measure should also be foreseen under article 64 of the Regulation. B. Article 44.6 – Deposit return system for glass Many countries do already have effective national collection infrastructure especially, for glass recycling. For this reason, Member States should have maximum freedom to set up their own systems, taking into account the specific situation in the concerned Member State. C. Article 46.d – Recycling targets and promotion of recycling Many countries within the EU have already very high recycling rates for glass. FERVER therefore advocates an increase in the target for a minimum percentage of the recycling target to 80%.
…glass. FERVER therefore advocates an increase in the target for a minimum percentage of the recycling target to 80%. FERVER is also of the opinion that the Commission should consider the introduction of ambitious collection targets as an additional tool to ensure the recycling targets are met within its Member States. D. Article 47.9 - Rules on the calculation of the attainment of the recycling targets In article 47.9, which refers to the calculation of the attainment of the recycling targets, it is proposed that where packaging waste materials cease to be waste as a result of a preparatory operation before being actually reprocessed, they should be counted as recycled provided that they are destined for subsequent reprocessing into products, materials or substances, whether for their original or other purposes.
…for subsequent reprocessing into products, materials or substances, whether for their original or other purposes. By explaining that packaging waste materials cease to be waste as a result of a preparatory operation (End of Waste - EOW), but that at the same time this EOW (i) still has to be reprocessed and (ii) is destined for subsequent reprocessing into product, a “no man’s land” is created between waste and product. Either we speak about waste, or about a product. There is no in between. FERVER fully understands the objective of the Commission to avoid “shame recycling” by requiring the actual reintegration in the production process. However, glass producers are generally speaking not licensed for the treatment of waste, nor is their main activity to recycle, but to produce final products and devices. Additionally, there are situations where there is no subsequent reprocessing step.
…produce final products and devices. Additionally, there are situations where there is no subsequent reprocessing step. For instance, Furnace Ready Cullet might also be used in the process of filtration of drinking water or glass blasting. Based upon the proposed text, that would entail that they are not counted as recycled as there is no reprocessing step in such case. A cullet FERVER Fédération Européenne des Recycleurs de Verre European Federation of Glass Recyclers Boulevard Auguste Reyers 80 – 1030 Brussels [email protected] tel: +32 2 757 91 70 Direct tel. : +32 229 15 05 www.ferver.eu 3 that meets the given specification has to be a product independent and regardless of the subsequent use. Moreover, one could argue that based upon this proposed text, the Furnace Ready Cullet used in the process of filtration of drinking water is still a waste, as there is no reprocessing step.
Ready Cullet used in the process of filtration of drinking water is still a waste, as there is no reprocessing step. That would not make sense. Hence a clarification of the text is required, tackling this situation. We draw the attention to the fact that, in view of the above, there is also a need to revise the implementing decision 2019/1004 with respect to the calculation points. E. Article 64 – Repeal and transitional provisions As indicated in our comments under article 5.5. of the proposed Regulation, today Decision 2001/171/EC, as extended by decision 2006/340/EC provides a specific exemption for the presence of lead in recycled glass. This exemption should remain valid as long as no new Delegated Act has been issued by the Commission in accordance with article 5.5 of the proposed Regulation. Hence, article 64 would need to be amended in this regard.