RELOOP

Packaging and Packaging Waste Regulation proposal Contribution to the public consultation - April 2023 Reloop welcomes the possibility to provide feedback on the recently proposed revision of the Packaging and Packaging Waste Directive. We commend the Commission's efforts and the level of ambition introduced in the new proposal, which will help reduce the ever-increasing amount of packaging waste and facilitate the development of a circular economy. We welcome the transition from a Directive to a Regulation, which will ensure harmonisation across the EU, a level playing field and safer investment environment stimulating Europe’s competitiveness. This proposal shows Europe’s leadership on packaging circularity, making the EU well placed to lead also the international negotiations on plastic pollution. At Reloop we strive to build a waste-free world, where resources remain resources and…

…addressed to further strengthen the proposal and ensure that the circular economy ambitions become a reality, namely: 1. Increased transparency: Need to ensure public access to Member States’ data on packaging and packaging waste We welcome the new targets set on reuse (Art. 62), recycled content, (Art. 7) and waste prevention (Art. 55). This means that there is a greater need for Member States to gather more data from more stakeholders and highlights the need for more transparency. This data should include information on how much packaging/material is placed on the market; how much is exported, collected for disposal, landfilled, incinerated and recycled. In addition, new reporting requirements are needed on reuse which includes system information, data, audited reports and data references.

…requirements are needed on reuse which includes system information, data, audited reports and data references. Therefore, to ensure transparency, the Regulation should include a provision providing public access to this Member States’ data by interested stakeholders. This is essential for strengthening accountability and trust in public institutions and improving the accuracy of the reported data by allowing public access and scrutiny. While the level of transparency should preserve confidentiality of commercially sensitive information, it should include at least data which makes up the individual variables for the methodologies for calculating the rates set in the new proposal. 1 Ref.

…which makes up the individual variables for the methodologies for calculating the rates set in the new proposal. 1 Ref. Ares(2023)2893470 - 25/04/2023 This will enable Member States to benefit from the ability to compare and cross-check their figures with other Member States and to be better equipped to identify any data gaps or nefarious activity within their borders. This will allow public entities and NGOs to better monitor and identify countries with weaknesses in waste reduction and offer expertise and recommendations for improvement. 2. Need for Deposit-Return Schemes and other measures for Glass Packaging While the Commission proposal is ambitious overall, it lacks measures to improve the circularity of glass packaging. Namely, glass packaging is excluded from provisions setting deposit-return systems (DRS) in Article 44 and collection rates, as well as from other measures.

…provisions setting deposit-return systems (DRS) in Article 44 and collection rates, as well as from other measures. If the collection target for glass bottles were increased to 90% by 2029 through deposit-return systems, in line with plastics and beverage cans, this would result in a higher glass packaging recycling rate and reduced litter and glass disposal. According to a recent ZWE / Eunomia report, deposit return systems with single-use glass in their scope can improve the overall glass collection rates for this material if implemented across Europe. Given that glass is a highly energy intensive material, a 90% collection rate for glass bottles, in combination with a clean cullet procedure i.e.

…energy intensive material, a 90% collection rate for glass bottles, in combination with a clean cullet procedure i.e. cullet that has been thoroughly cleaned and free of contaminants such as paper, plastic, or metal, and is ready to be re-melted and used in the production of new glass products, can lead to significant energy savings, as it requires less energy to melt cullet than it does to melt raw materials from scratch. It can also help reduce the amount of waste generated by the glass industry, as cullet is made from recycled glass that would otherwise be discarded. Besides lowering greenhouse gas emissions, cullets also have a positive impact on air pollutants. The production of new glass releases air pollutants into the atmosphere, like nitrogen oxides (NOx), which is a major contributor to air pollution with harmful effects on human health and the environment.

…oxides (NOx), which is a major contributor to air pollution with harmful effects on human health and the environment. Glass recycling, on the other hand, involves the melting of glass and the shaping of it into new products, which does not produce NOx emissions. In addition, recycled content targets for glass packaging should also be considered as the current uptake of recycled content in glass containers produced in Europe is rather low (52% for unspecified colour, 80% for green glass, 50% for brown glass, 40% for flint glass), according to European Container Glass Federation (FEVE) last Life Cycle Assessment study.

…glass, 40% for flint glass), according to European Container Glass Federation (FEVE) last Life Cycle Assessment study. At the same time, FEVE and the European Federation of Glass Recyclers (FERVER) highlighted in their recent position paper on recycled content that glass bottles can be produced with up to 100% recycled glass and can be endlessly recycled into new glass packaging applications without lowering the quality of glass. Therefore to mitigate the environmental impact, decrease air pollution and make use of the full potential of glass as a product, glass beverage packaging should be included under the DRS obligation with a 90% separate collection target, in parallel with recycled content targets for glass packaging (minimum 50% in 2 each Member States, or 75% in the EU as a whole as derogation).

…content targets for glass packaging (minimum 50% in 2 each Member States, or 75% in the EU as a whole as derogation). Certain exemptions from DRS for glass bottles could be allowed if they achieve a 90% separate collection for recycling target and a high recycled content rate.

…could be allowed if they achieve a 90% separate collection for recycling target and a high recycled content rate. 3. Support for ambitious reuse targets Reloop supports the ambitious reuse targets introduced in the Commission Proposal. It has been shown that Reusable Packaging systems can offer significant environmental gains over the alternative single-use packaging when operating within a series or efficiency parameters, as recognised also in the Commission’s impact assessment. The EEB also concluded that a reusable packaging target of 50% by 2030 could lead to the reduction of 3.7 million tonnes of CO2, 10 billion cubic metres of water and nearly 28 million tonnes of material. However, we are concerned that, as the proposal is debated by the EU co-legislators over the next year, policymakers will be confronted with many diverging life cycle assessments in favour of single-use over…

…set, including on high collection and recycled content, for the derogation to be allowed.

…meet certain targets to be set, including on high collection and recycled content, for the derogation to be allowed. 4. Design for Recycling criteria to include negative list of packaging characteristics We regret the omission of a negative list of packaging characteristics, which was included in Part D of Annex to a previous leaked draft of the proposal. In addition, we believe that the Design for Recycling criteria should include the fundamental requirements for ‘at scale’, with the following definitions: (a) Packaging is collected, sorted and recycled ‘at scale’ when packaging waste can be collected, sorted and recycled in Member States representing equal or more than 75% of the EU population (b) ‘Packaging is collected ‘at scale’ where the entire population of the Member State other than inhabitants of sparsely populated areas, mountainous areas and islands has access and the…

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