The UK Advisory Committee on Packaging (ACP) has submitted proposals to the European Commission on what it would like to see in its circular economy package 2.0, including urging that targets implemented need to reflect resource efficiency in design.
The ACP says it strongly supports the concept of a circular economy and supports the review that the Commission is conducting. It has raised points raised, which it hopes will be taken into consideration in the formulation of the new package.
The Advisory Committee on Packaging is made up of members from a range of industry sectors, who have been appointed by the Government to advise on issues relating to packaging and the UK Packaging Regulations.
ACP – “Targets are not necessary to stimulate ‘prevention’ or ‘reuse’ of packaging – commercial and sustainability drivers are strong enough and are assessed in relation to the nature of the product”
The paper was formulated by a sub-group of the Committee that includes additional members from Trade Associations (see below for members).
The European Commission President, Jean-Claude Juncker confirmed the original waste proposals set out by former Environment Commissioner Janez Potocnik would be axed at the end of last year, claiming that they won’t deliver the results needed in their current form. (See CIWM Journal Online story)
The original circular economy package included a 70% recycling target for municipal waste by 2030, 80% recycling for packaging, such as glass, paper, metal and plastic by 2030, and a ban on landfilling of all recyclable and biodegradable waste by 2025.
This was dropped at the end of last year, to be replaced with a more “ambitious proposal” by the end of 2015, according to the Commission.
Points For Consideration
- Whilst the concept of a circular – rather than linear – economy is understood, there needs to be a clear, realistic and meaningful definition and achievable objectives of a Circular Economy provided by the Commission that recognises that Resource Efficiency is an essential element.
- Packaging recyclability has at times been prioritised at the expense of fitness for purpose. An example is described in Appendix 1 and we ask that the Commission recognises the vital role that packaging plays in prolonging product life, in particular food, by ensuring that targets are not proposed that compromise the effectiveness of packaging in its primary role or the design of packaging for resource efficiency.
- Targets need to reflect resource efficiency in design, production and during product and packaging lifetimes. They should also relate to the value of the recovery of embedded resources at the end of life; both materials and energy. Pure recycling targets based on recycling for recycling’s sake that are not based on scientific assessment of the whole product lifecycle can have unintended consequences and potentially create a net environment dis-benefit. Increased recycling rates will result in greater demands for sorting and washing with associated energy and water / water treatment demands. An impact study is required to assess an eco-efficient level of recycling, after establishing a standard methodology for measuring recycling rates. Only then should a recycling target can be set at EU level after a level playing field has been established between Member States.
- Targets are not necessary to stimulate ‘prevention’ or ‘reuse’ of packaging – commercial and sustainability drivers are strong enough and are assessed in relation to the nature of the product. Retailers will only consider the use of more complex – and generally more expensive packaging solutions – that may be more difficult to recycle when the additional costs justify the resource saving, e.g. keeping food fresher for longer.
- The Commission needs to lay down resource efficiency objectives and apply criteria to harmonise methodology across MS before proposing new targets. Recovery (recycling and energy recovery) targets should be set at a level that delivers a net gain in resource efficiency of all resources, not just materials, and across the whole lifetime of a product or packaged product. Before changing the current targets, the questions posed by DG ENV Director General Karl Falkenberg need to be answered, “Beyond what level of recycling is it not environmentally and financially interesting to recycle? Should energy recovery be favoured over recycling when dealing with low quality material streams?” This is likely to vary considerably depending on local conditions, for example energy supply, geography, population density, proximity of end markets, etc. These should be considered in the new Impact Assessment to determine net environmental benefit.
- The method of calculating recycling rates needs to be harmonised. This requires standardisation in the point at which recycling is calculated and the methodology for calculating the total amount of packaging placed on the market.
- A clear message is required from the Commission on whether the objectives for the new Package prioritise recycling infrastructure and jobs within the EU or whether export outside the EU is supported. The UK packaging industry believe that one of the key benefits of a Circular Economy should be the development of jobs and infrastructure within the Union. As the graph in Appendix 1 shows, at present, the UK ships nearly half of its packaging waste overseas, most of which moves beyond the EU. This is understood to be reflected across other Member States. Without clear direction and support, this trend will continue.
- EPR must not apply unreasonable cost burdens on producers from end user behaviour over which they have no control. eg total cost of litter management, collection from households. Responsibility for packaging should be shared between all stakeholders, for example manufactures and retailers (ensure packaging is fit for purpose and capable of being recovered after use), consumers (use and make it available for recycling/dispose of it responsibly) and municipalities (for public health and environmental reasons, treat used packaging responsibly).
- Common principles for EPR should be mandated by the Commission but should not be too specific and detailed and application should be determined by MS.
- The definition of waste laid down in the WFD does not reflect the needs of the waste hierarchy and Circular Economy. In particular, the lack of definition of ‘discard’ in these days of ebay and other post-first user disposal processes leads to constraints on use of end of first life products and process waste that inhibits use as a raw material. A revised definition is required that reflects waste as a resource and raw material but maintains proportionate protection of human health and environment.
- Much of current waste regulation relates to pre-waste hierarchy and often applies disproportionate controls in relation to environmental risk. Waste regulation should be reviewed to identify and minimise or remove barriers to use as resource e.g. Environmental Permitting, Trans-frontier Shipment etc.
- Clearer more consistent guidelines on the application of end-of-waste are also required which should be driven by safety, quality and performance requirements.
- Enforcement standards across the EU are inconsistent, both in terms of definition and application e.g. definition of contamination. The Commission should monitor and ensure consistency of enforcement across EU and it should be a requirement on MS to ensure adequate and properly funded enforcement regimes.
- Controls must safeguard free movement of goods within the EU but the system should allow MS to intervene to support infrastructure where short term commercial constraints threaten, provided it does not impose a restriction on free movement.
- The Commission should not apply recycled content targets as this creates unintended consequences. Use of recycled material is already driven by commercial considerations and it is not considered necessary to impose artificial targets. Recycled content should be driven by commercial benefits and Member States should be free to consider internal fiscal incentives if required.
- We would strongly urge the Commission to ensure that the Impact Assessment of its Circular Economy proposals must be based on sound scientific principles. The previous impact study mis-represented the energy production mix in Member States and set recycling levels that did not account for the wide variance in recycling rate reporting methodology across the EU. Neither did the impact study consider what is an eco-efficient level of recycling, e.g. at what level the overall resource benefit outweighs the resource cost.
- Phil Conran – Independent Chairman
- Rick Hindley – Alupro – Trade Association
- Rebecca Cocking – British Glass – Trade Association
- Adrian Hawkes – Valpak – Compliance Scheme
- Simon Stringer – NiPak/ScotPak – Compliance Scheme
- Garvin Freeman – Tata – Steel reprocessor
- Johnathan Short – ECO Plastics – Plastics reprocessor
- Andrew Bird – Newcastle-under-Lyme – Local Authority
- Roger Walton – Dover – Local Authority
- Martin Cooper – SITA – Waste Management company
- Andrew Speck – HAVI GS – Packaging Specialist
- Alison Ingle – Nestle – Pack filler representative
- Retailer member – to be advised