Commentary of Gregor Spengler, etma Secretary General

Reduce, Reuse, Recycle

Currently a revision of the so-called essential requirements for packaging and packaging waste is discussed which are laid down in Annex II of the European Packaging and Packaging Waste Directive (94/62/EC). In this context the essential requirements shall take into account the waste hierarchy of the Waste Framework Directive which is reduce, reuse, recycle.

With regard to reduction, the introduction of defined packaging/filling ratios is under discussion to avoid over-packaging. In addition, the EN standard 13428 “Packaging - Requirements specific to manufacturing and composition - Prevention by source reduction” with its underlying assessment criteria shall be revised to promote the minimization of material input.

However, a lopsided focus on packaging reduction might entail the risk of under-packaging with potential collateral damages such as product waste or spoilage. In addition, it might trigger the conflict between packaging minimization through the use of complex laminate structures and the recyclability of packaging which can more easily be reached with mono-material packaging. In this context, clear rules from the European legislator are needed concerning the prioritization of aims in the packaging policy as a kind of guideline for the packaging supply chain.

As regards reuse the EU Commission is also aiming at incentives to promote design for reuse and replace as much single-use packaging by reusable or refillable alternatives. In this context, for example deposit systems for beverages shall be promoted throughout Europe. In addition, several important brands have, for example, partnered with the company Loop offering home delivery service for foods and household goods with reusable packaging. However, it has to be taken into account that reuse/refill systems need not necessarily have a better carbon footprint than single-use alternatives depending on the framework conditions. Incentives or even legal obligations to use reusable/refillable systems are only reasonable in those cases in which scientifically sound life cycle assessments unequivocally prove the superiority of such systems.

Concerning recycling a compulsory recycled content quota in packaging should be thoroughly analysed in the framework of an impact assessment based on the Packaging and Packaging Waste Directive. In any case, such a quota needs to be harmonized within the European Union in order to avoid any trade barriers.

Several challenges are linked to the definition of a harmonised recycled content quota:

• Availability of high-quality recycling materials
• Harmonisation of the requirements of Extended Producer Responsibility (EPR) systems in Europe in order to promote financial incentives for increased recyclability and recycled material content
• Introduction of a traceability system for recycled materials
• Existing legal limitations for the use of recycled materials (e.g. for food contact materials)

On top of that, the gap between the market price for virgin and recycled material plays an important role. In the case of plastics, for example, due to several reasons (low oil price, weak global economy, limited availability of high-quality recycling materials) the industry currently faces the tricky situation that the market price for high-quality recycled material is higher than that of virgin material. This has already induced the plastic recycling industry to ask for additional (political) measures and incentives to close that gap in order to achieve the desired recycled content in packaging.

With regard to the term “recyclability” the legislator is obviously planning the establishment of an authority which develops positive and negative lists of packaging components which facilitate or hamper the recycling of packaging. In Germany such an approach has already been put in place with the so-called “Zentrale Stelle Verpackungsregister” which developed a standard for assessing the recyclability of packaging. At European level it has to be ensured that a bureaucratic monster for the authorization of packaging is avoided.

In the current draft of the revised essential requirements the ambitious aim is laid down that 95 percent of the components of each packaging have to be recyclable until 2030. In this context a considerable technical progress and revamping of packaging structures is needed in the next ten years. It is very much likely that this requirement will lead to less complex packaging structures in the near future. Whether in the long run chemical recycling might be a solution for the recycling of plastic components in complex, multi-layer packaging structures and whether this approach is accepted by the legislator remains to be seen.

The above-mentioned aspects outline that it will be a huge challenge for the European legislator to lay solid foundations for reasonable essential requirements for packaging and packaging waste and to promote the circular economy in Europe in the best possible way. In any case, flexible tube producers will have to take these developments into account and adapt their company strategies and packaging designs accordingly so that they are in a position to provide convincing and sustainable packaging solutions for their customers and the final consumer.