Letter to European Commission Vice President Timmermans on Plastics Strategy
The undersigned organisations are writing to express deep concern over the European plastics strategy currently under development. Based on drafts released by the media, we believe the strategy seriously risks: 1) being developed in silos of plastics without a systemic view, 2) failing to respect the principle of technological/material neutrality and having serious unintentional and unassessed consequences for competing materials and technologies that may in some cases perform better in terms of environmental impacts and circularity and 3) missing the opportunity to drive a low-carbon circular economy. Representing sectors that both compete and work with plastics, we would call upon you to take corrective measures, including the concrete requests for actions listed below before the Commission moves to adopt the strategy.
1) The strategy is being developed in silos of plastics without a systemic view
Plastic materials compete on the market with many other materials with similar or better functionalities and similar or lower negative impact. We strongly believe that the silo approach adopted by the Commission – ignoring interactions, market mechanisms, competition, implications on the whole packaging value chain – will have serious unassessed and unintended consequences and does not ensure fair and equal treatment of all materials. In our view, the draft plastics strategy fails to consider and assess the value chain systems both within the petrochemical industry and even more so in the wider economy. Our observations include:
• the evident market failures of plastic prices; instead the strategy seems to suggest introducing more financial support mechanisms despite the fact that oil and gas subsidies in the EU are significant and have been growing in the OECD at a much higher rate than the growth of GDP ;
• the potential to substitute plastics by better alternatives for some applications;
• the potential to replace fossil feedstock by alternative feedstocks (to name but one, sustainable lignin );
• the sourcing element as circularity is not only about recycling but about the sustainable production of input material; sustainable sourcing is a growing concern and already a legal requirement for other technologies;
• the market impacts for other solutions, materials and products;
• other key policies such as climate change, mobility or bio-economy.
The undersigned deeply regret that - despite several attempts to be heard - they have not been allowed to contribute to the discussion on the strategy.
We would call for the Commission to incorporate the following elements in the plastics strategy:
I. Interaction of the many connected policies, including low-carbon bioeconomy.
II. Implications for competing technologies and materials to ensure fair competition and a level playing field.
III. A holistic view reflecting the reality where plastics are not addressed in isolation and a dynamic understanding of the sectors involved and impacted by the strategy.
IV. Assessment of the systems of value chains within the petrochemical industry, with a view to subsidies for fossil-based plastics and in the wider economy.
V. Assessment of the petrochemical industry as a resource.
VI. Improved assessment of alternative feedstocks, including existing by-products from other sectors and their accessibility, and symmetry in assessing traditional fossil feedstocks’ environmental impacts.
VII. Our industry should be included in the platforms which will be established to discuss and implement this strategy as it will have a direct impact on us.
2) The strategy risks failing to respect the principle of technological neutrality
The measures proposed in the draft plastics strategy and the associated financial and other support would fail to respect the principle of technological neutrality and non-discriminatory policy. And this, notwithstanding that circular economy targets would remain lower for plastics than for other materials.
We find it unfair to have a strategy that rewards the laggards whilst other materials who have done the work and paid for it themselves in the past decades risk being penalised. It would be a strange outcome if the final strategy were to favour a material that remains problematic over less problematic ones.
We would call for the Commission to incorporate the following elements in the plastics strategy:
VIII. Full respect of the principle of technological neutrality in a fair and equal approach.
IX. Reserving an equal amount of public funding for other solutions, materials and technologies as will be the case for plastics.
X. Acknowledgment and promotion of sustainable substitution by competing solutions, materials and technologies; more sustainable packaging materials should be preferred when there is a choice.
XI. Assessment of, and setting policy requirements for, plastics with metrics and boundaries comparable to competing technologies; targets set for plastic materials have to be set on a par with targets for other materials.
XII. Consideration of the full life cycle of plastics, including upstream sourcing of feedstocks (both alternative and traditional).
3) The strategy misses an opportunity in a low-carbon and circular economy
The strategy misses an opportunity to combine a drive for resource efficiency and a move away from non-renewable resource use. As highlighted by President Juncker and the Industrial Policy Strategy released by his Commission, the aim is to build a low-carbon circular economy.
The potential offered by the bio-based economy should be considered alongside the potential to streamline the plastics value chain and make it more efficient. The US public procurement strategy for bio-based materials and products has had a significant positive impact in terms of growth and jobs : similarly the public procurement in Europe should first consider sustainable substitutes to plastics.
We would call for the Commission to incorporate the following elements in the plastics strategy:
XIII. To ensure that public procurement rules or economic incentives are fair, proportionate and not unduly supporting a material, such as recycled plastics, instead of choosing other solutions, materials and technologies, in particular renewable or already highly recycled, over fossil-based plastics.
XIV. Indeed, we would call for the Commission to incentivise industry to encourage companies to choose more sustainable, renewable materials in the first place when selecting their packaging materials. This might be through taxation on the use of plastic or providing positive incentives to use more sustainable materials.
We share a common aim: producing a sustainable circular European economy. The buy-in of the wider economy and society in general for the plastics strategy prepared by the European Commission would require a much more holistic and systemic approach and respect of the principle of technological neutrality by giving a fair and equal treatment to all sectors. At the same time, the plastics strategy should be seized as an opportunity to bring the plastics industry on a par with other industry sectors regarding responsible performance, not least to protect the marine environment and other water bodies.
We remain at your disposal to discuss the matter further and will be in contact with your respective teams of Commissioners in order to support the development of the strategy.
CITPA, International Confederation of Paper & Board Converters
CEPI, Confederation of European Paper Industries
ACE, The Alliance for Beverage Cartons and the Environment
CEPI CONTAINERBOARD, European Producers of corrugated case materials
CEPI EUROKRAFT, European Producers of Sack Kraft Paper and Kraft Paper
ECMA, European Carton Makers Association
EMBALPACK, European Association of Makers of Packaging Papers
EMFA, European Moulded Fibre Association
EUROSAC, European Federation of Multiwall Paper Sack Manufacturers
FEFCO, European Federation of Corrugated Board Manufacturers
PRO CARTON, European Association of Carton and Cartonboard Manufacturers
CC: Commission Vice-President Katainen, Commissioners Moedas, Vella, Bienkowska
Secretary General of the Commission
Director Generals of DG Grow, DG RTD, DG ENV
Joint letter on alignment of Renewable Energy Directive with the Circular Economy Policies
TO: Members of the European Parliament ITRE Committee
Subject: Alignment of the revision of the Renewable Energy Directive with the Circular Economy Policies
Dear Members of the ITRE Committee,
Ahead of the report of the ITRE committee on the revision of the EU Renewable Energy Directive (RED II), the undersigned organisations, representing plastic and paper recyclers and zero waste associations around Europe, would like to bring to your attention our concerns as regards to inconsistency of the Commission’s proposal in RED II with the Circular Economy policies and the EU’s climate policy agenda.
This is due to the consideration of the biomass fraction of mixed municipal solid waste as a source of renewable energy when it is actually burning thanks to other materials (e.g. plastics and paper). Member States are consequently allowed to support various forms of energy generation from waste, to meet targets set under the RED II. These schemes which support waste-to-energy generation from mixed municipal waste, run counter to the EU’s transition to a low-carbon and circular economy, furthermore this would work to:
1. Undermine the Waste Hierarchy and the Circular Economy policies
Financial support for waste-to-energy from mixed municipal waste subverts one of the cornerstones of the EU waste policy – the waste hierarchy -, which establishes an order of priority in waste prevention and management i.e. prevention, preparation for re-use, recycling, other recovery (energy recovery), and disposal1. Waste is therefore meant to be firstly prevented, then prepared for reuse and, finally, recycled. Conversely, the RED II classifies it as a source of ‘renewable energy’ and allows renewable energy support schemes that conflict with the waste hierarchy by encouraging waste-to-energy processes, which is the second least desirable option of the waste hierarchy.
The effect so far has been a clear distortion of the market whereby investment in waste infrastructure and operation costs are organised on the basis of subsidies for the extraction of energy from waste instead of sound environmental and economic performance of the best waste management option. As a result, several European countries e.g. Denmark have overinvested in energy-from-waste plants whilst underinvesting in recycling facilities.
2. Undermine the Communication on Waste-to-Energy in the Circular Economy
The RED II also contradicts the Commission’s recent Communication on the Role of Waste-to-Energy in the Circular Economy which states that public financing of waste management, whether national or at EU level, should be consistent with the waste hierarchy and Member States should phase-out public support for the recovery of energy from mixed waste in line with the separate collection obligations and more ambitious EU recycling targets proposed in the legislative proposal on Circular Economy2.
3. Undermine the EU’s Climate Policy Agenda
The Commission’s proposal also undermines the EU’s climate agenda by supporting energy generation from mixed municipal waste, which is never solely composed of biogenic carbon. Much of the calorific value from waste-to-energy processes from mixed waste (incineration, pyrolosis or gasification) comes from the treatment of fossil carbon based materials such as plastics. For example, a typical waste incineration facility has a carbon intensity of approximately 600 kg CO2 eq. per MWh of electricity. This compares with a figure of 380 kg CO2 per MWh of electricity at an efficient natural gas power station using Combined Cycle Gas Turbine technology3.
Moreover, the monitoring of the amount of the proportion of organic waste compared to the amount of fossil-based waste in municipal mixed waste is both logistically and technologically difficult. It’s often assumed that the proportion is 50% - even if industrial and commercial waste is frequently included in the mix of waste entering a waste-to-energy facility. Given the heterogeneity of waste and the great differences from plant to plant, this percentage is neither constant nor reliable, which supports the evidence that much of the so-called renewable energy from waste-to-energy comes in fact from incinerating fossil carbon based materials.
The undersigned organisations therefore urge the members of the ITRE Committee to align the Commission’s proposal for a revised Renewable Energy Directive with the circular economy policies by explicitly excluding primes of subsidies for waste-to-energy generation from the mixed municipal solid waste.
On behalf of signatories
Joan Marc Simon
ZWE Executive Director
Janek Vahk, Development and Policy Coordinator, Zero Waste Europe: firstname.lastname@example.org
Ulrich Leberle, Raw Materials Director, The Confederation of European Paper Industries: email@example.com
Antonino Furfari, Managing Director, Plastics Recyclers Europe: firstname.lastname@example.org
Made to measure ‘real’ recycling rates will target investment where it matters most
The European Parliament has today opted to follow the ambitious lead set by Environment committee’s vote on the Circular Economy package in January this year.
The most important outcome from today’s vote is that MEPs moved in favour of one single calculation method that enshrines real and comparable recycling rates both in and for Europe.
“Today, the European Parliament has fully grasped the opportunity to make the Circular Economy work for Europe by enabling industry and local authorities to better target where investment needs to take place” says CEPI Director General Sylvain Lhôte
CEPI recognises that the new recycling targets are ambitious while providing new opportunities in terms of improving quality.
“For an industry where over half of our feedstock comes from paper for recycling, the Parliament’s approach means greater use of raw materials whilst putting the emphasis on quality” says CEPI Raw Materials Director Ulrich Leberle
The vote to encourage the use of bio-based packaging also demonstrates the importance of a Circular Economy that builds upon Europe’s wealth of renewable resources while accelerating the transition towards a low-carbon economy.
Finally the continued assertion of the separate collection of paper is viewed by the European paper and board industry as a means to bridge ambitious targets with higher quality recycling.
CEPI together with other partners in the European paper value chain will shortly publish its updated European Declaration on Paper Recycling where it addresses its commitment to the new targets.
The Circular Economy is one of the core elements necessary to achieving industry transformation in Europe as outlined in our ‘Investment Roadmap’ towards a low-carbon bioeconomy. Check out our alignment matrix for the full picture.
For more information, please contact Ulrich Leberle at email@example.com or by phone at (+32) 2 627 49 23
For press related enquiries, please contact Ben Kennard at firstname.lastname@example.org or by phone at (+32) 487 39 21 82
Waste Framework Directive: European material industries renew call for measurement of real recycling rates
Europe‘s metals, steel and paper industries renew their call for a harmonised method to measure Member State recycling rates at input into the 'final recycling process'. The full document can be consulted via the link below.Download here
ENVI committee vote: one step closer towards a truly circular economy in and for Europe
The Confederation of European Paper Industries (CEPI) welcomes today’s vote in Environment Committee (ENVI) strengthening the foundation of a truly circular economy in Europe.
“MEPs are now one step closer to building a truly circular economy” says Sylvain Lhôte, CEPI Director General. “The package needs to be kept on the right track in order to deliver the circular economy in and for Europe".
CEPI welcomes ENVI’s call to measure real recycling rates at the input to the final recycling process. To truly drive circularity in Europe, it is essential that material is only considered recycled once it enters the final production process and is actually reprocessed.
CEPI also supports the ENVI’s call for quality standards and traceability in the paper recycling chain that will enhance targeted investments and serve the efficient functioning of the secondary raw material market in Europe.
The reinforcement of separate collection will also drive quality recycling and boost circularity of Europe’s economy. In the past, authorities have used a loophole in the separate collection obligation to collect paper in co-mingled streams, undermining high quality recycling. CEPI is therefore concerned that the proposal to exempt scarcely populated areas from this obligation may unnecessarily open up a gap.
CEPI will further assess the extremely high gap between recycling targets of competing packaging materials, envisioned by MEPs.
Finally, CEPI is also encouraged by ENVI’s call on Member States to promote the use of bio-based recyclable packaging. “Leveraging on nature’s cycles for the circular economy is a welcome complement to the ambition of the Commission’s proposal” says Ulrich Leberle, CEPI Raw Materials Director.
For more information, please contact Ulrich Leberle at email@example.com or by phone at (+32) 2 62749 23
For press related enquiries please contact Ben Kennard at firstname.lastname@example.org by phone at (+32) 487 39 21 82
Circular Economy package - Joint statement by CEPI, EuRIC and FEAD
Leading federations representing the paper value chain call for the co-legislators to support the further increase of paper recycling and safeguard the “quantity” criterion in the definition of municipal waste.
The European Commission proposes to define municipal waste as mixed waste and separately collected waste from households and “mixed waste and separately collected waste from other sources that is comparable to household waste in nature, composition and quantity” .
A lot of the debate has focused on the quantity criterion. We believe that this is the only objective and measurable criterion. The quantity criterion is needed to clearly distinguish between municipal waste on one hand, and commercial and industrial waste on the other.
While paper from commercial and industrial sources is already collected and recycled at high levels, an untapped potential exists for household paper collection and similar sources, for which the waste directive is setting targets. If the quantity criterion is removed, the target for municipal solid waste will unduly include commercial and industrial waste and affect the accuracy of statistical data.
Moreover, the collection of commercial and industrial waste should not be financed and cross-subsidised by public funds, ultimately resulting in additional costs for taxpayers. In the absence of the quantity criterion there is a genuine risk that the scope of municipal waste is widened and therefore the focus is diverted from areas where the need to increase collection is the most acute. In order to ensure that all streams remain open to competition, instrumental to preserving cost-efficient and innovative waste markets, we support two key actions:
1. Maintaining the quantity criterion in the definition of municipal waste;
2. Clearly stipulate into the definition of municipal waste that it is neutral with regard to the public and private status “The definition of municipal waste (…) is neutral with regard to the public or private status of the operator managing waste and to the ownership of the waste”.
CEPI – The Confederation of European Paper Industries
The Confederation of European Paper Industries (CEPI) is a Brussels-based non-profit organisation regrouping the European pulp and paper industry and championing the industry’s achievements and the benefits of its products. Through its 18 member countries (17 European Union members plus Norway) CEPI represents some 505 pulp, paper and board producing companies across Europe, ranging from small and medium sized companies to multi-nationals, and 920 paper mills. Together they represent 23% of world production.
EuRIC – The European Recycling Industries’ Confederation
EuRic is the umbrella organisation for recycling industries in Europe. Through its Member Federations from 19 EU and EFTA countries, EuRIC represents today 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;
- An average of 150 million tons of waste recycled per year (paper, metals and beyond);
- Recyclers play a key role in a circular economy. By turning wastes into resources, recycling is the link which reintroduces recycled materials into the value chains again and again.
FEAD – The European Federation of Waste Management and Environmental Services
FEAD is the European federation representing the European waste management industry. FEAD’s members are national waste management associations covering 18 Member States, Norway and Serbia. They have an approximate 60% share in the household waste market and handle more than 75% of industrial and commercial waste in Europe. Their combined annual turnover is approximately € 75 billion. FEAD represents about 3,000 companies with activities in all forms of waste management. These companies employ over 320,000 people who operate around 2,400 recycling and sorting centres, 1,100 composting sites, 260 waste-to-energy plants and 900 controlled landfills. They play an important role in the determination of the best environmental option for waste management problems.
Joint Statement on the legislative review amending the Waste Framework Directive and Packaging and Packaging Waste Directive
1. Ensure a life-cycle approach in legislation, taking into account the functionalities of packaging, such as preserving the entirety of resources invested in the packaged product along the entire value chain.
2. Safeguard the Internal Market (the legal basis of the PPWD) to ensure the free movement of packaging and packaged goods. Avoid de facto trade barriers for packaging and packaged goods; retain the PPWD’s pre-notification procedure and Article 21 Committee.
3. Ensure relevance of the EU EPR “general requirements” for the packaging waste stream, alongside nationally and clearly defined roles and responsibilities, for all actors involved in EPR implementation. Obligated costs for producers need to be clearly demarcated and net of revenue from the sale of secondary raw materials.
4. Allow free competition so that producers can choose the packaging most appropriate for the product and distribution system. Legal requirements that mandate additional packaging reuse systems alongside existing EPR systems risk undermining the cost-efficiency of EPR and recycling efforts/investments. Resist national measures to promote packaging reuse systems that will distort the Internal Market.
5. Set realistic and achievable packaging “preparing for reuse”/recycling targets, based on an updated ex-ante impact assessment, known starting points, as well as a harmonised and clarified measurement point and calculation methodology.
The undersigned organisations1 represent a wide range of sectors in the packaging value chain. They support an enabling EU policy framework that facilitates sustainable resource use from a full lifecycle perspective, incentivises economies of scale and takes into account value chains at all levels with each of their different needs, supply and demand realities. To further enable our industries to transition towards a resource-efficient and competitive Circular Economy, our associations have the following recommendations for the European Parliament and Council to ensure EU legislation is relevant, achievable and proportionate for packaging and packaged goods.
1. LIFE-CYCLE APPROACH: In addition to end-of-life considerations, measures must also take into account the key functionalities of packaging, such as preserving the entirety of resources invested in the packaged product along the entire value chain.
- Packaging plays a positive role in a Circular Economy by optimising resource use, minimising product (e.g. food) waste and protecting products all along value chains. Packaging is cross-sectoral and, in order to perform its functions, the full lifecycle of the packaging, intrinsically connected with the product it contains and value chain, must be considered in its entirety. The choice of packaging which best meets the functional requirements for the product concerned, needs to be made on a case-by-case basis.
- Therefore, we strongly caution against measures that set restrictive/prescriptive requirements for packaging attributes (e.g. single-use/multiple use, recyclable or non-recyclable, bio-based and/or biodegradable, recycled content, single-serve/dose) without regard to the impact on the life-cycle of packaged products themselves. Such legal requirements for attributes of packaging could imply significant costs for businesses in Europe to adapt whole supply chains, stifle product innovation, distort the Internal Market (see point 2) and might lead to a net detrimental environmental impact on packaged goods. In case of restrictions on single-use packaging, it also ignores (modern) societal and consumer trends, and risks being perceived as the EU overstepping its boundaries.
- We also believe it is difficult to set and fairly calculate packaging prevention targets and to ascribe related targets to different sectors. The demand for packaging is linked to the demand for packaged goods. Changes in demand for packaged goods and associated product innovations determine the types of packaging placed on the market and the amount of protection that their contents need. Prevention is already addressed under the PPWD’s essential requirements in Annex II. In addition, there is already an economic incentive for producers to optimise the amount of packaging they use (over and above the cost of the packaging materials) since packaging EPR fees are based on weight.
2. INTERNAL MARKET: Safeguard the Internal Market (the legal basis of the PPWD) to ensure the free movement of packaging and packaged goods
- A Circular Economy in Europe cannot be achieved without a properly functioning Internal Market, guaranteed by the PPWD that has the Internal Market as its sole legal base. That legal base, alongside its harmonisation and environmental objectives, gives companies in the packaging value chain the confidence to invest and innovate in order to meet the growth, competitiveness and employment objectives of the Circular Economy Package.
- Therefore, we recommend avoiding measures that could lead to divergent national packaging design requirements, since they create de facto trade barriers for all packaged goods. The PPWD contains an important obligation, under Article 16, on Member States to notify their intention to introduce such measures. This obligation ensures that national measures do not disrupt the Internal Market for packaging and packaged goods.
- Likewise, promoting national reduction quotas and even national bans for certain packaging types, materials or systems is inappropriate (see also point 1). Such measures would create real trade barriers in the EU which the PPWD explicitly aims to avoid. Great care must be taken not to undermine two decades of success in safeguarding a single European market for packaging and packaged goods. As long as a packaging respects the essential requirements of the PPWD, it must be guaranteed access to market and free movement in the EU.
- The Commission should continue to be assisted by the Committee for the Adaptation to Scientific and Technical Progress, composed of the representatives of the Member States and chaired by the representative of the Commission as stated in the initial PPWD Article 21. This article allows the practical implementation of the PPWD to be kept under review. The composition of this Committee should explicitly include national environmental/waste and industry experts in order to mirror the PPWD’s Internal Market legal base, as well as its dual objectives.
3. EXTENDED PRODUCER RESPONSIBILITY: Ensure that the EU EPR “general requirements” in the WFD apply to all schemes and are made relevant for the packaging waste stream, respecting the PPWD’s legal base. These EU requirements sit alongside explicitly specified roles and responsibilities, defined at national level by Member States, for all actors involved in EPR implementation. This allows Member States to continue to set up EPR systems according to their national requirements, in line with the subsidiarity principle. Additionally, obligated costs for producers need to be clearly demarcated and net of revenue from the sale of secondary raw materials.
- This will ensure that national measures to implement the EPR “general requirements” cannot disrupt the Internal Market for packaging and packaged goods, since the PPWD has the Internal Market as its legal basis which the WFD has not. For instance, “including all the following costs” suggests that the basis of the costs may differ from one Member State to another, potentially fragmenting the Internal Market. The basis of the costs should be based on harmonised criteria established by the proposed Member States’ exchange of information forum (see also point 2). However, actual fee setting should remain the responsibility of individual EPR schemes within a Member State.
- Ensure a clear net cost demarcation for the obligated industry at EU and national level. An unlimited obligation for producers to “cover the entire cost of waste management” is disproportionate to the producer’s role and responsibility for the separate collection, sorting and related treatment operations of used packaging for recycling. In line with the Circular Economy’s objectives, we strongly support the proposed net cost principle/incentive which takes into account the revenues from sales of secondary raw packaging materials.
- In addition, we believe that producers need to be able to drive waste prevention within their production, because it is the producer who knows what the packaging needs of their products and supply chains are (see point 1). Therefore, we recommend keeping prevention requirements outside the EPR “general requirements”, which apply to all waste streams covered by EPR and the different ownership models of EPR schemes. Waste prevention goes beyond the end-of-life role and responsibility of packaging EPR schemes and is related to the life-cycle of the entire product.
4. REUSE: Allow free competition between packaging materials and formats so that producers can choose the packaging most appropriate for the product and its distribution system. Legally requiring new packaging reuse systems to be established alongside existing EPR systems will undermine the cost-efficiency of EPR and recycling efforts/investments and distort the Internal Market.
- Avoid creating an obligation for Member States to introduce new reuse systems in markets where EPR and recycling systems are well-established. Studies show that imposing new systems to promote reuse activities alongside well-functioning recycling systems erodes the (cost-) efficiency of household-based collection systems as existing infrastructure would no longer be used to its full potential. In addition, if existing installed production capacity is required to be substituted by reuse systems, substantial capital and operating costs will be imposed on producers and retailers for which no economic return is possible without incremental sales volumes or increased prices for consumers. Additional reuse systems should be subject to a complete ex-ante technical, social, environmental, and economic analysis.
- In addition, national measures to promote packaging reuse systems tend to undermine the Internal Market because they favour local trade exchanges/sales as reusable packaging systems rarely make economic or environmental sense over longer distances.
- We support smart regulation for the PPWD that allows those Member States with existing reuse systems for packaging in place to be credited for their efforts when calculating their progress towards the EU packaging targets. This can be done by deducting reusable packaging (which is not part of ‘packaging waste generated’) from the reported ‘packaging placed on the market’ (all packaging), as part of the target calculation methodology. At the end of its reusable life, it becomes waste and thus part of ‘packaging waste generated’. In this spirit, we support Member States and MEPs request not to mix waste with products and thus to retain the 2008 WFD definition for ‘preparing for reuse’.
5. PACKAGING TARGETS: Set realistic and achievable packaging “preparing for reuse”/recycling targets, based on an updated ex-ante impact assessment, known starting points, as well as a harmonised and clarified measurement point and calculation methodology.
- We support realistic and achievable “preparing for reuse”/recycling packaging targets based on clear starting points. Hence, any changes to the structure of targets, definitions, measurement points and related methodology need an updated ex-ante cost/benefit analysis. Such an analysis will assess the impact of these changes against target achievement and economic and environmental benefits.
- Robust measurement and accurate reporting are crucial to ensure transparent and comparable data across the EU. The Commission’s proposal rightly establishes the point of measurement for packaging recycling as the point of input to a final recycler, after sorting operations have been completed. The option to count output from sorting operations under certain conditions is fully consistent with this measurement approach.
- We support the current method of counting recycling of composite packaging towards the rates and targets of the predominant material. It is neither technically nor administratively feasible to count the recycling of material components of composite packaging coming out of a recycling process towards their individual material recycling rates. In addition, counting such materials separately is unlikely to have any significant impact on overall packaging material recycling rates.
We trust that the above is constructive and would welcome the opportunity to reflect further on the points outlined above together with the European Parliament, Council, Commission and other stakeholders.
Signed by the following industry organisations (in alphabetical order)
ACE – The Alliance for Beverage Cartons and the Environment
AGVU - Arbeitsgemeinschaft Verpackung und Umwelt e.V., Germany
AIM – European Brands Association
A.I.S.E. – The International Association for Soaps, Detergents and Maintenance Products
ARA – Altstoff Recycling Austria AG Packaging Compliance Scheme, Austria
ARAM – Romanian Association for Packaging and the Environment
BIHPAK – Bosnia and Herzegovina Association for Packaging & Packaging Waste Management
CEPI – Confederation of European Papers Industries
CICPEN – Czech Industrial Coalition on Packaging and the Environment
CITPA – International Confederation of Paper and Board Converters
Cosmetics Europe – The Personal Care Association
DSD - Der Grüne Punkt Dual System for Packaging Recycling, Germany
Eco-Emballages – Packaging Recovery Association, France
EuPC – European Plastics Converters
EPBA – European Portable Battery Association
EUROPEN – The European Organization for Packaging and the Environment
FEA – European Aerosol Federation
FEFCO – European Corrugated Packaging Association
FEVE – The European Container Glass Federation
Flexible Packaging Europe
IK- Industrievereinigung Kunststoffverpackungen e.V., Germany
INTERGRAF– European Federation for Print and Digital Communication
INCPEN - The Industry Council for Research on Packaging and the Environment, UK
MPE - Metal Packaging Europe
Miljöpack – Trade Industry Group, Sweden
Pack2Go Europe - Europe’s Convenience Food Packaging Association
Pakkaus – Finnish Packaging Association
REKOPOL - Recovery Organisation S.A., Poland
REPAK - Packaging Recovery Organisation, Ireland
Serving Europe - Branded Food and Beverage Service Chains Association
SLICPEN – Slovak Industrial Coalition on Packaging and the Environment
Sociedade Ponto Verde, S.A. – Packaging Recovery Organisation, Portugal
UNESDA – Union of European Soft Drinks Associations
Valpak - Environmental Compliance, Recycling and Sustainability Solutions, UK
1 This joint statement captures the main points our associations share in common and does not preclude each of the undersigned organisations from issuing individual positions that are more focused on their specific sectors.
2 Roland Berger, The consequences of a deposit system for disposable packaging based on the German example, 2008
3 Communication (2009) from the Commission: Beverage packaging, deposit systems and free movement of goods (2009/C 107/01); European Commission (1999) Reuse of primary packaging
Hands-on Circular Economy - An inspiring paper mill visit with permanent representation officials
The Dutch Presidency of the Council of the European Union organised a field trip for Industry and Environment Council working group members to illustrate the Circular Economy, one of the Presidency’s top priorities. The Presidency chose the state-of the-art paper mill in Roermond, The Netherlands. The mill is operated by Smurfit Kappa and its raw material is 100% paper for recycling, making it the perfect example of circularity. The visit was co-organised with the Confederation of European Paper Industries (CEPI) and the Royal Dutch papermaking association VNP.
“We are very happy to be given the opportunity to demonstrate that paper is at the heart of the Circular Economy”, said CEPI Acting Director General Jori Ringman. “The paper industry champions many aspects of circularity from reusing water to industrial symbiosis, from including the whole value chain in advancing circularity to working towards clean and safe cycles. Whilst the recycling starts already at homes and offices and is a chain of many important actors, it is vital that EU legislation acknowledges the final recycling where the material is physically transformed to start a new cycle; this is what the participants saw today in practice”, he added.
Europe is a world champion when it comes to paper recycling, achieving a 72% recycling rate in 2014.
The Roermond mill is a great example of Circular Economy. It processes 600 000 tonnes or one million bales of waste paper into new paper rolls every year, which is more than 25% of the annual collected amount of paper for recycling. “The companies in our sector produce products in a very high tech and sustainable way, products that play a very important role in everyday life. The participants of the field trip could closely experience that in Roermond,” said Gerrit Jan Koopman, Director of Royal VNP.
For more information, please contact:
Jori Ringman, CEPI Acting Director General at email@example.com, mobile: +32 478 25 50 70
Rutger van Dijk, VNP Communication and PR at firstname.lastname@example.org, mobile +31 6 45 79 02 60
Note to the Editor
CEPI aisbl - The Confederation of European Paper Industries
The Confederation of European Paper Industries (CEPI) is a Brussels-based non-profit organisation regrouping the European pulp and paper industry and championing industry’s achievements and the benefits of its products. Through its 18 member countries (17 European Union members plus Norway) CEPI represents some 505 pulp, paper and board producing companies across Europe, ranging from small and medium sized companies to multi-nationals, and 920 paper mills. Together they represent 23% of world production. For further information see http://www.cepi.org/
Royal VNP – Koninklijke Vereniging van Nederlandse Papier- en Kartonfabrieken
The Dutch paper and board association represents the interests of the Dutch paper and board industry with an active lobbying focused on solutions, on current policies, legislation and sustainability. They provide services to their members and initiate policy-supporting studies. In this way they help to connect the companies’ needs and developments in society (customers, employees, government, NGOs and society in general). For further information see www.vnp.nl.
Circular Economy for paper: Better design and management guidelines
A World Economic Forum publication in collaboration with industry
The European paper industry was invited to collaborate with the World Economic Forum (the Forum), the Ellen MacArthur Foundation and the McKinsey Center for Business and Environment on Circular Economy to produce a white paper with guidelines on design and management for circularity. The new publication provides essential guidance to all actors in the supply chain through simple ecodesign rules for paper products, without limiting innovation and the introduction of new techniques. This is a product of the three pilots under Project MainStream, launched during the 2014 summit in Davos.
“We trust helping circular thinking in all steps of the complex value chain will help reach higher in what is already a high recycling performance”, said CEPI Sustainability Director Jori Ringman, one of the draftsmen of the guidance, in a panel discussion on the feasibility of higher recycling rates at the Packaging and Sustainability event in Brussels on Wednesday. “In circular economy, your downstream is your upstream and what you pass on into the loop will have an impact on your own business.”
Although highly recyclable, paper is usually converted by industries that add chemicals to it through printing inks and other auxiliary materials. This can lead to problems in subsequent circular chains, as these chemicals cannot easily be removed from the paper before re-entering the mill. Furthermore, the already highly-optimised recycling process cannot follow the speed of the evolution of inks and toners.
The publication summarises the key choices to be made by direct (printers, papermakers, collectors) and indirect (such as local authorities, ink producers, equipment manufacturers) stakeholders. More specifically, it identifies the choices that can influence businesses ordering a fibre-based product - printed paper, packaging or other.
“Businesses will have many priorities topping their agendas, such as meeting customer requirements, creating functionalities that meet both the purpose and profitability, and respecting environmental considerations”, says Ringman. “This document is meant to make decision-making in companies easier when balancing these priorities.”
For more information, please contact Jori Ringman at email@example.com, mobile: +32 478 25 50 70.
Note to the Editor
Project MainStream is a collaboration between the World Economic Forum, the Ellen MacArthur Foundation and the McKinsey Center for Business and Environment, seeking to remove bottlenecks in the large-scale transitioning to the circular economy.
CEPI aisbl - The Confederation of European Paper Industries
The Confederation of European Paper Industries (CEPI) is a Brussels-based non-profit organisation regrouping the European pulp and paper industry and championing industry’s achievements and the benefits of its products. Through its 18 member countries (17 European Union members plus Norway) CEPI represents some 505 pulp, paper and board producing companies across Europe, ranging from small and medium sized companies to multi-nationals, and 920 paper mills. Together they represent 23% of world production.
Open letter to Jean-Claude Juncker on the withdrawal and renewed discussion of the circular economy package
CEPI together with other representatives from industry, NGOs, municipalities and public service providers addressed an open letter to Commission president Jean-Claude Juncker. In this letter, they underlined the importance of publishing a new Circular Economy proposal within a short timeframe. According to the co-signatories, this would enable our European economy to rebound through the creation of a circular economy.