European Commission and Republic of Estonia, Ministry of the Environment
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: email@example.com
Ulrich Leberle, Raw Materials Director, The Confederation of European Paper Industries: firstname.lastname@example.org
Antonino Furfari, Managing Director, Plastics Recyclers Europe: email@example.com
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 firstname.lastname@example.org or by phone at (+32) 2 627 49 23
For press related enquiries, please contact Ben Kennard at email@example.com 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 firstname.lastname@example.org or by phone at (+32) 2 62749 23
For press related enquiries please contact Ben Kennard at email@example.com 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
The paper packaging industry’s on Directive 94/62/EC on packaging and packaging waste (PPWD) and Directive 2008/98/EC on waste (WFD)
Paper Packaging Coordination Group (PPCG)
The Paper Packaging Coordination Group comprises the major European paper and board packaging associations representing the interests of a wide range of packaging products used in transport, retail and consumer packaging. Paper and board packaging is based on a renewable resource (the forest) and is recyclable. We support the concept of a circular economy in which raw materials are sourced from renewable, responsibly-managed resources and recycled after use.
1. Recycling targets for paper and board
• The proposed targets are ambitious, reflect technical and economic realities and can be achieved.
• Packaging recycling targets should be at comparable levels between different consumer packaging materials. High achievement of one packaging material should not compensate for another material’s lower achievement.
• We welcome the proposal that waste exported outside Europe should count towards the target of the Member State where it has been collected on condition that recycling takes place in equivalent environmental conditions.
We welcome the proposed targets for paper and board by the Commission. The paper and board packaging industry in Europe has achieved high recycling rates. In 2014, the average paper and board packaging recycling rate was 81.1% (CEPI). The EUROSTAT figure for 2011 was 79.9%. However, there are also significant differences between Member States, with the recycling rate ranging from 59% to 98% (EUROSTAT). Calculation methods for recycling vary between countries, making it difficult to compare existing data from different countries.
2. Recycling rate calculation
• We support quality recycling.
• We support the harmonised method based on “input to final recycling process”.
• Calculation formulas should be adapted and clarified with regards to “preparation for re-use and recycling” of “products and components” for packaging
We believe the “input” to the final recycling process is the correct basis for calculating the recycling rate and will improve the quality of recycling.
Final recycling process
• Article 1(2f) of the proposal for amending the WFD with a definition of “final recycling process” should read as follows: “final recycling process” means the recycling process which begins when no further mechanical sorting operation is needed and when waste and waste considered to have ceased to be waste in accordance with Article 6 enter a production process and are effectively reprocessed into products, materials or substances”.
• Article 1(5a) (i) should be consistent with the new definition of final recycling process. Therefore Article 6 (1c) of the WFD should therefore be amended as follows: “the substance or object fulfils the technical requirements for the final recycling process and meets the existing standards and legislation applicable to products.”
• The derogation article 11a paragraph 3(a) and (b) of the proposed amendments to the WFD and derogation article 6a paragraph 3 (a) and 3(b) of the proposed amendments to the PPWD should read as follows: “The weight of materials or substances that are not subject to a final recycling process and that are disposed or subject to energy recovery remains below the maximum threshold of impurities acceptable to operators carrying out a final recycling process in order to ensure quality recycling. These thresholds are outlined in Annex VII”. There should be a new annex VII on impurities limits per waste stream, in which the impurities limit for paper (non-paper components and other unwanted materials) should be set at 3% in line with the EN 643.
Packaging is different from the other waste streams, which the European Commission already acknowledges by having a dedicated directive for packaging and packaging waste. Packaging which is re-used in a closed loop is not considered as waste and only becomes waste when it leaves the loop. Mixing waste and non-waste (“products and components”) in one calculation formula will jeopardise the potential a harmonised method could have to deliver robust, comparable and accurate reporting. This, combined with an optional reporting on “products and components” will lead to increasing differences in the Member States’ reporting. It may also trigger cases where targets are met by clever calculations without an effective contribution to the circular economy. The resources needed from the European Commission to control the accurate implementation of the formula would be disproportionate to the potential benefits.
Calculation method and formula
• The formula in Annex IV of the PPWD should be clarified to avoid misinterpretations, under claims or over claims and allow for fair treatment of packaging, considering the intrinsic differences among materials.
• For packaging, the proposed Article 6a), paragraph 1c) should be deleted. Member States should not be optionally allowed to include in the calculation “products and components prepared for re-use”.
• For packaging, “R” should be removed from the formula in Annex IV.
• The denominator “P” should be clearly explained by defining “packaging waste generated”, as, for example, “total packaging placed on the market”.
3. Minimum requirements for Extended Producer Responsibility (EPR)
• EPR systems should be transparent.
• The scope of EPR and roles and responsibilities of each actor involved in packaging waste management should be clearly defined.
• A minimum requirement for EPR systems to collect all (packaging) materials should be introduced.
• A reference to EPR systems needs to be made in PPWD (94/62/EC) to ensure the protection of the internal market, and in the WFD (2008/98/EC).
We welcome the Commission’s intention to make EPR systems transparent as well as the inclusion of three important elements in the Commission’s proposal for general requirements for EPR systems: Eco-modulation, optimised cost and secondary raw materials sales revenues. Recyclability is a key criterion in eco-modulation for EPR systems andensures the value from the sales of secondary raw material. As the additional cost for their collection can be covered by these revenues, the contribution of producers should be lower. Within every material category, criteria for eco-modulation should be carefully designed so they do not inhibit innovation, technical progress, the functioning of the internal market and specific requirements regarding the packed products.
The provisions on general requirements for EPR systems should describe the costs to be covered without using non-exhaustive lists.
• Article 1(8) 4. (a) first paragraph of the proposal for amending the WFD should read as follows: “Cover the following cost of waste management for the products it puts on the Union market:…”
• The packaging sector should be recognised as a stakeholder in the EPR process so that it can share its expertise in managing the different materials
4. Separate collection, Landfill and Incineration of waste
• Recyclable packaging waste should not go to landfill. We support the ban on landfilling separately collected waste.
• Separate collection of all packaging waste should be strengthened and clarified.
• Incineration of recyclables should be restricted.
The requirement for separate collection of recyclable packaging waste is a precondition to avoid landfilling. The proposal aims in the right direction by linking the provisions on landfill restrictions to the separate collection requirement in the WFD and by introducing a methodology to measure the recycling rate at the input to a final recycling process, and by defining this final recycling process.
Despite the existing capacity for reprocessing paper in Europe, up to 10 million tonnes of all paper, including packaging, are currently being landfilled or incinerated in Europe. This situation has to be addressed, otherwise ambitious recycling targets cannot be achieved.
Paper and board should be collected separately from other recyclables such as plastics, metal, glass – or any combination thereof - and residual waste. Separate collection of all packaging and packaging waste is crucial in order to promote a circular economy and guarantee a high quality of secondary raw materials. The WFD formulated a separate collection target in 2008, but this has been interpreted in different ways by Member States. Beverage cartons (consisting predominantly of board) should be collected in the most optimal way for further recycling, which may differ from country to country.
• Article 11(1) of the WFD should be amended by changing ”for the relevant recycling sectors” to “for the relevant final recycling processes”.
• Article 11(11) of the WFD should be amended to clarify that paper shall be collected separately from metal, plastic and glass.
5. Unlock the potential of Renewable, Bio-Based Materials
• EU circular economy policies and measures should promote and encourage the use of bio-based materials as an essential solution to achieve a real circular economy.
The increased use of packaging made from bio-based materials fosters the establishment of a truly circular economy by taking into account an efficient use of renewable resources (biomass), integrated production and efficient use of bio-based feedstock in integrated bio-refineries. A true circular economy needs to be built on renewable carbon.
This logic should be extended to the legislative proposals under the circular economy package, in particular for sectors where solutions are already available, e.g. packaging. Therefore, the signatories request the recognition and encouragement of the use of materials from renewable sources in the PPWD.
Furthermore, using renewable, bio-based materials decreases Europe’s dependence on the import of raw materials and supports green development within the EU, leading to green growth and jobs.
• Amend the PPWD with the explicit requirement for Member States to encourage the use of bio-based materials for the manufacturing of packaging, where appropriate.
• Introduce a clear definition of what is meant by ‘bio-based’ to ensure coherent interpretation and a level-playing field for producers. The signatories recommend using existing definitions of the CEN Technical Committee TC 411 on bio-based products which define ‘bio-based’ as “derived from biomass” and ‘biomass’ as “material of biological origin excluding material embedded in geological formations and/or fossilised”.
6. Food waste
• We support the efforts of the Commission to reduce the generation of food waste.
• Cooperation among all stakeholders in the food supply chain and the Commission is needed.
Packaging prevents food loss and food waste in a sustainable way. UN studies support the fact that a substantial reduction of food losses can be achieved by providing and using the right packaging solution.
• The methodologies (paragraph 4) developed by the Commission should consider the positive role of packaging in the prevention of food waste.
• The packaging sector should be among the stakeholders consulted on the subject.
Currently, the following organisations participate in the PPCG:
CEPI, Confederation of European Paper Industries
CITPA, International Confederation of Paper & Board Converters
ACE, The Alliance for Beverage Cartons and the Environment
ECMA, European Carton Makers Association
EMBALPACK, European Association of Makers of Packaging Papers
EMFA, European Moulded Fibre Association
CEPI EUROKRAFT, European Producers of Sack Kraft Paper and Kraft Paper
CEPI CONTAINERBOARD, European Producers of corrugated case materials
EUROSAC, European Federation of Multiwall Paper Sack Manufacturers
FEFCO, European Federation of Corrugated Board Manufacturers
PRO CARTON, European Association of Carton and Cartonboard Manufacturers
The position paper can be downloaded here.
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 firstname.lastname@example.org, mobile: +32 478 25 50 70
Rutger van Dijk, VNP Communication and PR at email@example.com, 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 firstname.lastname@example.org, 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.