Recycling

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20 May.2016 ,

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)

Introduction
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
Key messages:
• 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
Key messages:
• 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.

Recommendations:

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.”

Derogation
• 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.

Recommendations:
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)
Key messages:
• 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.


Recommendations:
• 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

Key messages:
• 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.

Recommendations:
• 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
Key message:
• 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.
 

Recommendations:
• 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
Key messages:
• 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.

Recommendations:
• 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.

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04 Apr.2016

Paper for Recycling Quality Control guidelines

The European Standard EN 643, European list of standard grades of paper and board for recycling, is the basic document to be used by industry professionals in the buying and selling of paper for recycling. Interested parties should order the EN 643 from their respective national standardisation body . The standard was revised in 2013. It defines what the different grades of paper for recycling can and cannot contain as well as defining prohibited materials and unwanted materials. It also sets maximum tolerance levels by grade for unwanted materials.

Specific agreements between buyer and supplier for grades with special specifications might still be necessary to meet individual requirements. However, general recommendations are needed to facilitate a common understanding of the standard.

To achieve greater harmonisation, to improve the implementation of the EN 643 Standard and to facilitate commercial relationships between paper mills and paper for recycling suppliers, these guidelines contain recommendations regarding paper for recycling quality controls for paper for recycling suppliers and paper mills.

The publication is now available in French
 

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04 Apr.2016 ,

European paper industry launches revised Paper for Recycling Quality Control guidelines

The Confederation of European Paper Industries (CEPI) has revised its guidelines on Paper for Recycling quality control, with recommendations for Paper for Recycling suppliers and paper mills. The objective of the guidelines publication is to achieve greater harmonisation, to improve the implementation of the EN 643 Standard and to facilitate commercial relationships between paper mills and paper for recycling suppliers.

The revised guidelines put a strong emphasis on the inspection procedure for quality control at the paper mill and explain what controllers should consider during an inspection in order to decide if a load should be accepted, conditionally accepted or refused. After a general control, further important parameters for quality control are named, i.e. bale conditions, moisture control and control of unwanted materials. The control procedure recommended is described in detail and illustrated by a decision tree at the end of the document.

The guidelines give furthermore recommendations on the level of information for suppliers, documentation and staff education.

CEPI will organise a free webinar in the weeks to come, to present the revised guidelines and to answer any questions that may arise.

You can download the publication at: http://bit.ly/1ouOkFm

For more information, please contact: Ulrich Leberle, Raw Materials Director at CEPI: u.leberle@cepi.org, +32 2 627 49 23.
 

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02 Mar.2016 ,

Design and Management for Circularity – the Case of Paper

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.

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.

Read the press release on the topic.

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02 Mar.2016 ,

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.”

You can view the publication at: http://bit.ly/1T7vLVb and download it at: http://bit.ly/1QqTqdt.

For more information, please contact Jori Ringman at j.ringman@cepi.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.

 

 

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