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New PPWD: Legislation for the past or for the future?

Analysis of the new proposal of the EU on Packaging and Packaging Waste Directive (PPWD)

On December 2, the European Commission (EC) proposed a new legislative proposal aimed at amending the waste directive and pushing the EU towards a circular economy. However, if the text of the proposal for the Packaging and Packaging Waste Directive (PPWD) is analyzed in detail, people will doubt whether the proposal will be enacted in 2030 or 2010.

Taking effective action in the packaging sector is both important and urgent. This incident is caused by many reasons;

The absolute value of packaging in terms of volume and weight is increasing. From 2000 to 2015, the share of plastic packaging increased by 5% every year, and now the market share is 25%. Most packaging is only used once; 95% of the value of plastic packaging materials is lost after one life cycle. Once it becomes waste, most packaging (Especially plastic but not entirely plastic) are usually disposed of instead of being recycled. Marine litter is a global problem, 80% of which is made of plastic packaging. By 2050, the plastic in the ocean may be more than fish. many.

In addition, current packaging recycling programs in Europe are often inefficient. In a study we published in 2015, we proved that 70% of urban waste in Europe is product waste, that is, not biological waste, and 45% of it is not covered by the Extended Producer Responsibility Program, which can only be successfully collected separately Of 18%. As a result, the recycling system performs poorly, causing most product waste to end up in the environment, landfill or incinerator.

With this in mind, the European Commission put forward a proposal in December 2015 aimed at creating an “economy that maintains the added value of products for as long as possible and almost eliminates waste”. When the product reaches the end of its useful life, it retains the resources in the economy so that they can continue to be used for production purposes and create more value."

Therefore, one would expect that the goal of the revised Packaging and Packaging Waste Directive (PPWD) is to increasingly retain this value, and we seem to be very inefficient in maintaining this value.

If we look at the EC's current proposal to modify PPWD, we will find that it mainly proposes two things;

First, it shows that preparing for the recovery rate can be counted as a contribution to the recovery effort. One can understand the political reasons behind this move and help those countries that will see their recycling rate decline use new suggested methods to explain their goals, but technically, this is an objectively bad idea because it will Mixing apples and pears will not help bring clarity and legal protection to the recycling industry and public authorities. If EC wants to increase the reuse of packaging, it is best to set a separate preparation for the reuse target.

Second, compared with the 2014 proposal, the preparation target for reuse and recycling has been reduced by 5 to 15 percentage points, although the proposed target is still higher than the 1994 PPWD directive. All in all, this is welcome, but if preparations for reuse will be counted together with recycling, it is likely that many countries have achieved recycling targets today.

However, before ranking the level of ambition of the EC proposal, we need to narrow down and ask ourselves a simple but important question; if the purpose of the legislation is to promote the establishment of a circular economy, so as to maintain the added value of the product for as long as possible... …Are the proposed measures appropriate?

Unfortunately, the answer is no. The current proposal applies to the discussions that we had during the revision of the Waste Framework Directive 10 years ago, which aimed to "transform the EU into a circular society", but does not apply to discussions in the 2016 circular economy discussion framework.

Many stakeholders, including EC itself, recognize that the true added value of products and resources lies in prevention and reuse operations. A very simple example; if we recycle a mobile phone, the value of the material we extract will not exceed 2 euros, and if we repair and resell it, we may get hundreds of euros. In this sense, the proposal to amend PPWD is not to legislate for the future, but to legislate for the past. Where are the suggestions for reducing packaging waste? How to increase packaging reuse? What is the deposit plan? By focusing primarily on recycling, EC has made the same mistakes of the past few decades; working at the bottom of the hierarchy and ignoring the greatest potential benefits at the top.

Another sign that the proposal is being enacted is that it does not address current market developments. The fastest-growing packaging waste stream is composite packaging (multi-layer packaging, pouch packaging, etc.), which is growing at a double-digit rate every year. They are difficult to collect and even more difficult to recycle, but they are not included in the instructions. On the other hand, we see the rise of online shopping, which includes a large number of packaging that manufacturers like Amazon put into the EU market, but they are not responsible for this... In addition to tax evasion, these companies have also received another This is a competitive advantage by transferring responsibility for the management of its packaging waste to public authorities. Where is the EU's action in this regard? What about coffee capsules? They are a problem today and will continue to grow in the coming years. Legally speaking, they are not even considered packaging! The proposal we need is not for past legislation, but for European legislation that we will propose in 2025 and 2030.

The basic components that make PPWD suitable for a circular economy

If the goal is to build a circular economy to preserve the added value in the economy, then EC should consider at least four tools:

We need to stop the growth of packaging waste in Europe. This means that there should be prevention goals. In my opinion, these goals do not need to solve the entire problem of packaging waste, but need to target specific waste streams, and at least have plastic packaging prevention goals.There are three reasons for this; plastic packaging is the stream with the lowest recyclability and recycling rate, it is the fastest-growing stream of packaging waste, and a major issue for the marine environment and human health. In addition, due to its light weight, it is difficult to compare with metal, paper and glass. The EU is developing a plastic strategy that needs to solve the problem of plastic packaging. Why not start here?

The current PPWD directive already includes a prevention goal for disposable bags, focusing on reducing the number of plastic bags, rather than solving the flow problem by weight. Similar methods can be used to set prevention goals for plastic packaging.

2. Separate targets for reuse

If there is a recycling target, there may also be a separate target to prepare for reuse or any other promise to return the refillables to Europe. Otherwise, there will be a paradox, that is, by trying to achieve recycling targets by weight, member states may decide to dismantle existing packaging reuse programs. In the past few decades, the European refillable and reusable packaging market has been relentlessly shrinking, and without clear signs and guidance from the EU level, nothing can encourage the government to believe that this process can be reversed or even stopped. . The current PPWD already contains good wording about packaging reuse, but it still lacks the means and goals to make it possible.

3. Adjust the EPR fee according to the "circulation" of the product

There should be a clear feedback mechanism linking waste to product and process design. In a circular economy, waste and inefficient use of resources anywhere in the value chain should be transformed into direct costs for the enterprise. In other words, for producers and consumers, products that are less durable, reusable or recyclable should be more expensive than recycled products. One way is to use the adjustment fee in the extended producer responsibility plan, because it is used in some cases, such as French paper. Fortunately, the current proposal to amend the waste framework directive already covers this option, but we need stronger legislation to provide producers with clear signs and legal protection.

4. More and better recycling, but as a last resort

Recycling is very important as the final stage of the circular economy, but it cannot be done alone. Yes, we need more recycling. Yes, we need a separate recycling target. Yes, we need to set a separate recycling target for composite packaging. Yes, we need a more direct and enforceable legal formulation, but only by Recycling does not bring about a circular economy.

All in all, the effectiveness of the new PPWD will be judged based on two parameters; on the one hand, measures to solve the problem of plastic packaging, and on the other hand, measures to support reusable and refillable packaging. Currently missing and need to be introduced in the joint decision-making process.

Due to the economic benefits behind disposable packaging, disruptive legislation in this area is not easy, but if Europe is serious about becoming a circular economy and combating marine pollution, it needs to stop looking back at the past and start legislation for the future.

The speech was delivered at the Packaging and Sustainability Forum on February 3, 2016.

"An economy that preserves the added value of products for as long as possible and almost eliminates waste."

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