Reuse before recycling - this is the short version of the amendment to the packaging waste regulations recently proposed by the European Commission. While there is a broad consensus that this approach makes sense in principle, the details of the specifications provided by the Commission are assessed very differently. While some countries, including Germany, are already implementing corresponding regulations such as the amendment to the Packaging Act, in other places corresponding legislative initiatives are far from advanced.
European interest groups also do not have a uniform opinion on the Commission's proposal. For many NGOs and environmental protection organizations, the announced reuse quotas do not go far enough, while representatives of the packaging industry see them as excessive and counterproductive. "Reuse is generally placed at the top of the waste hierarchy after avoidance. New reuse systems will save many times more packaging, but the systems have to be set up from scratch or even established in most countries," says Pacoon Managing Director Peter Désilets. However, there is still a lot of information work to be done: "When we talk to interested parties, they naturally think first and foremost of today's pooling systems, which are riddled with errors, and everyone immediately thinks of many reasons why reuse should not work. When we then explain to them what future reuse will look like, it makes sense to many and offers enormous potential - a multi-billion market is just emerging here with huge savings potential."
Missing the mark?
Because, the argument goes, there is currently no reuse infrastructure at all for many packages. If companies have to build one very quickly, that will result in less money available for recycling systems, he said.
"Disproportionately high targets would lead to the dismantling of a number of highly effective existing recycling systems," complains UNESDA, the Brussels-based trade association of the European beverage industry, in a statement.
Apart from glass and PET packaging, there are currently hardly any reuse systems for food. If the reuse requirements are too high, the industry fears that it will have to do without many ecologically sound materials, such as packaging made from renewable raw materials. Although these can be recycled very well, they are difficult to reprocess for reuse, especially if they are to come into contact with food.
Hygiene as a sticking point
"The proposed Reuse targets are worryingly high, especially in the contact-sensitive sector, where packaging fulfills an essential protective and hygienic function," accordingly judges Francesca Stevens of EUROPEN, the European Organization for Packaging and the Environment, a lobby group for the European packaging industry. In addition to the food sector, she says the pharmaceutical industry would also be particularly hard hit.
Dorota Napierska of the NGO Zero Waste also admits that there is currently no infrastructure for many packages to meet the required reuse and recycling quotas. However, she adds: "Nevertheless, these quotas are necessary. Without them, the risk is far too great that industry will never begin to design safe and recyclable packaging, but will simply continue as before." Besides, he said, the targets have already been lowered anyway. Pacoon CEO Peter Désilets has been involved with reuse packaging concepts for a long time and says, "A lot of fears are based on false assumptions based on the current status quo of reuse packaging. Yes, there is a lot of investment to be made, but do I want to invest in a recycling system that has been proven not to work and, even with new recycling technologies, will only gloss over many problems? Or in a system that is a permanent solution in many areas? There will be products for which reuse doesn't make sense, such as durable products that sit in stock for years, like electrical appliances and accessories. But there has also been proven packaging for touch-sensitive products for a long time. It is also wrong that only reuse packaging travels long distances. The transport distances of disposable packaging after opening to the finished recyclate are several hundred, in the case of exports even thousands of kilometers. In contrast, Reuse is almost a neighborhood model," says Peter Désilets.
Lowered targets
What is actually true. Following criticism from the packaging industry, for example, the reuse quota to be achieved by 2030 for hot and cold beverages has been halved from 30 to 20 percent, and the targets for packaging for takeaway meals have also been halved, from 20 to 10 percent.
Germany, meanwhile, has already taken the first steps towards achieving these figures. Since the beginning of the year, many establishments above a certain size that offer takeaway food have been obliged to offer a reusable variant alongside plastic-based disposable packaging at the same price. However, many micro businesses such as snack bars and kiosks remain exempt from this obligation.
However, Europe still has a long way to go to achieve the circular economy formulated as part of the New Green Deal. Currently, more than one-third of packaging waste across Europe is not recycled, but ends up in landfills, incinerated or disposed of illegally. The per capita quantities, however, are increasing massively and are now around 180 kilograms per year. If no countermeasures are taken, this figure will rise by around twenty percent by 2030, and plastic packaging waste is even expected to double. However, the EU's declared goal is to reduce packaging waste by 15 percent per member state and per capita.
Not harmonized
Even though the EU is trying to harmonize the packaging sector within Europe, including through such laws - the picture that presents itself in the various countries is anything but harmonious. The regulations for registering packaging, labels, reporting in the national waste management systems and possible sanctions for violations of labeling obligations alone are almost a science in themselves. Peter Désilets knows this very well; his agency has recognized this problem and repeatedly denounced this tangle in recent years. That's why they have published a compendium of registration and labeling requirements for European countries and the U.S. "We spent months researching with partners to produce a useful overview. The result is a 42-page summary of all the key regulations for 31 countries." The compendium can be purchased in German or English via Pacoon's website. But Peter Désilets also sees his own experience of working on the compendium as a mandate to stakeholders in the packaging sector and legislators: "It is not very conducive if each country creates its own labels, the use of which is then still partly prohibited among countries. As a design agency of internationally distributed products, we see a chaos of labels as a result, which the consumer will also no longer be able to see through. It is therefore urgently necessary to streamline and harmonize the labels. As packaging designers, we have also known for many years that a label can only communicate limited information. So much information is packed into a small space here, which then finds a place somewhere on the back of the package anyway. But then, please, no insane label like the one on plastic-coated beverage cups, where a 4-color notice has to be printed on, but a barely visible embossing is then sufficient for plastic cups." Désilets suggests other solutions: "Instead, it would be better to collect the paper cups separately and recycle the fibers, as happens with beverage cartons. But there have also long been solutions for fiber containers without plastic for the to-go sector, which could be recycled relatively easily - if you collect them properly."
At a glance
Amendment to the Packaging Ordinance Final distributors of disposable plastic food packaging and disposable beverage cups are required to also offer the goods offered in this packaging in reusable packaging. From Jan. 1, 2023, this obligation will also apply to fast food and meal-to-go catering.
Reusequotas from the EU Commission In November, the EU Commission proposed reuse quotas for packaging, which are now to be discussed in the European Parliament and the Council of Europe and made into law. Among other things, the proposal provides for:
- For hot and cold beverages, a reuse quota of 20 percent by 2030 and 80 percent by 2040.
- For take-away meals, a reuse quota of 10 percent by 2030 and 40 percent by 2040.
- E-commerce companies must achieve a reuse rate of 10 percent by 2030 and 50 percent by 2030.
