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Recycler’s 6 key recommendations for improving packaging circularity under PPWR

11 September 2023

In view of the European Parliament’s and Council’s positioning on the Commisison’s proposal for a Packaging and Packaging Waste Regulation (PPWR), the European Recycling Industries’ Confederation (EuRIC) calls on the European legislator to support 6 key recommendations for making packaging more circular under the PPWR:

1.       Unequivocally support recycled content targets

2.       Recycled content and bio-based plastics deserve separate targets

3.       Mandatory third-party verification of sustainability requirements

4.       Effective representation of recyclers in EPR and DRS governing bodies

5.       Equal market access for all actors in recycling markets

6.       Voluntary DRS and flexibility in implementation of collection targets

 

  1. Unequivocally support recycled content targets (Article 7)

Currently, plastic recyclers face a massive drop in demand for recycled plastics[1]. More broadly, packaging producers simply lack commitment and incentives to use recycled plastics, mostly due to volatile global oil market prices, directly linked to lower priced virgin plastics. Today in Europe, only 8.5% of post-consumer plastic packaging is recycled into new packaging[2], a very low level considering the 25% incorporation target that will be binding in 2025 for single use plastic bottles (single use plastic directive (EU)2019/904). For environmental protection[3] reasons and planning security (investments in R&D, innovation, recycling capacities), unequivocal minimum recycled content targets in packaging are paramount. Subjecting minimum recycled content targets to a revision clause through a delegated act based on an assessment of availability and prices of recycled materials would undermine predictability and harm investments in innovation and new capacities. Critically underestimating the efficiency of the legislation it must therefore be deleted.

  1. Recycled content and bio-based plastics deserve separate targets (Article 7)

The use of bio-based plastics does not guarantee packaging recycling at end-of-life. Linking bio-based-and recycled content incorporation targets would heavily undermine the scope of recycled content targets. The link between bio-based and recycled content must strongly be rejected. A separate target would make sense, provided that the biobased material is recyclable. Biobased plastic content should only replace virgin plastic content.

  1. Mandatory third-party verification of sustainability requirements (Articles 6, 7, 8 & 13)

Currently, voluntary commitments by packaging producers and self-declaration is not sufficient to attest compliance with EU requirements and doesn’t protect the European industry from unfair competition from fraudulous import. This mechanism does not guarantee compliance with recyclability, recycled content and bio-degradability requirements, as they are becoming binding under EU legislation. Ensuring effective compliance with sustainability requirements through a mandatory third-party verification would ensure a level playing field  for all the EU single market players.

  1. Effective representation of recyclers in EPR and DRS governing bodies (Article 42, Annex X)

With technical expertise on recycling operations, recyclers have a key role to play for the whole value chain in achieving the PPWR targets. Their participation in governing bodies of EPR systems and possible DRS is paramount for ensuring a whole value chain approach, regarding for instance setting EPR fees for eco-modulation. A effective representation of recyclers in governing bodies of EPR schemes and possible DRS is needed for each system put into place by EU Member States.

  1. Equal market access for all actors in recycling markets (Articles 43, 44, Annex X):

Priority access for producers of certain packaging applications regarding specific plastic types has been discussed. It must be strongly rejected as it (1) would breach EU competition law, and (2) undermine drastically the capacity of recyclers to develop, invest and innovate which is necessary to circularity by questionning directly their access to waste to recycle and/or their capacity to set prices coherent with their production costs. A retention of materials would also impede the functioning of an EU single market for recycling, hampering recycled plastics’ competitiveness compared to virgin plastics. For all these reasons, priority access must be strongly rejected.

  1. Voluntary DRS and flexibility in implementation of collection targets (Articles 44, Annex X)

The implementation of DRS should be left entirely to Member States at national level, in order to best adapt the cost-efficiency equation to the existing infrastructure and organisations and be seen as a complementary means to achieve more ambitious collection rates. This regulation must enhance the collection rate of all packaging by putting forward an obligation of results, not of means.

 

[1] No peak season expected for Europe recycling markets in 2023 | ICIS.

[2] Plastics Europe, Plastics – the Facts 2022, October 2022.

[3] Plastic recycling significantly reduces CO2 emissions, energy, and water consumption, cf. EURIC - Plastic Recycling Fact Sheet, 2020; Comparative LCA and Certification, Carbon Trust report for MBA Polymers (2020); Impact Assessment Report accompanying the PPWR proposal, SWD(2022) 384 final Part 1.