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New Reuse Alliance
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21 March, 2023
The New European Reuse Alliance (New ERA) represents the interest of economic operators that offer, use and promote reusable packaging systems, services and/or products across Europe, and who share an aim to create a low-carbon circular economy for packaging with safe, convenient and sustainable packaging solutions.
Reusable packaging is in general a more sustainable choice compared to single-use packaging. Research shows that when scaled effectively, reuse systems have (1) a lower carbon impact per use, (2) higher resource efficiency per gram, and (3) lower likelihood of contributing to mismanaged waste such as littering. It is therefore correctly identified by leading organisations such as WWF and Ellen Macarthur Foundation as critical to addressing the current environmental crisis. This is also confirmed by leading coalitions of private sector economic operators, for example the Global Commitment 2022 endorsed by more than 500 organisations (>350 companies) and the Plastic Pacts signed up in many European countries.
While niche examples can always be found where a reuse system may not be the most effective environmental choice along one of the environmental parameters (carbon impact, plastic use, water use, etc.), in general reuse is always more favourable. This was recognised at the presentation of the European Commission’s proposal for a regulation on packaging and packaging waste (PPWR) by Executive Vice-President Frans Timmermans: “We cannot recycle ourselves out of a growing stream of waste. And reusable packaging, in a well-functioning reuse system, is better for the environment than single-use options”.
Reusable packaging systems do not face a level-playing field: producers and users of
single-use packaging do not pay for the environmental impact of their products.
Existing extended producer responsibility and other systems do not adequately level the playing field. New ERA therefore welcomes the PPWR proposal. The proposed approach to set mandatory reuse and refill targets for some packaging sectors where reuse solutions have been demonstrated to be feasible is considered balanced and fair, although we believe there is scope for more ambitious targets in certain market segments and beyond, based on the demonstrated best practice examples.
Overall, this proposal represents a great opportunity to establish the conditions for the uptake of reusable packaging and provide legal certainty that will accelerate the development of the infrastructure needed to build robust, cost-effective and environmentally sound reuse systems.
Based on the experience of our members, in the following pages we would like to address some concerns and gaps in the PPWR proposal, with the objective of contributing constructively to a successful regulation.
1. Reuse and refill targets
New ERA strongly supports the introduction of mandatory reuse and refill targets for sectors. We believe the proposed approach to set mandatory targets for some packaging sectors where reuse solutions have been demonstrated to be feasible is balanced and fair.
Nonetheless, the proposal refers indistinctly to reuse and refill targets for food and beverages in sales packaging, leaving the choice to the operator to meet the objectives either by implementing a system for reuse or enabling refill. As recognised in the definitions on article 3, reuse and refill are different approaches to packaging. Refill means an operation by which an end user fills its own container. In this sense, the container is not a packaging but a consumer owned product. Therefore, the action of refill by a consumer should be considered as a measure to prevent packaging waste prevention. On the other hand, reuse means an operation by which a reusable packaging is used again for the same purpose for which it was conceived. In this sense, reusable packaging is an asset owned by the system operator, which ensures it is collected, washed and refilled.
New ERA considers that reuse and refill targets should not be mixed up in order to avoid the risk of huge margins of error and unreliable data. There are clear differences and distinct levels of maturity of data collection between both and they target two different levels of the waste hierarchy, which is particularly important when it comes to implementation and enforcement of the measures.
The main issues arising from mixing up reuse and refill targets are:
● different calculation methods and metrics. Reusable packaging in systems for reuse is easily traceable by units with a serial number. However, it is very difficult to measure refill through consumer owned products. Combining both targets will lead to a huge margin of error and not robust data.
● challenge for market operators to guarantee that the reuse/refill targets are being reached with single use packaging being provided on the side (even if not for free). This could risk erroneous inclusion towards the reuse/refill targets, which will make the data even less reliable.
New ERA is currently working with its members who are active in the market segments covered in article 26. We can provide more detailed feedback upon request to demonstrate the appropriateness and feasibility of the targets for each sector and specific issues that should be clarified per sector.
As an example, we would like to highlight the case of reusable transport packaging. Transport packaging (including flexible versions) can be reused, significantly reducing waste generation and with a much lower CO2 footprint (evidence can be provided on request). We believe the reuse targets should be material neutral, without exemptions for cardboard packaging. Providing an exemption will encourage the switch to unsustainable single-use cardboard-plastic composite alternatives. These have a higher carbon impact and cannot be recycled without separation. This has been extensively documented, for example by the NGO NABU.
We therefore recommend removing specific reference to plastic in Article 26, paragraph 7 and the exemption for cardboard in article 26, paragraphs 12 and 13.
For demonstration:
2. Rethinking refill and recognition to sale in bulk
The term “refill” should be redefined as “bring your own”, because the ownership of the container is what differentiates this concept from reusable packaging systems. The term “refill” can lead to confusion as reusable packaging returned by consumers is refilled as well before it is being reused. In addition, there should be a recognition of the “sale in bulk”, including a new definition in article 3:
“Sale in bulk” means the commercialisation of products free-of-packaging in quantities chosen by the consumer and filled in reusable containers either provided at the point of sale by the retailer or brought by the consumer. Bulk sales can be offered on a self-service or assisted service basis in ambulant points of sales. Any product can be commercialised via bulk systems, except for justified public health reasons.
Considering the products permitted of commercialisation in bulk systems, mineral water, pasteurised and UHT milk, foods for infants and other groups, dietary supplement and frozen product should be allowed, as there are no justified public health reasons, as it is explained in the contributions made by New ERA, in the frame of the TRIS procedure, to the French decree establishing the list of products for which sale in bulk is prohibited for public health reasons.
In addition, the proposed requirements for refill stations are too restrictive. The proposal requires that economic operators offering refill containers need to introduce “refill stations” that include weighing devices. However, take-away beverages and food
prepared on the spot for immediate consumption are mostly sold by the unit, not by weight (e.g. coffee). This requirement places a disproportionate burden on operators allowing customers to bring their own containers. By default, economic operators preparing cold and hot beverages and food for immediate consumption on the-go should enable consumption by “bring your own” containers. Exceptions should be justified.
Furthermore, in order to accelerate the deployment of refill systems and to prevent packaging waste, we recommend adding a target for retailers to dedicate 20% of their space to refill stations or sale in bulk by 2030 if their premises are bigger than 400m2. Certain retailers can benefit from justified exemptions.
3. Role of Extended Producer Responsibility (EPR) schemes
New ERA welcomes the proposal to switch legal instruments from a Directive to a Regulation implying greater homogeneity and avoiding fragmentation of the single market. However, the PPWR proposal misses the opportunity to create homogeneity within systems for Extended Producer Responsibility resulting in a significant fragmentation of the EU single market. As one of the main financial instruments to incentivise reuse, this is critical to address in order to bring more legal certainty to economic operators across the EU. This is in particular a challenge for European SMEs that must invest significant resources understanding multiple different EPR systems.
Furthermore, the PPWR proposal does not sufficiently address the importance of EPR schemes to incentivise reuse, as the focus is currently on design for recycling and recycled content. In our view this is a missed opportunity. We therefore recommend the PPWR be strengthened by:
● ensuring that economic operators switching from single use to reusable packaging could get a reuse bonus within the eco modulation requirements.
● requiring EPR schemes to use a proportion of the funds generated to provide a fund to accelerate the transition on reduction and reusability. An example is the French model established with the Food waste prevention and circular economy Law, which gives a mandate to Citeo (French EPR for household packaging) to invest 5% of their annual budget towards this goal.
● requiring closely aligned EPR systems to avoid fragmentation of EU single market, for example, defining the magnitude of eco-modulation (% increase or decrease for reuse, design for recycling and recycled content).
4. Design for recycling
New ERA strongly supports the requirement specified in article 6 that all packaging should be recyclable, including reusable packaging. Only in this way can we ensure that packaging can be recycled to provide the raw material required to meet the recycled content targets specified in article 7, including for reusable packaging.
However, we are concerned that the current approach will not deliver this objective. Although the proposed PPWR specifies that all packaging must be recyclable, the target level of recyclability (70%) is low and imprecise. We propose to tighten the recyclability requirement by raising the minimum recyclability performance grade to Grade C (>80% recyclability).
5. Standardisation of reusable packaging
The proposed PPWR barely refers to standardisation when announcing that the European Commission will ask the European standardisation organisations to come forward with harmonised standards for reusable packaging. Today, there are no existing standards for reusable packaging at EU level, although there are some ongoing discussions within CEN-CENELEC to establish rules for reusable plastic tableware (e.g. plates, trays, cups, dishes, glasses, bowls, etc.).
The diversity of packaging formats and materials is so large that asking the competent authorities to develop mandatory standards of reusable containers is nothing but a cyclopean task. Rather, the European standardisation bodies should focus on elaborating standards on the characteristics for well functioning reuse systems. It is important that they do not start the work from scratch, but consider the dialogues on the topic that are taking place among public-private stakeholders at international level (e.g. PR3 Standards).
Voluntary standards on certain reusable packaging systems will also play an
important role in supporting the scale up of reuse systems at local and EU level. The agreements made between industry players should not leave none behind, and hence, SMEs must participate in the discussions to avoid the standards being a burden instead of an opportunity. For instance, Citeo published guidelines to develop standards of reusable packaging for the HORECA, fresh products and beverage sectors in October 2021. Besides, operators of reusable packaging shall be given the choice -and not the obligation- to apply the standards, as long as interoperability of the systems and fair access to all players is guaranteed.
6. Deposit-return systems
As underlined by the OECD in its last circular economy report, DRS has proven effective in increasing collection rates and reducing littering. DRS is the reference scenario to reach the 90% recycling target for plastic bottles and cans. It is one way of increasing performance, not the only one. Indeed, DRS is one way to implement an EPR policy and can lead to synergies, as it can improve the quality and quantity of recycling, enable reuse systems and incentivise eco-design. DRS also helps to address littering and influence consumer behaviour, which is difficult to address with other mandatory EPR policy instruments.
For example, in Estonia, after the introduction of a DRS for beverage containers, the share of beverage containers amongst littered items along roadsides dropped from 80% to below 10% (Global Deposit Book, Reloop, 2022). In Germany, the share of beverage containers amongst total litter dropped from 20% in 1998 to “almost zero” two years after the introduction of a DRS on one-way beverage containers in 2005.
In this perspective, minimum requirements on DRS within the PPWR should help to achieve the targets on recycling, reuse and recycled content by material or type of packaging.
DRS can be helpful for enabling reuse of packaging by giving consumers an incentive to return products, thus facilitating the necessary physical movement between consumers and producers. In addition, the return of products needs to be made easy and possible by adequate and accessible logistics for consumers. We therefore ask to include a mandatory measure on DRS and reusable packaging with a clear timeline to move to systems which accept reusable packaging.
Finally, regulation should clearly define the scope of a DRS in the context of other EPR instruments and establish which products are subject to which programme, to avoid potential “double coverage” or unintended substitution effects. Policies that define the scope of a DRS based on certain materials leave more opportunity for producers to change materials in product design to avoid participation. Policies that instead specify the scope based on product groups may be better suited to avoiding possible substitution effects.
7. Labelling of packaging
New ERA supports harmonisation of labelling requirements as laid out in Chapter III of the proposed PPWR. However, we believe that transport packaging should not be exempted from this requirement. Although transport packaging does not end up in the municipal waste stream, challenges remain in the adequate separation of business waste streams. Harmonised labelling requirements will help to address this.
As an example, one of our members is providing reuse solutions for transport using packaging made from recycled materials. Making the recycled material of the correct quality is undermined by a lack of information regarding the material composition of such packaging from other suppliers. A requirement to indicate the material composition on all packaging, including transport packaging, will address this challenge.
