Generic filters
Search in excerpt
x
Become a Member
Become a member
Generic filters
Search in excerpt
x
Become a member
Generic filters
Search in excerpt
x

Category: Position Papers

Posted on

Safety of food contact materials: 20 years of inaction on EU’s basic rules

4 December, 2024

Safety of food contact materials: 20 years of inaction on EU’s basic rules

Subject: Safety of food contact materials: 20 years of inaction on EU’s basic rules

Dear President von der Leyen,

We, the undersigned, are deeply concerned about the current state of the EU Food Contact Materials Regulation revision (EC 1935/2004) due to its significant delay. The European Commission committed to updating these 20 year-old rules to better regulate harmful chemicals in food contact materials (FCMs) as part of the 2020 EU ‘Farm to Fork’ and ‘Chemicals Strategy for Sustainability’ initiatives. While new rules on recycled plastic in FCMs were introduced in 2022, the overall revision of the law is still pending.

FCMs, including food packaging, make up a large segment of consumer goods. Undeniable evidence shows that hundreds of chemicals possessing well-known hazardous properties are intentionally used in these products, made from both plastic and non-plastic materials. For example, more than 70 carcinogens were found in FCMs purchased from markets including the European Union. Thousands of FCM chemicals continue to be detected in human samples, such as urine, blood, and breast milk, with links to serious health effects, particularly for vulnerable populations like children and pregnant women. Many chemicals remain insufficiently tested, and current EU risk assessments do not address their cumulative toxicity.

This regulatory failure is contributing to rising health concerns. The EU is seeing an increase in cancer rates, infertility, and metabolic diseases like Type 2 diabetes. The estimated cost of exposure to endocrine disrupting chemicals, including phthalates and bisphenols found in food packaging, is €157 billion annually.

There is also growing evidence of health risks associated with some alternative materials introduced after the Single Use Plastic Directive. Studies from the Netherlands and Belgium highlight the potential dangers of these materials, making it crucial to harmonise and strengthen EU regulations on all FCMs to ensure consumer safety.

Therefore, along with political demand for long term competitiveness, sustainable circular economy solutions and creation of a strong secondary materials market in the EU, the critical aspect of safety of all food contact materials, both conventional and alternative, virgin and recycled, cannot be left behind any longer.

We thank you for your consideration of this important matter and remain at your disposal for any questions you may have.

Posted on

A New ERA for packaging: how policy can pave the way for sustainable, convenient and efficient reuse systems

21 March, 2023

A New ERA for packaging: how policy can pave the way for sustainable, convenient and efficient reuse systems

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.

Recommendations to enhance the PPWR proposal

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.

Posted on

Packaging Reuse: Maximising the Benefits​

23 October, 2023

Packaging Reuse: Maximising the Benefits​

Introduction

Packaging plays an instrumental role in our modern world. It ensures goods remain unscathed during transit, prolongs t he lifespan of products, contributes to consumer experience and product performance, and serves as a conduit of essential information within the supply chain and to consumers. Yet, despite these invaluable functions, it has become increasingly clear that our current approach to packaging in the European Union (EU) is unsustainable.

The Packaging and Packaging  Waste Regulation (PPWR) proposal draws attention to the staggering figures—packaging accounts for an astounding 40% of all plastic and 50% of all
paper consumption in the EU. Packaging waste constitutes over a third of all municipal waste generated, and despite endeavours in weight reduction, overall packaging waste generation is increasing. The swelling tide is largely propelled by the pervasive use of single-use packaging. While the amount of packaging waste going to landfill has reduced since the early 2000s, it remains significant – estimated at 20% in 2020. In some cases, landfilling of packaging waste has simply been displaced by incineration – estimated at 16% in 2020. The rate of packaging waste recycling in the EU has stagnated since 2010, plus ~17% of all packaging is non recyclable by design. This stagnant recycling rate is despite many industry initiatives and policies on recycling, and means that any improvements in recycling have merely been enough to compensate for the growth in packaging use, not any more than that.

Halting and reversing these trends in material consumption and waste. within the EU’s packaging sector is imperative. Embracing the essential functions of packaging while limiting its environmental footprint necessitates moving from single-use-only, towards the development of reuse in practice and at scale of high-performing reuse systems. This development would enable us to extract utility from packaging over longer periods, concurrently decoupling consumption from material extraction and excessive carbon emissions on the long-term.

Recycling, on its own, is not enough to reduce Europe’s material and carbon footprints at the speed and scale needed to achieve its climate and environmental goals. Nor is the simple substitution of one single-use material for another acceptable – instead the EU should seek to drive genuine circular solutions. Reuse before recycling, therefore, stands as a cornerstone to ensure the sustainability of the EU’s packaging sector in the future. But in a region challenged by finite natural resources, the impetus for reuse in Europe is more than an environmental endeavour; it also embodies a crucial component of an ambitious, globally differentiated and diversified green industrial strategy in Europe, where we lead the way in building the industries of the future. The Commission’s own estimates are that the reuse transition will contribute a net 600,000 jobs to the EU economy by 2030 and have a deflationary impact on the cost of consumer goods. So the reuse transition means a transition away from growth driven by consumption of imported natural resources, towards growth in green jobs and services within the EU, needed now more than ever.

The central role of reuse within the draft PPWR text is therefore a welcome—and essential—inclusion. Setting forth clear and ambitious targets for both 2030 and 2040 is key to providing Europe’s innovators, entrepreneurs, and investors the confidence needed to innovate and invest in the next generation of packaging solutions. The Commission is to be commended for bringing forward these elements in the draft text. With that said, it is imperative to acknowledge that, to maximise the potential of reuse, some further improvements are necessary. In particular, the most optimal legislative framework must be put in place to ensure that the reuse transition is smooth and efficient.

The impetus for reuse in Europe is more than an environmental endeavor; it also embodies a crucial component of an ambitious, globally differentiated and diversified green industrial strategy in Europe, where we lead the way in building the industries of the future.

Maximising the opportunity to benefit from Reuse in the PPWR: Key Principles

As we navigate the pathway towards a more circular packaging future, below are some key principles for maximising the opportunity to benefit from reuse in the PPWR:

Setting high performance criteria
To ensure that packaging —and the wider systems they are a part of—which are labeled as “reusable” truly fit the description, it’s critical that clear requirements be established. These would outline, for example, the minimum number of times a package needs to be reused before it’s counted as reusable.

Sharing responsibility throughout the value chain
Both manufacturers and final distributors are essential to making a reuse system work. Clear obligations throughout the value chain to offer and takeback reusable packaging is essential to fully unlocking the potential of reuse. It is also important to apply targets to manufacturers as well as final distributors, including ensuring that manufacturers meet targets in every Member State they operate in. Consumers also have a vital part to play, as they are the ones needed to ensure their packaging is reused.

Aiming higher to ensure success
It is essential that ambitious targets be maintained, if not increased. High targets, as well as long-term targets, are a prerequisite for incentivising innovation and securing investment in reusable packaging systems. Additionally, targets must be set high enough that the size of the reuse market is sufficient to achieve economies of scale and the resulting efficiency benefits, providing a level playing field. Expansion of sectoral coverage should also be considered in due course, as much of the infrastructure can be shared across sectors.

Always striving to improve
Transparency in reporting for reuse systems is essential, as is a dynamic process of review that enables ambition to be raised as lessons are learned. Having a way to evaluate and report on how well we’re doing with reusables will help us keep moving forward, for example on key performance indicators such as return rates. Coverage should also be expanded to additional product categories on the most accelerated timeline feasible.

Embracing refill’s role
Refill, whereby people fill up their own containers instead of using single-use items, whether at-home or in-store, is a well-proven means of waste prevention and is highly complementary to reuse.

Clear definitions, criteria and metrics
Given the broad range of reuse and refill models, and the big differences between them, it will be crucial set out clear definition of which models are included under the target and minimum criteria metrics that these meet to be counted towards the target, ensuring that they are effective and beneficial.

The European Parliament’s Environment Committee has put forward a number of proposals to strengthen the PPWR text on reuse, but should now move forward to provide decisive leadership in support of the ambitious reuse agenda that Europe needs.

The Future is Reuse

The urgency of the environmental challenges confronting us has reached an unprecedented level, shining a glaring spotlight on the unsustainable nature of our current packaging practices. The status quo is no longer sufficient; a radical shift is imperative—a shift that requires us to embrace and nurture new ways of doing things. Simultaneously, we find ourselves at the precipice of a profound transformation in global materials consumption and
management. Europe’s pivotal role in this transformation is undeniable, as it holds the potential to lead the global transition to a true circular economy.

In this context, reuse has the potential to be a cutting edge of these wider changes, and the PPWR stands as a catalyst, poised to propel the EU toward a future centered on reuse. The EU has the potential to lead the world in the development of the materials, systems, processes, and digital tools needed to deliver our reuse vision.

Posted on

The reuse industry urges EU policymakers to take action and vote for the economical and ecological common sense

5 December, 2023

The reuse industry urges EU policymakers to take action and vote for the economical and ecological common sense

We are writing on behalf of the European reusable and refillable packaging industry, represented by the 8 signatory organisations of this letter, totalising more than 1,700 companies to strongly urge you to support the draft General Approach of the Packaging and Packaging Waste Regulation proposed by Spain the 1st of December, in particular for the restrictions on the single-use packaging market (article 22) and the reuse and refill targets (article 26).

The transition to reuse systems offers economic opportunities for European businesses by reducing our dependence on global supply chains while supporting local economies and contributing to sustainable economic growth. Among some of the positive benefits of reuse systems are: lower inventory costs, energy savings, reduced price sensitivity to rising resource costs, and diminished waste management costs.

This is not theoretical: many companies across Europe are already benefiting from the implementation of re-use systems.

“Since the 1st of January 2023, France has made reusable tableware compulsory for onsite consumption in fast-food restaurants. It’s a technical challenge that we’re delighted to have met in all our restaurants. Since the launch, the results are highly satisfactory: strong consumer support, a positive reorganisation of the way we serve, and a deep satisfaction among our teams that gives meaning to their efforts. Our experience proves that this challenge is not only feasible, but also ecologically and professionally beneficial as it enables us to build customer loyalty. We’re not going backwards.”

– Charlotte Gibaud – Purchase and product development Director at Bioburger (fast-food chain)

“Vytal operates in Germany, which we consider to be the most developed market for reuse in the takeaway sector. In the last four years we have grown to become the world’s largest digital reuse solution in the takeaway industry with more than 7,000 B2B-partner locations and more than 550,000 registered users. Thanks to our own tech platform, more than 7.8 million single-use containers were replaced by Vytal customers. With a 99% return rate and an average return time of less than 5 days, Vytal reduces packaging costs for the foodservice industry and proves the effectiveness of reusable packaging. Based on our success so far, local entrepreneurs from Ireland, Sweden, Luxembourg and other countries are now implementing Vytal’s reusable system across Europe as Vytal franchisees. With support of the German GIZ, Vytal is even being exported to Latin America.”

– Dr. Tim Breker – Managing Director at VYTAL Global (provider of reusable takeaway packaging)

A PPWR with ambitious reuse targets is a unique opportunity for Europe to become the global driver of the circular economy, establishing an unequalled global advantage in knowledge and location for decades to come. Beyond the positive impact on the environment, Europe’s strong position in reusable and refillable packaging will create massive economic value through the export of effective European solutions to the global packaging waste crisis. Boosting reuse systems should also lead to a minimum of 600,000 jobs by 2030, according to the European Commission. This is already the case in Germany, where beverage reuse systems are estimated to employ 150,000 people. According to the latest study “Unlocking a reuse revolution: scaling returnable packaging” of the Ellen MacArthur Foundation, scaling reuse systems could create 11,000 jobs in return logistics in a market like France. These jobs are essentially local and cannot be outsourced outside Europe. Imagine the potential if such systems were deployed throughout Europe.

“Business and society are embedded into and dependent upon healthy ecosystems. Today, taking action on a company’s environmental impact is not only about ethical leadership, but also about questioning our impact on our society’s well-being and its viable future. With a community of over 7,500 companies of all sizes and sectors in 90 countries, including over 360 in France, the B Corp movement and its current international certification standards already list a range of beneficial circular practices. We encourage companies to consider how their different product and packaging choices contribute to reducing the overall pressure on natural resources. Ambitious reuse targets at European level are a positive step forward towards building a more inclusive, equitable and regenerative economic system. In this sense, the B Corp movement intends to accompany the evolution of our economy, reflected in the evolution of our standards. This will involve accelerating circular models, developing the economy of use and functionality, and the emergence of new models with regenerative potential.”

– Augustin Boulot – Director General of B Lab France (business association)

“Biocoop is France’s leading specialist retailer of organic food and products with more than 740 shops and a turnover of 1.5 billion euros in 2022. Since we were founded in 1986, we’ve strived to market our products with the least environmental impact and with a minimum of single-use packaging. As proof of our commitment, refill stations have been available at our shops since we opened, and we completely stopped selling single-use plastic water bottles in all our shops in 2017.

Refill and reuse now account for more than 1/3 of our turnover and 50% of our sales volumes. This is clear proof that the move away from single-use packaging is making progress and is not in contradiction with the goals of business, but is simply helping it to evolve.

By 2025, we aim to achieve 50% of our turnover from selling products without single-use packaging. To achieve this, we plan to accelerate our efforts in several areas:

● Our refill offer: by improving the existing range and phasing out the distribution of certain products sold in single-use packaging. By 2023, certain products in the dried fruit range will only be available in refill format.
● Products available in reusable packaging: we have already sold 5.5 million bottles in reusable packaging since 2020. For wine and beer, 1 product over 5 is sold in reusable packaging. We are currently working on extending the reusable packaging system to other markets in order to offer our customers even more reusable solutions.
● The collection of empty reusable packaging: increase the number of our shops capable of doing so from the 389 currently to 100% by 2025.

As you can see, refill and reuse are an operational and commercial reality for the Biocoop Cooperative. We are therefore hoping for an ambitious European trajectory to support this approach.”

– Tanguy Le Gall – President of Biocoop (retailer)

By adopting a forward-thinking and robust legislation, EU policymakers can accelerate the adoption of reuse systems and create a level playing field with single-use packaging. In doing so, the European Union could bring about a profound and positive transformation that empowers the growth and competitiveness of reuse systems. Legal certainty is essential to unlock investment in reuse and refill business models. These investments aim to drive innovation in the design, labelling, traceability, transport, sorting and cleaning of reusable packaging.

“MIWA is a globally awarded and recognized reusable packaging and refill system. It allows producers and retailers to distribute dry and liquid products from food through pet food to personal care and home care products via reuse and refill while significantly decreasing both material footprint (by 90%) and carbon footprint (by 62%). System is fully certified to meet the highest requirements (including for food) in terms of cost effectiveness, efficiency, hygiene and product protection. A proof of it being MIWA cooperating with 5 large retailers and 4 global brands where consumers can buy known products via refill without compromising on quality.
Up to date over 100,000 consumers have shopped from the system and by the end of January 2024 MIWA will be installed in 40 large supermarkets in Europe (Czech Republic, Germany, and the Netherlands). With data features and traceability MIWA also allows building of a reuse habit among consumers, who can be incentivized via discounts to further reuse their consumer packaging.”

– Ivana Soboliková – Impact Strategy & Investor Relations at MIWA (refill stations designer and operator)

“Since its creation in 1994, ETERNITY Systems has enjoyed constant double digit annual growth to reach + €110 million turnover. The  company collects, transports, repairs, washes and stores more than 750 million reusable containers and packaging a year at 18 European and global centres of its own. It employs nearly 1,500 people in Europe (France, Germany, Spain and Portugal) and North America. R&D and technological developments (automation, Industry 4.0, digital traceability, etc.) are at the heart of the development of reuse. With the opening of one to three centres a year, the Packaging and Packaging Waste Regulation is the response we are waiting for to invest and scale up.”

– Gildas Bouilly – CEO of ETERNITY Systems (industrial solutions for reusable packaging)

An ambitious PPWR that defines clear measures for reuse and removes obstacles to the implementation of these solutions is paramount. However, this is exactly the opposite of what the European Parliament adopted on 22 November. The text is full of derogations and reduced aspirations, and provides an insufficient response to the packaging waste crisis we are experiencing (with a record level of 189 kg per EU citizen every year).

“Through its work, Porto Protocol has created a collaborative network of European stakeholders and beyond, spread across the wine value chain, at various stages of implementing returnable bottle schemes. This collective of companies has been working towards its environmental and economic feasibility, understanding how this solution can be scaled within the complexity of the wine industry. Wineries have experienced climate change, glass scarcity and increased costs of production. Legislation to support the reuse of glass bottles, winegrowers’ container of choice, will provide a myriad of benefits to mitigate this combination of pitfalls: cost savings, increased operational efficiency and waste reduction, allowing wineries to rely less on single-use bottles and reduce its vulnerability to disruptions in the supply chain related to packaging materials. It can contribute to the conservation of raw materials like sand, a finite and highly exploited resource. Ultimately, it can build on the long-term sustainability and resilience of the industry.”

– Marta Mendonca – Manager at The Porto Protocol Foundation (global organisation of the wine
industry)

Considering the imminence of the adoption of the Council's position of the Packaging and Packaging Waste Regulation (PPWR) scheduled on 18 December, we strongly urge you to support the draft General Approach proposed by Spain on December 1st, in particular the restrictions on the single-use packaging market (article 22) and the reuse and refill targets (article 26).

Posted on

Industry Statement on Existing Reusable Transport Packaging Systems: Environmental and Economic Benefits​

22 April 2024

Industry Statement on Existing Reusable Transport Packaging Systems: Environmental and Economic Benefits​

The undersigned associations and companies, representing the reusable transport packaging value chain, urge the European Parliament to maintain the reuse targets for transport packaging used for transporting products i) between sites of the same economic operator or linked/partner enterprise, and ii) within the same Member State, as previewed in article 26.2 and 3 of the Packaging and Packaging Waste Regulation (PPWR).

Recently, various trade associations addressed letters to policymakers requesting the elimination of the reuse targets in the above mentioned use cases. Legislation cannot be shaped by the inaccurate argumentation put forward by those who claim that reusable alternatives to pallet wrappings and straps are not technically possible. These statements contain no evidence and are actually incorrect. There is a wide myriad of reusable transport packaging solutions, including for pallet wraps and straps, as you can see in the Annex below. Change requires innovation and it is entirely feasible to move over to reusable pallet wrappings and straps, as these solutions already exist and are easily scalable. Moreover, reusable transport packaging such as crates, trays and pallets, can be designed to be fully stackable without single-use wrappings and straps.

Transport packaging serves an important role in transporting raw materials and products in-between the many stages of modern global supply chains. They act as a barrier to external elements, allow for safe handling of bulk quantities and provide load stability to their content. For this reason, standards are strict and testing extensive. For example, flexible intermediate bulk containers (FIBCs) have a dedicated ISO-standard (ISO 21898) that specifies the strength and minimum test requirements for such packaging. These norms have already existed for many years, demonstrating its feasibility in practice.

Interestingly, the single use packaging industry’s claims focus solely on eliminating this specific type of packaging, while they advocate for removing the targets across all forms of transport packaging. In addition, it is mentioned that transport packaging will have to be 100% reusable from the entry into force of the PPWR, ignoring deliberately the numerous exemptions established within this category: i) transportation of dangerous goods, large scale machinery, equipment and commodities with custom-designed packaging, ii) flexible packaging in contact with food, and iii) cardboard boxes). This approach is misleading and unacceptable.

Removing paragraphs 2 and 3 from article 26 would also mean removing the low-hanging fruit for Member States to prevent waste, as reuse in the transport packaging sector has already been a trusted option for businesses for over 60 years.

Over the last years, companies have been investing hundreds of millions of euros in developing cost-efficient and environmentally sound reuse systems for transport packaging in Europe. The sector is constantly innovating to provide solutions that remove the necessity for single-use. These investments have led, inter alia, to outperform single-use alternatives in many aspects (Fraunhofer, 2022). In the case of reusable plastic crates, they excel over single-use carton boxes in 15 out of 17 categories, including lower breakage rate, lower greenhouse gas emissions throughout a lifecycle, where optimized transport, number of rotations all play a role, and better material efficiency and recycling rates. In particular, reusable pallet wraps account for up to 90% reduction of greenhouse gas emissions and 95% of waste reduction over 150 uses. Besides, recent innovation has led to improving the reusability of cardboard boxes, boasting its use to at least 6 rotations, significantly reducing the carbon footprint compared to single-use boxes (80 % reduction for transport distances of 50 km, the benefits being also positive for longer distances of up to 1000 km) and with different types of transportation. Last but not least, reusable transport packaging can accommodate a large percentage of recycled material in their composition without compromising integrity, further helping the development of a circular economy for materials.

In conclusion, reusable transport packaging stands as a proven solution embraced by forward thinking companies across various sectors. With established norms ensuring safety and functionality, coupled with its significant positive environmental impact, the case for its widespread adoption is compelling. It is already seamlessly integrated into supply chains, spanning from industrial applications to food and ingredients, with tailored collection and cleaning processes in place. Current reusable transport solutions widely available on the market are not patent protected, which means production can easily scale up to quantities needed once their use is encouraged by legislation. The infrastructure also exists and can be easily scaled as the technology is available.

We therefore recommend maintaining existing targets for reusable transport packaging as agreed during the interinstitutional negotiations of the PPWR.

Posted on

Integrating reuse and refill in the Global Plastics Treaty​

24 April 2024

Integrating reuse and refill in the Global Plastics Treaty

Scientific research on plastics has seen considerable growth, technological innovations in
plastic management have made significant strides, and legislative frameworks have become
more robust over the last years. Yet, despite the increased awareness and efforts, global
plastic production — and the resulting pollution — continue to rise, with an expected 66%
increase in annual virgin plastic production by 2040 compared to 2019. Managing this
growing wave of plastics is proving increasingly difficult worldwide.

Plastic pollution is as a “glocal” crisis where local and global scales are intricately intertwined.
The impacts of plastic waste are felt acutely at local levels, affecting communities,
ecosystems, and local economies. At the same time, the production and distribution of
plastics are part of a vast global network, with materials and products crossing international
boundaries.

We need to move away from the waste-centric view of plastics, where the focus is primarily at
the end-of-life. This approach often leads to an overemphasis on downstream solutions such
as collection and recycling, while overlooking the broader implications of plastic production
and consumption. We advocate for a comprehensive approach that considers the entire
plastic value chain, from raw material sourcing to manufacturing, distribution, use, and
eventual disposal.

Today, between 40 and 50% of plastics are destined for packaging, being also the category
of products that ends up leaked into the environment. This means this sector is one that needs
to be prioritized for having an effective impact in reducing plastic pollution. In this sense, New
ERA advocates for the inclusion of policies promoting reuse and refill systems for packaging
within the treaty.

New ERA has identified five pillars that support the framework for the development of
effective and efficient systems for reuse and refill, enabling it to realize its full potential:

New ERA has identified five pillars that support the framework for the development of effective and efficient systems for reuse and refill, enabling it to realize its full potential:

1) Take-back obligation,
2) incentives,
3) mandatory targets,
4) consumer information, and
5) data collection, monitoring, and enforcement.

Each category provides recommendations based on the best practices of existing European legislation, as well as the insights and experiences from our members who have been operating in the reuse and refill market for years, decades in some cases.

Within the scope of an international treaty, New ERA believes that clarity and adaptability are essential to accommodate various sectors, formats, and differences in consumption patterns, geography, and infrastructure across different countries.

I. Efficient reuse and refill measures

1) Take-back obligation
Final distributors shall be obliged to accept, without charge, all reusable packaging of identical type, form, and size to the packaging they place on the market, within the designated reuse system at the point of sale. To be completely effective, this requirement must be passed on along the entire supply chain to ensure the packaging is duly returned so it can be introduced again on the market after washing/cleaning takes place.

📍 Note: This obligation ensures a high return rate by facilitating the consumer journey, echoing one of the pillars of the German packaging law (1991).

2) Incentives
The implementation of an effective incentive mechanism is paramount to foster a high return rate and encourage consumers to embrace the concept of reuse. Such a mechanism not only motivates consumers to participate actively, but also spurs businesses to integrate reusable packaging into their operations.

📍 Note: The standardized deposit system (for both single use and reusable packaging) implemented in Germany ensures one of the highest collection rates in Europe.

3) Mandatory targets
Establishing overarching quantitative objectives provides clear direction and long-term vision to the market, reducing risk for companies and for financial institutions willing to invest. While these targets can be customized for specific sectors, it is essential that countries have certain extent of flexibility to reflect their specificities and consumption behavior patterns.

📍 Note: Reuse targets are becoming more common across European laws addressing packaging waste. For example, in France, the Anti Waste and Circular Economy Law (2020) sets national reuse objectives: 5% of household packaging to be reused by 2023, and 10% by 2027.

4) Consumer information
Ensuring that consumers are well-informed about the availability of reuse and refill systems is essential for promoting their uptake and widespread adoption. Governments, economic operators and Producer Responsibility Organisations (PRO) have a shared responsibility in disseminating this information to the public. This effort involves implementing various communication strategies, including signage campaigns in-store information
dissemination, and clear labeling practices.

📍Note: The recently adopted Packaging and Packaging Waste Regulation in the EU mandates final distributors to offer and inform consumers at the point of sale about the possibility to bring their own containers via easily readable information boards or signs.

5) Data collection, monitoring, and enforcement
Gathering data and insights is necessary to effectively measure the impact of measures and adjust accordingly. The establishment of an entity, such as an observatory, holds significant promise for monitoring adequate implementation of legislation, mar et dynamics and institutionalising the principles of reuse and refill.

📍Note: The Packaging and Packaging Waste Regulation proposes the creation of an EU observatory. The French Climate and Resilience Law (2021) previews a similar provision.

Standardizing methodologies and calculation methods is essential for facilitating cross-border comparisons and sharing best practices globally. The implementation of sanctions is also crucial to ensure adherence to regulations.

📍Note: Monitoring and enforcement mechanisms are equally critical; they serve as pivotal components in overcoming implementation challenges, as observed in both Germany and France, where they have posed significant hurdles to the effective enforcement of national legislation.

II. Development of the reuse and refill industry internationally

Furthermore, to ensure the development of a robust reuse and refill industry, it is crucial to address the following aspects within the treaty.

1) Establishing a common terminology
It is essential to include definitions* in the treaty’s annex to clarify the terms used throughout the text, including:

    • Reuse: Any process or operation in which an item (e.g. packaging) is used again for the same purpose for which it was originally designed.
    • Reuse System: The organizational, operational, technical, or financial framework, including any necessary infrastructure and incentives, that facilitates and supports the reuse of products such as packaging.
    • Reusable Packaging: Packaging designed and introduced to the market with the intention of being used multiple times. This type of packaging is capable of being emptied, unloaded, refilled, or reloaded, while still maintaining its ability to perform its intended function.
    • Refill: operation by which a container, owned by the end user, is filled by the end user or by the final distributor with a product purchased by the end user.

2) Setting minimum requirements
It is imperative to ensure that reuse and refill are correctly understood and implemented:

    • Clear labeling for consumers: necessary to enable consumers to make informed choices, prevent greenwashing, and facilitate the return of packaging.
    • Design considerations: packaging design should prioritize maximizing the number of rotations and ensure recyclability at the end of life.
    • Safety regulations: rules for reusable packaging should be equivalent to those for single-use items, ensuring consumer protection and compliance with established standards.
    • Minimum rotation requirement: reusable packaging is introduced to the market to ensure it is effectively reused. The system must be designed to ensure that reusable packaging rotating within it completes at least the minimum intended number of rotations.
    • Guidelines for governance: this entails outlining the structure of governance for a reuse system, delineating the responsibilities of system participants, ownership arrangements, and any anticipated transfers of packaging ownership.

3) Financing
There are four main approaches that should be applied and implemented in parallel:

    • Extended Producer Responsibility (EPR) system: a portion of the funds collected through eco-contributions should be allocated to support reuse initiatives and infrastructure.

📍Note: In France, Citeo – PRO in charge of household packaging – is required to allocateat least 5% of its budget to the development of reuse systems and its infrastructure.

    • Government subsidies:  Reuse is not financed yet enough by public organizations as opposed to recycling. This support should encompass a wide range of activities, including but not limited to: infrastructure development, technological innovation, consumer education and awareness, regulatory compliance and standards enforcement.
    • Establishing clear objectives to facilitate financing: setting precise and binding objectives can stimulate private investment and provide market direction offering investors and businesses confidence to invest.

📍Note: The enactment of legislation mandating the incorporation of recycled materials in France made recycling sectors invest €656 million in 2022, representing a 20% increase compared to 2012.

    • Taxes: introducing a tax on single-use plastic packaging could help equalize costs with reusable alternatives.

📍Note: Spain adopted a tax on single use-plastic packaging made of virgin material in 2022. In Europe, there is a levy on non-recycled plastic implemented from January 2021. Each Member State needs to contribute to the EU budget with €80 cents per kilogram of unrecycled plastic packaging waste.

The treaty should serve as a guiding framework and common foundation for each country to embrace the concept and systems of reuse and refill. Subsequently, it is up to each country, within its national plans, to propose systems tailored to its specific circumstances to achieve globally established objectives. It would be highly beneficial to complement the treaty with guidelines, particularly focusing on sectors identified as priorities.

Posted on

Proposition d’introduction d’une taxe plastique dans le cadre du PLF 2025​

24 May 2024

Proposition d'introduction d'une taxe plastique dans le cadre du PLF 2025

Monsieur le Ministre,

Dans le cadre des discussions budgétaires qui s’ouvrent, notre coalition large d’acteurs
économiques et associatifs, souhaite attirer votre attention sur une proposition visant à lutter contre les produits en plastique à usage unique.

Nous proposons la création d'une "taxe plastique", conçue comme une contribution compensatoire destinée à inciter les metteurs en marché à opter pour des solutions alternatives.

En France, malgré une baisse de la production de plastique à usage unique depuis 2020,
la consommation reste élevée, avec une moyenne de 70 kg de plastique par habitant et par an.
La contribution de la France au titre de la ressource propre plastique s’élève en 2023, à 1,3 Md€. La France recycle un peu plus d’un quart de ses déchets d’emballages plastiques chaque année, loin de la moyenne européenne (41,5 % en 2018, selon Eurostat). Elle figure de fait parmi les principaux contributeurs, en deuxième position juste derrière l’Allemagne.

L’impact environnemental est par ailleurs considérable : la production et l’incinération de plastiques pourraient générer près de 56 milliards de tonnes de CO2 d’ici à 2050. Il est donc crucial de mettre en place des mécanismes efficaces pour réduire cette consommation. La “taxe plastique” que nous proposons, qui s’aligne sur des dispositifs déjà existants chez certains de nos voisins européens (c’est le cas de la Suède par exemple), et soutenue par de nombreux parlementaires, vise non seulement à soulager les finances publiques qui pèsent actuellement sur l’État et, par extension, sur les contribuables, mais aussi à responsabiliser davantage les acteurs de l’industrie plastique.

En introduisant cette contribution dans le PLF 2025, nous pourrions envoyer un signal prix fort aux producteurs et inciter à une réduction substantielle de la production de plastique à usage unique. Nous sommes convaincus que cette initiative permettrait de faire progresser la France vers son engagement de mettre fin aux emballages plastiques à usage unique d’ici 2040, conformément à la loi relative à la lutte contre le gaspillage et à l’économie circulaire (AGEC).

Nous sollicitons donc votre soutien pour inclure cette proposition dans les discussions budgétaires à venir et restons à votre disposition pour toute information complémentaire ou discussion approfondie sur ce sujet.

Veuillez agréer, Monsieur le Ministre, l’expression de notre haute considération.

Posted on

World Refill Day: Political parties must act now to prevent runaway levels of plastic pollution​

16 June 2024

World Refill Day: Political parties must act now to prevent runaway levels of plastic pollution​

The world produces 141 million tonnes of plastic packaging a year and around a third leaks from collection systems, polluting the environment.

Plastic’s impact on our planet isn’t going unnoticed. Over two-thirds of consumers agree brands should do more to offer reuse and refill and reduce packaging, with 71 percent saying they would view brands and retailers much more favourably if they took these vital steps.

Many reuse systems have taken place around the world with positive customer acceptance.

From the food and drink on-the-go sector with borrow and return initiatives like Muuse in Hong Kong or Refill Return Cup in the UK, to refillable and reusable packaging in supermarkets by retailers like Carrefour in France or Kaufland in Germany, to brand-led initiatives like Ecover refill stations, industry is trying.

However, legislative change is vital to create a level playing field for businesses to deliver reuse and refill at scale.

Governments globally must implement legally binding reuse targets, supported by a complete ban on unnecessary single-use plastic packaging and full. support for a robust Global Plastics Treaty.

Cutting back on single use isn’t rocket science. Since launching, City to Sea’s Refill campaign has saved an estimated 43 million plastic bottles through simply connecting people with locations where they can refill their reusable water bottles.

The international community has proven that definitive action is possible; however, continued compromise with the plastics industry at successive Global Plastics Treaty negotiations leaves consumers and campaigners frustrated.

Today is World Refill Day and we are surrounded by unnecessary single-use plastic.

The signatories of this open letter are calling on governments globally to protect the planet from plastic pollution by setting legally-binding and time-bound targets to increase the amount of reusable packaging on the market. We urgently need to shift away from our single-use culture to a more sustainable, circular future, with reuse and refill at the centre.

A reusable future is possible. But we need to act now.

Become a Member
New European Reuse Alliance
info@newreusealliance.eu
Avenue Louise 209, boîte 7, 1050 Ixelles, Belgium
X-twitter Linkedin-in
Our work contributes to Agenda 2030:
© 2025
New Reuse Alliance
This website was designed and devoloped by CREATIVA. Contact Info.
Generic filters
Search in excerpt