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5 December, 2023
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).
