Over-ambitious packaging reuse targets mustn't kill off recycling

We support ambitions to increase reuse. It should be part of the EU strategy to reduce packaging waste, but it should complement the efforts already made — and yet to be pursued — to reduce and recycle packaging, and it should leave room to adapt to changing local contexts and emerging evidence.

We are therefore deeply concerned that the European Commission's draft proposed revision of the EU Packaging and Packaging Waste Directive (PPWD) might set a dramatic and discriminatory new route for our beverages, singling our sectors out and defining reusable packaging as essentially our only path towards circular packaging.

Unintended consequences for recycling

This approach will be disastrous not just for businesses in our sectors, but also for all existing well-functioning recycling systems. It will require scaling back or reversing huge investments made in the past years to achieve circularity of our packaging. Ultimately, it will make our journey towards greater environmental sustainability longer and more complex, with no guarantees of success.

Recycling and reuse are different routes to the same goal.

Both can help bring about packaging circularity, reduced use of virgin material and a lower environmental footprint compared to the status quo.

We should not, a priori, promote reuse at the expense of recycling, especially when relative environmental impact varies depending on multiple factors. Whilst there are situations and conditions where reuse is preferable and indeed already works well, it does not necessarily perform better than recycling. Impact assessments have not established that high reuse targets across the board will positively impact the environment in all cases and for all packaging. Context is key.

In assessing the environmental impact of reusable beverage packaging, many factors come into play, such as the resources required to produce reusable packaging, the extent to which consumer behaviour will change to ensure the containers are actually reused, the carbon footprint related to the transport of returnable bottles and crates, and the energy needed to wash packages before reuse. Impacts will differ between categories — for example legislation requires natural mineral water to be bottled at source, which limits the flexibility of production and logistics.

Let's ensure a level playing field for our beverages

If the proposals from the European Commission only propose reuse targets within the beverage industry, it would also be discriminatory and show a complete disregard for all the pioneering circularity efforts our sectors are already building on.

When it comes to setting reuse targets and obligations for beverages, it would furthermore be incomprehensible and unacceptable for the beer and cider sectors that exemptions be a priori granted for the other alcoholic beverage sectors.

Preventing the use of more virgin material

Over-ambitious reuse targets may also, in some cases, actually increase the amount of virgin material on the market, particularly in the transition phase. Much heavier, reusable beverage containers, durable enough to survive multiple journeys along the reuse chain, will be needed to stock the sector.

Reuse systems can also lead to logistical bottlenecks as they depend on the efficient return of packages by both consumers and retailers. Whilst producers await the return of containers, more packages are needed to fill the gap, necessarily demanding further raw materials for their production.

As for metal cans, the package of choice for many small producers and for on-the-go consumption, these are infinitely recyclable but they currently do not exist in a reusable form. Other materials would be needed to replace them if overly-high reuse targets are to be met for all types of beverage packaging.

A harsh economic blow to thousands of companies

Policymakers should recognise that over-ambitious reuse targets could be economically ruinous for thousands of companies within our sectors. Meeting new reuse targets is not a minor adjustment, but a complete shift in business model and production processes for many producers, in particular SMEs. For example, a PwC report commissioned by UNESDA found that moving towards a market share of 20 percent reusable PET bottles by 2030 would cost EU soft drink makers €19bn.

SMEs — already squeezed by inflation and high energy costs — simply do not have the resources to commit to such massive investments in such a short timeframe. There are thousands of SMEs in our sectors that sell locally, often in rural areas, running just one packaging line. Thousands of jobs in local communities are at stake.

This discriminatory, disproportionate and misplaced targeting of our sectors would be a bitter pill to swallow even if this was the only road to sustainable packaging. But it is not. The draft plan of the commission is currently to require our sectors to go all in on one policy measure while ignoring the progress made on recycling and the effectiveness of many of the systems already put in place to collect and recycle our packaging. It does not make sense.

Ambition needed but the right ambition

We are not advocating for no ambition. In fact, the opposite is true. We are leaders in packaging sustainability and advocating that the foundational vision of the EU Green Deal be upheld: ambitious and evidence-based policy measures which support sustainable growth and jobs and which make sense for our environment.

We know that a combined approach including reducing, reusing and recycling works. Reusable beverage packaging is not the only way.

There is a better path, based on the combination of all available solutions, that is already leading to circularity of our beverage packaging. It should not be undermined. We are therefore looking forward to a supportive and reasonable proposal from the European Commission.