Our sectors – beer, cider, fruit juices, natural mineral waters and soft drinks – have been pioneers in making progress towards environmental sustainability. We are deeply committed to creating a circular economy by reducing, recycling and reusing beverage packaging. This is a complex task for almost every business.
We support ambitions to increase reuse. This should be part of an EU strategy to reduce packaging waste, but it should complement existing and ongoing efforts to reduce and recycle packaging and leave room for adaptation to changing local contexts and emerging evidence.
We are therefore deeply concerned that the European Commission’s proposed revision of the EU Packaging and Packaging Waste Directive (PPWD) could set a dramatic and discriminatory new route for our drinks, distinguishing our sectors and making reusable packaging inherently circular. identifies as our only path to waste. packaging.
Unintended consequences for recycling
This approach will be disastrous not only for businesses in our sectors, but for all existing well-functioning recycling systems. Achieving the circularity of our packaging will require scaling back or reversing large investments made in past years. Ultimately, this will make our journey to greater environmental sustainability longer and more complex, with no guarantee of success.
Recycling and reuse are different paths to the same goal. Both can help circularize packaging, reduce virgin material use, and have a lower environmental impact than the status quo. we shouldn’t a priori, promote reuse at the expense of recycling, especially when the relative impact on the environment varies depending on many factors. While there are situations and conditions where reuse is preferred and indeed works well, it does not perform better than recycling. The impact assessment did not find that high reuse targets would have a positive environmental impact in all cases and for all packaging. Context is key.
When assessing the environmental impact of reusable beverage packaging, many factors are considered, such as the resources required to produce reusable packaging, the extent to which consumer behavior will change to ensure that containers are actually reused, and the carbon footprint associated with transporting beverages. returnable bottles and crates, and the energy needed to wash packages before reuse. Impacts will vary between categories, for example, legislation requires natural mineral water to be packaged at source, which limits the flexibility of production and logistics.
Let’s level the playing field for our drinks
If the European Commission’s proposals only propose recycling targets in the drinks industry, it would also be discriminatory and completely ignore all the pioneering circular efforts our sectors are already building.
This would be incomprehensible and unacceptable to the beer and cider sectors when it comes to setting drinks reuse targets and obligations. a priori provided for other alcoholic beverage sectors.
Preventing the use of more virgin material
Overambitious reuse targets may also increase the amount of material leaked to the market in some cases, particularly during the transition phase. To sustain the sector, there will be a need for heavier, reusable beverage containers that are durable enough to survive multiple journeys along the reuse chain.
Reusable systems can also cause logistical bottlenecks because they depend on the efficient return of packages by consumers and retailers. While manufacturers wait for the containers to be returned, more packaging is required to fill the void, which necessarily requires additional raw materials to produce.
As for the metal cans that many small producers and on-the-go consumers pack of choice, these are infinitely recyclable, but are not currently available in reusable form. Meeting extremely high reusability targets for all types of beverage packaging will require other materials to replace them.
Heavy economic blow to thousands of companies
Policymakers need to recognize that overly ambitious recycling targets could be economically detrimental to thousands of companies in our sectors. Achieving the new recycling targets is not a small adjustment, but a complete change in business model and production processes for many manufacturers, especially SMEs. For example, a PwC report commissioned by UNESDA found that moving towards a 20 percent market share for reusable PET bottles by 2030 would cost EU soft drinks producers €19 billion.
Already squeezed by inflation and high energy costs, SMEs simply do not have the resources to make such massive investments in such a short period of time. Our sectors have thousands of local, often rural, SMEs operating only one packaging line. Thousands of jobs in local communities are at risk.
This discriminatory, disproportionate and inappropriate targeting of our sectors would be a bitter pill to swallow, even if it were the only path to sustainable packaging. But it is not. The Commission’s draft plan is to require our sectors to go all in on one policy measure, ignoring the progress currently being made on recycling and the effectiveness of the many systems already in place to collect and recycle our packaging. It doesn’t make sense.
Passion is necessary, but the right ambition
We do not support any ambition. In fact, the opposite is true. We are leaders in packaging sustainability and committed to supporting the core vision of the EU Green Deal: ambitious and evidence-based policy measures that support sustainable development and jobs and make sense for our environment.
We know that a combined approach including reduction, reuse and recycling. Reusable beverage packaging is not the only way.
There is a better way, based on the combination of all existing solutions, which leads to the circularity of our beverage packaging. It should not be crushed. Therefore, we expect a supportive and reasonable proposal from the European Commission.