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position papers
29 Mar.2017

Joint letter on alignment of Renewable Energy Directive with the Circular Economy Policies

TO: Members of the European Parliament ITRE Committee

Subject: Alignment of the revision of the Renewable Energy Directive with the Circular Economy Policies

Dear Members of the ITRE Committee,
Ahead of the report of the ITRE committee on the revision of the EU Renewable Energy Directive (RED II), the undersigned organisations, representing plastic and paper recyclers and zero waste associations around Europe, would like to bring to your attention our concerns as regards to inconsistency of the Commission’s proposal in RED II with the Circular Economy policies and the EU’s climate policy agenda.

This is due to the consideration of the biomass fraction of mixed municipal solid waste as a source of renewable energy when it is actually burning thanks to other materials (e.g. plastics and paper). Member States are consequently allowed to support various forms of energy generation from waste, to meet targets set under the RED II. These schemes which support waste-to-energy generation from mixed municipal waste, run counter to the EU’s transition to a low-carbon and circular economy, furthermore this would work to:

1. Undermine the Waste Hierarchy and the Circular Economy policies
Financial support for waste-to-energy from mixed municipal waste subverts one of the cornerstones of the EU waste policy – the waste hierarchy -, which establishes an order of priority in waste prevention and management i.e. prevention, preparation for re-use, recycling, other recovery (energy recovery), and disposal1. Waste is therefore meant to be firstly prevented, then prepared for reuse and, finally, recycled. Conversely, the RED II classifies it as a source of ‘renewable energy’ and allows renewable energy support schemes that conflict with the waste hierarchy by encouraging waste-to-energy processes, which is the second least desirable option of the waste hierarchy.

The effect so far has been a clear distortion of the market whereby investment in waste infrastructure and operation costs are organised on the basis of subsidies for the extraction of energy from waste instead of sound environmental and economic performance of the best waste management option. As a result, several European countries e.g. Denmark have overinvested in energy-from-waste plants whilst underinvesting in recycling facilities.

2. Undermine the Communication on Waste-to-Energy in the Circular Economy
The RED II also contradicts the Commission’s recent Communication on the Role of Waste-to-Energy in the Circular Economy which states that public financing of waste management, whether national or at EU level, should be consistent with the waste hierarchy and Member States should phase-out public support for the recovery of energy from mixed waste in line with the separate collection obligations and more ambitious EU recycling targets proposed in the legislative proposal on Circular Economy2.
1 http://ec.europa.eu/environment/waste/framework/pdf/guidance_doc.pdf
2 http://ec.europa.eu/environment/waste/waste-to-energy.pdf

3. Undermine the EU’s Climate Policy Agenda
The Commission’s proposal also undermines the EU’s climate agenda by supporting energy generation from mixed municipal waste, which is never solely composed of biogenic carbon. Much of the calorific value from waste-to-energy processes from mixed waste (incineration, pyrolosis or gasification) comes from the treatment of fossil carbon based materials such as plastics. For example, a typical waste incineration facility has a carbon intensity of approximately 600 kg CO2 eq. per MWh of electricity. This compares with a figure of 380 kg CO2 per MWh of electricity at an efficient natural gas power station using Combined Cycle Gas Turbine technology3.
Moreover, the monitoring of the amount of the proportion of organic waste compared to the amount of fossil-based waste in municipal mixed waste is both logistically and technologically difficult. It’s often assumed that the proportion is 50% - even if industrial and commercial waste is frequently included in the mix of waste entering a waste-to-energy facility. Given the heterogeneity of waste and the great differences from plant to plant, this percentage is neither constant nor reliable, which supports the evidence that much of the so-called renewable energy from waste-to-energy comes in fact from incinerating fossil carbon based materials.

The undersigned organisations therefore urge the members of the ITRE Committee to align the Commission’s proposal for a revised Renewable Energy Directive with the circular economy policies by explicitly excluding primes of subsidies for waste-to-energy generation from the mixed municipal solid waste.

Kinds regards,
On behalf of signatories
Joan Marc Simon
ZWE Executive Director
Contacts:
Janek Vahk, Development and Policy Coordinator, Zero Waste Europe: janek@zerowasteeurope.eu
Ulrich Leberle, Raw Materials Director, The Confederation of European Paper Industries: u.leberle@cepi.org
Antonino Furfari, Managing Director, Plastics Recyclers Europe: antonino.furfari@eupr.org
3 https://www.zerowasteeurope.eu/downloads/the-potential-contribution-of-waste-management-to-a-low-carbon-economy/

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22 Mar.2017

Position Paper on LULUCF

CEPI position on the Commission proposal for a regulation on the inclusion of GHG emissions and removals from LULUCF into the 2030 climate and energy framework

Main Goal:

The main goal for the European pulp and paper industry in the debate on climate change and forestry is to work on a policy framework enabling the long term sustainable management of European forests. This is in line with the conclusions of chapter 9 of the 4th Assessment Report of the International Panel on Climate Change (IPCC): “In the long term, a sustainable forest management strategy aimed at maintaining or increasing forest carbon stocks, while producing an annual sustained yield of timber, fibre or energy from the forest, will generate the largest sustained mitigation benefit.”

Main Concern:

The main concern of the European pulp and paper industry is that proposals for the inclusion of GHG emissions and removals from LULUCF focus on the 2030 horizon and forest sequestration. Meanwhile the potential of the other aspects of sustainable forest management such as the absorption of carbon by more dynamic forest management and storage and substitution of wood products replacing fossil based ones would not be sufficiently recognised and harvesting levels would be reduced.

The European pulp and paper industry is a key contributor to the bioeconomy. It uses wood from sustainably managed forests to produce renewable and recyclable products which substitute more carbon intentive products.. In addition, the European pulp and paper industry produces bioenergy with highly efficient combined heat and power generation. Further increasing the efficiency of the wood use, the industry is developing new products based on wood to grow the bioeconomy and even more substitute fossil based materials. The mitigation potential could be further improved by further supporting the growth of forests, dynamic forestry and the mobilisation of wood, the use of wood-based products, high value added products, the cascading use principle and strengthening innovation in new bio-based products.

Accurately accounting the emissions/removals from the sector is crucial to demonstrate that European forests and the use of its products have a positive contribution to climate change, as forests absorb carbon from the atmosphere and sequester it. Harvested wood products store carbon and substitute fossil based products. Along the chain, wood, harvesting residues and industrial residues are also used to produce bioenergy substituting fossil fuels. (Replacing fossil fuels by bioenergy is an interim target on the way to bio-based value chains creating high value added from products, materials and fuels.)

In the last decades, forests in Europe have been growing both in surface and in growing stock. Looking ahead, Chapter 9 of the 4th Assessment Report of the IPCC states: “In the long term, a sustainable forest management strategy aimed at maintaining or increasing forest carbon stocks, while producing an annual sustained yield of timber, fibre or energy from the forest, will generate the largest sustained mitgigation benefit. Most mitigation activities require up-front investment with benefits and co-benefits typically accruing for many years to decades. The combined effects of reduced deforestation and degradation, afforestation, forest management, agro-forestry and bioenergy have the potential to increase from the present to 2030 and beyond”. The combined climate change mitigation effect should be maximised. Therefore disproportionate measures on one of these elements should be avoided.

In this context CEPI and its members welcome the recognition of forests and forest products in the EU’s new climate and energy policy framework 2020-2030 and the inclusion of the land use, land use change and forestry sector in the framework.

Even though the proposal is on a 10 year period, it should incentivise the long term carbon benefits of forests and the bio-economy. The inclusion should not lead to an optimisation for the 2020 to 2030 period. In the long term, Europe will need more wood products.

The regulation should provide a framework incentivising Member States to promote a forest management, which increases the capacity of its forests to take carbon out of the atmosphere and at the same time store it in products that substitute fossil products.

The Commission proposal includes several positive principles:

Emissions from the land use sector are reported when harvesting takes place. Carbon emissions should be accounted once. Emissions from the combustion of biomass should therefore accounted as zero to avoid double counting. This also ensures the climate effect of the wood use is allocated to the country in which the trees are harvested.

Harvested Wood Products (HWP) are recognised as carbon pools contributing to the mitigation efforts. We believe this is a very important element of the framework, as HWP provide a mitigation potential well below the 2020-2030 period.

Flexibility between LULUCF and the effort sharing sector is limited to afforestation. This gives Member States with potential for afforestation the possibility to use this abandoned land for afforestation. The potential for afforestation is varying strongly between Member States. However, we believe it is not necessary to limit this flexibility to 280 million tons of CO2. There should not be flexibility between LULUCF and effort sharing sector for forest management.

 We believe that the Commission should continue work towards international progress in carbon accounting and encourage other world regions to account for their emissions from LULUCF, particularly countries from which the EU is sourcing wood for bioenergy and products. A credible and though workable scheme in Europe could facilitate the uptaking of similar initiatives in other world regions. Such bottom-up approach has proven successful in the Paris agreement. 

Finally we welcome the fact that the proposal is directed to the Member States rather than smaller entities. This ensures the contribution from forestry is regarded upon in landscape approaches and with long time frames.

The Commission proposal contains provisions to be improved:

The framework should be comprehensive and as flexible as possible to further allow Member States to develop policies based on their national conditions.

 Forest management reference levels should be set on the basis of long timeframes in order to better reflect trends and responses to climate change policies and measures already in force. These timeframes should enable reference levels to emphasise the impact of most recent policy instruments affecting forest resources, forest management and use of forest products in the country.

The setting of projections based on reference levels has to be credible and transparent and should be based on subsidiarity in forest related issues. The European Commission’s role should be focused on ensuring harmonised country established reference levels and on ensuring credibility and transparency rather than a centralised recalculation on those national elements.

The criteria for the establishment of forest reference levels should be reviewed and better focused on carbon relevant criteria. Biodiversity conservation is already addressed in specific EU and national legislation and this should be reflected in policy.

The option chosen by the Commission is based on the no-debit rule. CEPI believes the no-debit rule is crucial in the LULUCF proposal to demonstrate that the forest sector acts as a sink. However, we believe that Member States demonstrating they harvest less than the net annual increment should not be sanctioned.

 

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13 Mar.2017

Placing competitiveness at the heart of the ‘Energy Package’

In view of the European Commission's publication of its Winter Energy package, the European paper industry has compiled a position paper outlining its stance on key aspects of the proposal. Here are our key messages:

Deliverables expected by “Clean energy for all Europeans” package, as a whole:

• Promotion of cost-competitive energy prices
• Consistency between policy measures
• Stability and predictability of the regulatory framework

Deliverables expected by specific legislative proposals:

Electricity markets
• Allowing for market-based prices to show real value of electricity
• RES generators should participate in the markets in the same way as all other generators
• Subsidies to RES-E should not be allowed to distort wood supply markets
• Security of electricity supply to energy intensive industry must be secured
• Demand flexibility should be voluntary and rewarded
• The benefits of CHP should be recognised (efficiency, cost effective, energy security, resource efficiency)
• EU should not create more bureaucracy or official bodies / authorities

Energy Union Governance
• No to a binding cap on energy consumption impeding industrial growth
• Increased mobilisation of forest biomass is essential in reaching the 2030 renewable energy target
• Need for a real focus on industrial competitiveness
• Reduction of administrative burden for business needs to be prioritised
• Need to avoid/minimise policy conflicts and overlaps

Energy Efficiency
• The directive should not set a binding EU cap on energy consumption
• Member States should be allowed to set their own indicative targets
• Costs and potentials varies across Member States: there is no one-size-fits-all energy savings trajectory
• Equal footing between obligation schemes and alternative measures needs to be preserved
• Cogeneration to remain at the core of the Energy Efficiency Directive

Renewable energy
• Support schemes should not distort wood markets and should stimulate supply of wood
• Opening up to national schemes to cross-border participation in electricity markets should lead to more market integration, not to harmonised subsidies
• Guarantees of origin should remain as trade description, not to be used as subsidies
• There is no “one size fits all” in heating and cooling: focus should be on flexibility and cost-efficiency
• Emission reduction in transport should cost-efficiently drive renewable energies in transport (RES-T) integration into the market while not resulting in transportation costs increased
• Our industry is an emerging producer of RES-T solutions mainly from wastes and residues, such as advanced biofuels, biogas, excess electricity from bio-based pulp and paper mills...
• Bureaucracy and costs should be avoided when implementing sustainability criteria

The full position paper can be consulted via the link below.

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09 Mar.2017

Waste Framework Directive: European material industries renew call for measurement of real recycling rates

Europe‘s metals, steel and paper industries renew their call for a harmonised method to measure Member State recycling rates at input into the 'final recycling process'. The full document can be consulted via the link below.
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17 Oct.2016

Review of Directive on the charging of heavy goods vehicles for the use of certain roads

We welcome the European Commission’s intention to create a technically interoperable system in all Member States. However, the introduction of any distance-based road charging measure will inevitably be more costly. Road charging should not result in penalising of the road. It should respect the level playing field between different modes and not disturb the market conditions.

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10 Oct.2016

Circular Economy package - Joint statement by CEPI, EuRIC and FEAD

Leading federations representing the paper value chain call for the co-legislators to support the further increase of paper recycling and safeguard the “quantity” criterion in the definition of municipal waste.

The European Commission proposes to define municipal waste as mixed waste and separately collected waste from households and “mixed waste and separately collected waste from other sources that is comparable to household waste in nature, composition and quantity” .

A lot of the debate has focused on the quantity criterion. We believe that this is the only objective and measurable criterion. The quantity criterion is needed to clearly distinguish between municipal waste on one hand, and commercial and industrial waste on the other.

While paper from commercial and industrial sources is already collected and recycled at high levels, an untapped potential exists for household paper collection and similar sources, for which the waste directive is setting targets. If the quantity criterion is removed, the target for municipal solid waste will unduly include commercial and industrial waste and affect the accuracy of statistical data.

Moreover, the collection of commercial and industrial waste should not be financed and cross-subsidised by public funds, ultimately resulting in additional costs for taxpayers. In the absence of the quantity criterion there is a genuine risk that the scope of municipal waste is widened and therefore the focus is diverted from areas where the need to increase collection is the most acute. In order to ensure that all streams remain open to competition, instrumental to preserving cost-efficient and innovative waste markets, we support two key actions:

1. Maintaining the quantity criterion in the definition of municipal waste;

2. Clearly stipulate into the definition of municipal waste that it is neutral with regard to the public and private status “The definition of municipal waste (…) is neutral with regard to the public or private status of the operator managing waste and to the ownership of the waste”.

CEPI – The Confederation of European Paper Industries

The Confederation of European Paper Industries (CEPI) is a Brussels-based non-profit organisation regrouping the European pulp and paper industry and championing the industry’s achievements and the benefits of its products. Through its 18 member countries (17 European Union members plus Norway) CEPI represents some 505 pulp, paper and board producing companies across Europe, ranging from small and medium sized companies to multi-nationals, and 920 paper mills. Together they represent 23% of world production.

EuRIC – The European Recycling Industries’ Confederation

EuRic is the umbrella organisation for recycling industries in Europe. Through its Member Federations from 19 EU and EFTA countries, EuRIC represents today across Europe over:

  • 5,500 companies generating an aggregated annual turnover of about 95 billion €, including large companies and SMEs, involved in the recycling and trade of various resource streams;
  • 300,000 local jobs which cannot be outsourced to third EU countries;
  • An average of 150 million tons of waste recycled per year (paper, metals and beyond);
  • Recyclers play a key role in a circular economy. By turning wastes into resources, recycling is the link which reintroduces recycled materials into the value chains again and again.

FEAD – The European Federation of Waste Management and Environmental Services

FEAD is the European federation representing the European waste management industry. FEAD’s members are national waste management associations covering 18 Member States, Norway and Serbia. They have an approximate 60% share in the household waste market and handle more than 75% of industrial and commercial waste in Europe. Their combined annual turnover is approximately € 75 billion. FEAD represents about 3,000 companies with activities in all forms of waste management. These companies employ over 320,000 people who operate around 2,400 recycling and sorting centres, 1,100 composting sites, 260 waste-to-energy plants and 900 controlled landfills. They play an important role in the determination of the best environmental option for waste management problems.

 

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19 Sep.2016

Response to Commission public consultation on reduced VAT rate for e-books and periodicals

Short summary: The proposal to reduce the VAT rate for e-books will not necessarily reduce the current price of e-books, as publishers may not pass this reduction to the end consumer. On the other hand, if the VAT increases for print products, this will inevitably reduce print book sales, as consumers will need to pay more. If the proposal leads to replacing printed books with e-books, we would find it unfair and not aligned with the general interest. These concerns should be addressed by maintaining the current reduced VAT rates for paper books, newspapers and periodicals and ensuring an equal and neutral treatment for both technologies. In addition, the Commission should encourage Member States to make full use of the possibility to reduce the VAT rate they apply to both printed products and e-books.

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16 Sep.2016

Response to public consultation on access to international road haulage

Short summary: We support a completely free market for transport services in the European Union that can improve industry’s competitiveness. Liability of shippers should be proportionate. Simple cabotage rules allowing the development of today’s complex and international supply chains should be promoted throughout the EU.

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01 Sep.2016

Joint Statement on the legislative review amending the Waste Framework Directive and Packaging and Packaging Waste Directive

Key Messages
1. Ensure a life-cycle approach in legislation, taking into account the functionalities of packaging, such as preserving the entirety of resources invested in the packaged product along the entire value chain.


2. Safeguard the Internal Market (the legal basis of the PPWD) to ensure the free movement of packaging and packaged goods. Avoid de facto trade barriers for packaging and packaged goods; retain the PPWD’s pre-notification procedure and Article 21 Committee.


3. Ensure relevance of the EU EPR “general requirements” for the packaging waste stream, alongside nationally and clearly defined roles and responsibilities, for all actors involved in EPR implementation. Obligated costs for producers need to be clearly demarcated and net of revenue from the sale of secondary raw materials.


4. Allow free competition so that producers can choose the packaging most appropriate for the product and distribution system. Legal requirements that mandate additional packaging reuse systems alongside existing EPR systems risk undermining the cost-efficiency of EPR and recycling efforts/investments. Resist national measures to promote packaging reuse systems that will distort the Internal Market.


5. Set realistic and achievable packaging “preparing for reuse”/recycling targets, based on an updated ex-ante impact assessment, known starting points, as well as a harmonised and clarified measurement point and calculation methodology.


The undersigned organisations1 represent a wide range of sectors in the packaging value chain. They support an enabling EU policy framework that facilitates sustainable resource use from a full lifecycle perspective, incentivises economies of scale and takes into account value chains at all levels with each of their different needs, supply and demand realities. To further enable our industries to transition towards a resource-efficient and competitive Circular Economy, our associations have the following recommendations for the European Parliament and Council to ensure EU legislation is relevant, achievable and proportionate for packaging and packaged goods.


1. LIFE-CYCLE APPROACH: In addition to end-of-life considerations, measures must also take into account the key functionalities of packaging, such as preserving the entirety of resources invested in the packaged product along the entire value chain.
 

  • Packaging plays a positive role in a Circular Economy by optimising resource use, minimising product (e.g. food) waste and protecting products all along value chains. Packaging is cross-sectoral and, in order to perform its functions, the full lifecycle of the packaging, intrinsically connected with the product it contains and value chain, must be considered in its entirety. The choice of packaging which best meets the functional requirements for the product concerned, needs to be made on a case-by-case basis.
  • Therefore, we strongly caution against measures that set restrictive/prescriptive requirements for packaging attributes (e.g. single-use/multiple use, recyclable or non-recyclable, bio-based and/or biodegradable, recycled content, single-serve/dose) without regard to the impact on the life-cycle of packaged products themselves. Such legal requirements for attributes of packaging could imply significant costs for businesses in Europe to adapt whole supply chains, stifle product innovation, distort the Internal Market (see point 2) and might lead to a net detrimental environmental impact on packaged goods. In case of restrictions on single-use packaging, it also ignores (modern) societal and consumer trends, and risks being perceived as the EU overstepping its boundaries.
  • We also believe it is difficult to set and fairly calculate packaging prevention targets and to ascribe related targets to different sectors. The demand for packaging is linked to the demand for packaged goods. Changes in demand for packaged goods and associated product innovations determine the types of packaging placed on the market and the amount of protection that their contents need. Prevention is already addressed under the PPWD’s essential requirements in Annex II. In addition, there is already an economic incentive for producers to optimise the amount of packaging they use (over and above the cost of the packaging materials) since packaging EPR fees are based on weight.

    2. INTERNAL MARKET: Safeguard the Internal Market (the legal basis of the PPWD) to ensure the free movement of packaging and packaged goods
  • A Circular Economy in Europe cannot be achieved without a properly functioning Internal Market, guaranteed by the PPWD that has the Internal Market as its sole legal base. That legal base, alongside its harmonisation and environmental objectives, gives companies in the packaging value chain the confidence to invest and innovate in order to meet the growth, competitiveness and employment objectives of the Circular Economy Package.
  • Therefore, we recommend avoiding measures that could lead to divergent national packaging design requirements, since they create de facto trade barriers for all packaged goods. The PPWD contains an important obligation, under Article 16, on Member States to notify their intention to introduce such measures. This obligation ensures that national measures do not disrupt the Internal Market for packaging and packaged goods.
  • Likewise, promoting national reduction quotas and even national bans for certain packaging types, materials or systems is inappropriate (see also point 1). Such measures would create real trade barriers in the EU which the PPWD explicitly aims to avoid. Great care must be taken not to undermine two decades of success in safeguarding a single European market for packaging and packaged goods. As long as a packaging respects the essential requirements of the PPWD, it must be guaranteed access to market and free movement in the EU.
  • The Commission should continue to be assisted by the Committee for the Adaptation to Scientific and Technical Progress, composed of the representatives of the Member States and chaired by the representative of the Commission as stated in the initial PPWD Article 21. This article allows the practical implementation of the PPWD to be kept under review. The composition of this Committee should explicitly include national environmental/waste and industry experts in order to mirror the PPWD’s Internal Market legal base, as well as its dual objectives.

    3. EXTENDED PRODUCER RESPONSIBILITY: Ensure that the EU EPR “general requirements” in the WFD apply to all schemes and are made relevant for the packaging waste stream, respecting the PPWD’s legal base. These EU requirements sit alongside explicitly specified roles and responsibilities, defined at national level by Member States, for all actors involved in EPR implementation. This allows Member States to continue to set up EPR systems according to their national requirements, in line with the subsidiarity principle. Additionally, obligated costs for producers need to be clearly demarcated and net of revenue from the sale of secondary raw materials.
  • This will ensure that national measures to implement the EPR “general requirements” cannot disrupt the Internal Market for packaging and packaged goods, since the PPWD has the Internal Market as its legal basis which the WFD has not. For instance, including all the following costs” suggests that the basis of the costs may differ from one Member State to another, potentially fragmenting the Internal Market. The basis of the costs should be based on harmonised criteria established by the proposed Member States’ exchange of information forum (see also point 2). However, actual fee setting should remain the responsibility of individual EPR schemes within a Member State.
  • Ensure a clear net cost demarcation for the obligated industry at EU and national level. An unlimited obligation for producers to “cover the entire cost of waste management” is disproportionate to the producer’s role and responsibility for the separate collection, sorting and related treatment operations of used packaging for recycling. In line with the Circular Economy’s objectives, we strongly support the proposed net cost principle/incentive which takes into account the revenues from sales of secondary raw packaging materials.
  • In addition, we believe that producers need to be able to drive waste prevention within their production, because it is the producer who knows what the packaging needs of their products and supply chains are (see point 1). Therefore, we recommend keeping prevention requirements outside the EPR “general requirements”, which apply to all waste streams covered by EPR and the different ownership models of EPR schemes. Waste prevention goes beyond the end-of-life role and responsibility of packaging EPR schemes and is related to the life-cycle of the entire product.
    4. REUSE: Allow free competition between packaging materials and formats so that producers can choose the packaging most appropriate for the product and its distribution system. Legally requiring new packaging reuse systems to be established alongside existing EPR systems will undermine the cost-efficiency of EPR and recycling efforts/investments and distort the Internal Market.
  • Avoid creating an obligation for Member States to introduce new reuse systems in markets where EPR and recycling systems are well-established. Studies show that imposing new systems to promote reuse activities alongside well-functioning recycling systems erodes the (cost-) efficiency of household-based collection systems as existing infrastructure would no longer be used to its full potential[2]. In addition, if existing installed production capacity is required to be substituted by reuse systems, substantial capital and operating costs will be imposed on producers and retailers for which no economic return is possible without incremental sales volumes or increased prices for consumers. Additional reuse systems should be subject to a complete ex-ante technical, social, environmental, and economic analysis.
  • In addition, national measures to promote packaging reuse systems tend to undermine the Internal Market because they favour local trade exchanges/sales as reusable packaging systems rarely make economic or environmental sense over longer distances[3].
  • We support smart regulation for the PPWD that allows those Member States with existing reuse systems for packaging in place to be credited for their efforts when calculating their progress towards the EU packaging targets. This can be done by deducting reusable packaging (which is not part of ‘packaging waste generated’) from the reported ‘packaging placed on the market’ (all packaging), as part of the target calculation methodology. At the end of its reusable life, it becomes waste and thus part of ‘packaging waste generated’. In this spirit, we support Member States and MEPs request not to mix waste with products and thus to retain the 2008 WFD definition for ‘preparing for reuse’.

    5. PACKAGING TARGETS: Set realistic and achievable packaging “preparing for reuse”/recycling targets, based on an updated ex-ante impact assessment, known starting points, as well as a harmonised and clarified measurement point and calculation methodology.
  • We support realistic and achievable “preparing for reuse”/recycling packaging targets based on clear starting points. Hence, any changes to the structure of targets, definitions, measurement points and related methodology need an updated ex-ante cost/benefit analysis. Such an analysis will assess the impact of these changes against target achievement and economic and environmental benefits.
  • Robust measurement and accurate reporting are crucial to ensure transparent and comparable data across the EU. The Commission’s proposal rightly establishes the point of measurement for packaging recycling as the point of input to a final recycler, after sorting operations have been completed. The option to count output from sorting operations under certain conditions is fully consistent with this measurement approach.
  • We support the current method of counting recycling of composite packaging towards the rates and targets of the predominant material. It is neither technically nor administratively feasible to count the recycling of material components of composite packaging coming out of a recycling process towards their individual material recycling rates. In addition, counting such materials separately is unlikely to have any significant impact on overall packaging material recycling rates.
    We trust that the above is constructive and would welcome the opportunity to reflect further on the points outlined above together with the European Parliament, Council, Commission and other stakeholders.

    Signed by the following industry organisations (in alphabetical order)
    ACE – The Alliance for Beverage Cartons and the Environment
    AGVU - Arbeitsgemeinschaft Verpackung und Umwelt e.V., Germany
    AIM – European Brands Association
    A.I.S.E. – The International Association for Soaps, Detergents and Maintenance Products
    ARA – Altstoff Recycling Austria AG Packaging Compliance Scheme, Austria
    ARAM – Romanian Association for Packaging and the Environment
    BIHPAK – Bosnia and Herzegovina Association for Packaging & Packaging Waste Management
    CEPI – Confederation of European Papers Industries
    CICPEN – Czech Industrial Coalition on Packaging and the Environment
    CITPA – International Confederation of Paper and Board Converters
    Cosmetics Europe – The Personal Care Association
    DSD - Der Grüne Punkt Dual System for Packaging Recycling, Germany
    Eco-Emballages – Packaging Recovery Association, France
    EuPC – European Plastics Converters
    EPBA – European Portable Battery Association
    European Aluminium
    EUROPEN – The European Organization for Packaging and the Environment
    FEA – European Aerosol Federation
    FEFCO – European Corrugated Packaging Association
    FEVE – The European Container Glass Federation
    Flexible Packaging Europe
    FoodDrinkEurope
    IK- Industrievereinigung Kunststoffverpackungen e.V., Germany
    INTERGRAF– European Federation for Print and Digital Communication
    INCPEN - The Industry Council for Research on Packaging and the Environment, UK
    MPE - Metal Packaging Europe
    Miljöpack – Trade Industry Group, Sweden
    Pack2Go Europe - Europe’s Convenience Food Packaging Association
    Pakkaus – Finnish Packaging Association
    REKOPOL - Recovery Organisation S.A., Poland
    REPAK - Packaging Recovery Organisation, Ireland
    Serving Europe - Branded Food and Beverage Service Chains Association
    SLICPEN – Slovak Industrial Coalition on Packaging and the Environment
    Sociedade Ponto Verde, S.A. – Packaging Recovery Organisation, Portugal
    UNESDA – Union of European Soft Drinks Associations
    Valpak - Environmental Compliance, Recycling and Sustainability Solutions, UK

1 This joint statement captures the main points our associations share in common and does not preclude each of the undersigned organisations from issuing individual positions that are more focused on their specific sectors.
2 Roland Berger, The consequences of a deposit system for disposable packaging based on the German example, 2008
3 Communication (2009) from the Commission: Beverage packaging, deposit systems and free movement of goods (2009/C 107/01); European Commission (1999) Reuse of primary packaging

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13 Jun.2016

Post 2020 ETS reform

Statement in view of the Environment Council on 20 June 2016

As a market-based system, emissions trading has the best potential to reduce greenhouse gas emissions in the lowest-cost way, and to create a market signal to drive low-carbon investment. The undersigned associations support the principles of the EU ETS as the cornerstone mechanism to deliver cost-efficient emission reductions in the EU while at the same time securing a global level playing field for industry.

But, for this to be achievable, we need to ensure that the EU ETS works for every covered sector. We must make sure that the energy-intensive, carbon-intensive and/or trade-exposed industries, operating in a highly competitive global market get the right kind of support to enable them to continue to reduce emissions within the EU. For the power sector, which needs significant levels of investment to secure and decarbonise the electricity supply, we must ensure a carbon price that provides a meaningful signal towards the sector’s low carbon investment decisions today and tomorrow.

The post 2020 ETS reform must focus on achieving long-lasting, holistic and effective changes to the system in order to instil confidence in the market. An essential element of the reform is to provide long-term predictability and legal stability to industry and investors, and to avoid the quick-fixes and piecemeal approach we have seen in the recent past.

In this respect, the European Commission’s proposal to set, in the ETS Directive itself, the ratio between the shares of allowances for auctioning and those for free allocation is an element of certainty. However, the rules should ensure the right balance between ensuring liquidity with regard to the available auctioning volumes and providing the necessary volume of free allowances on the level of best performers in order to avoid carbon and investment leakage.

The undersigned associations are committed to make the reform of the EU ETS a success. But it must be a success for all the covered sectors. As representatives of major industrial sectors, we will remain firm on this point as this will be essential to develop and strengthen the industrial value chain across Europe as well as European industry’s international competitiveness.
 

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