Introduction
The Paper Packaging Coordination Group comprises the major European paper and board packaging associations which represent the interests of a wide range of packaging products used in transport, retail and consumer packaging. Paper and board packaging is based on a renewable resource (the forest) and is recyclable. We support the concept of a circular economy in which raw materials are sourced from renewable, responsibly managed resources and where possible, recycled after use.
The members of our associations are directly affected by any legislative package which promotes the Circular Economy and amends the waste and packaging waste legislation.
1. Recycling targets for paper and board
Key Messages:
• Targets should be ambitious and reflect technical and economic realities
• For materials, a clear focus on recycling should be ensured
• Packaging recycling targets should be proportionate between different consumer packaging materials, fairly taking into account each material’s situation, achievements and potential for improvement. High achievement of one packaging material should not compensate for another material’s lower achievement.
We believe ambitious targets could be set when the reality is properly evaluated:
• On average, the paper and board packaging industry in Europe has achieved high recycling rates. In 2011, the average paper and board packaging recycling reached 81.3% (CEPI). The EUROSTAT figure for the same year is 79.9%. However, there are also significant differences between Member States, with the recycling rate ranging from 59% to 98%.
• Calculation methods for recycling vary between countries, making data from different countries not directly comparable. Proposals for targets based on the reported figures from best performing EU Member States will be ambitious but not realistic. The differences should be assessed and considered when defining new targets
• Our industry’s experience suggests that all Member States could achieve 80% paper packaging recycling by 2020 providing all adequate conditions are in place
• The priority should be to set a harmonised calculation methodology
• Further targets for 2025 and 2030 should be set when progress made by 2020 has been assessed, with the harmonised method
Targets for recycling should not be understood as targets for collection. To achieve higher recycling targets for paper and board packaging materials, a ban on landfill and restrictions on incineration for materials in the waste stream that could be recycled, should be enforced. In addition, the requirement in the Waste Framework Directive to collect materials separately should be strengthened and clarified.
2. Need to revise the calculation method before setting up new targets
Key Messages:
• The method for the calculation of recycling rates should be harmonised, providing clarity and simplification for ease of application
• The “input” method should be the basis of the calculation
• EU requirements for recycling should apply equally to exports of paper for recycling and should be enforced
We welcome the European Commission’s aim to promote a circular economy and improve the quality of recycling. We believe that the “input” to the final recycler should be used in a harmonised method for calculating recycling rates and should be the basis for calculation for paper and board packaging.
If the point at which packaging recycling is measured is defined as the “input to the final recycling process, after all sorting operations have been completed”, we consider that it provides the required quality of material for recycling. This is because we are confident that if the paper based packaging which is prepared for recycling meets the European list of standard grades of paper and board for recycling (EN643) then it is appropriate to apply the “input method” of calculation.
Any paper for recycling which is exported outside the EU should count towards the recycling rate provided it meets the EN 643 standard and is effectively recycled outside Europe in broadly equivalent environmental conditions to the EU. This should be demonstrated by a certification scheme which is being considered by the European Commission and would include in its scope the reprocessing site in the destination country and ensure traceability through adequate documentation. Similar procedures should apply to all packaging materials.
The denominator for such harmonised method should be clarified as well as to whether we are discussing product on the market or waste generated, including imports and exports. The denominator should be identical in all Member States to allow for comparison.
In our view, an effective method can be based on the following principles:
• recycling rates for waste are calculated as the weight of waste entering a final recycling process expressed as a percentage of the total packaging placed on the market
• to take account of a value chain approach, “final recycling” should be clearly defined in addition to the existing definition of “recycling” in the waste directive
• the recycling of multi-material packaging counts towards the recycling rate of its predominant material
Once a harmonised method is agreed and evaluated against existing performance, it should be the basis for establishing new targets.
3. Design of packaging
Key Message:
• Additional mandatory design requirements at national level for packaging will undermine the objectives of the Packaging and Packaging Waste Directive (PPWD)
Requirements for packaging design are already adequately expressed in the Essential Requirements and Member States should retain the flexibility to implement these according to the circumstances of their territories.
New obligations on Member States to set potentially divergent national packaging design requirements are not considered suitable, since they could put at risk the functioning of the internal market and potentially disrupt national recycling systems.
4. Composition of municipal waste
Key Message:
• Retailers should have the freedom to choose the method of collection of their secondary and tertiary packaging waste
Packaging waste from retail trade is a valuable commercial stream and the option for its separate collection should be retained. Retail waste, if included in the municipal waste collection, would divert the focus from the challenge of improving the waste collection from households and small businesses.
At present, secondary and tertiary paper packaging collection from the retail trade is often organized separately, in a manner very similar to industrial collection rather than to municipal collection, due to the homogenous origin of the waste material. If the retailers are included as part of the municipal waste stream collection, this may jeopardise the success of the existing collection system and have a negative impact on the recycling rate. At the same time it may require further investments in separation infrastructures to ensure high quality.
5. Minimum requirements for Extended Producer Responsibility
Key Message:
• The scope of EPR and roles and responsibilities of each actor involved in packaging waste management should be clearly defined
We wish to highlight:
• Responsibility should be limited to activities that each actor in the chain can control. For example: littering is a social problem determined by an individual’s action and the polluter pays principle should here address citizens instead of industry
• Member States should be free to determine how costs are divided between producers and municipalities and producers should have influence over implementation methods proportionate to their contribution to costs
• No overlapping and duplicating payments should be allowed: fees should only apply in absence of action when responsibility is delegated to compliance schemes, and fees should be charged on the basis of actual cost after the deduction of all fees and revenues related to the waste generated
• The need for enforcement of national EPR schemes by national authorisation and approval procedures, and for transparency of material flows
6. Landfill and incineration of waste
Key Messages
• Recyclables should not be sent to landfill
• Separate collection of materials should be strengthened
• Incineration of recyclables should be restricted
We believe that a ban on landfill should be introduced for recyclables, including paper, and incineration for recyclables should be restricted. Despite the existing capacity for reprocessing paper in Europe, up to 10 million tonnes of all paper, including packaging, is currently being landfilled or incinerated in Europe. This situation has to be addressed otherwise ambitious recycling targets cannot be achieved.
Paper and board should be collected separately from other recyclables such as plastics, metal, glass and from residual waste. Separate collection is crucial to promote a circular economy and achieve ambitious recycling targets, meet landfill restrictions and guarantee quality. The Waste Framework Directive formulated a separate collection target in 2008, but this has been interpreted by Member States, in different ways. Beverage cartons (consisting predominantly of paperboard) should be collected in the most optimal way for further recycling, which may differ from country to country.
7. Eco-design and product design
Key Messages
• The Essential Requirements in the PPWD and related CEN standards are sufficient to provide guidance for eco-design of packaging
• Packaging should serve the functionality and the safety of the product first
• Packaging should not be seen in isolation from the product
• Eco-design concepts as part of product design, should encompass the whole life cycle of the product with its packaging
Encouraging industries to use a life-cycle approach to evaluating the entire value chain of material use is the most effective and beneficial way to integrate eco-design measures into product innovation and design
Choice of the appropriate paper based material for a given packaging system should be made on the basis of fitness for purpose. No distinction between virgin and recycled fibres should be made on any other basis
Good recyclability of used packaging paper depends on good eco-design incorporated into the design of the product and its packaging and the responsible choice of additional materials (such as inks and adhesives)
Eco-design should be the guide but not the determinant for recyclability. It should provide a vision and direction for circularity but not compromise functionality
8. Renewability of Material Resources
Key Message
• Renewability of material sources is a natural driver for circularity and should be an essential element of a Circular Economy
The circle is not sustainable when it deals only with waste management and secondary raw materials: the input of primary raw material from renewable sources completes the cycle.
Renewable resources are intrinsically regenerative and can be used in a cascading way to extract the maximum value-added. For materials from sustainably managed renewable sources, there is an additional benefit: re-growth together with recycling increases the availability of materials for the economy.
For example, for paper based packaging, an input of primary fibres to the recycling process is essential. In Europe, fresh/virgin/primary fibres are derived from sustainably managed forests and play a significant part in reducing environmental impacts and improving resource efficiency at the beginning of a paper product’s lifecycle.
Within a circular economy policy framework, it is indispensable for Europe’s competitive advantage, resource security, low carbon goals and innovation potential that renewable resources and materials are promoted and supported.
Currently the following organisations participate in the Paper Packaging Coordination Group:
CEPI, Confederation of European Paper Industries
CITPA, International Confederation of Paper & Board Converters
ACE, The Alliance for Beverage Cartons and the Environment
ECMA, European Carton Makers Association
EMBALPACK, European Association of Makers of Packaging Papers
EMFA, European Moulded Fibre Association
CEPI EUROKRAFT, European Producers of Sack Kraft Paper and Kraft Paper
EUROSAC, European Federation of Multiwall Paper Sack Manufacturers
FEFCO, European Federation of Corrugated Board Manufacturers
GROUPEMENT ONDULE, European Association of Makers of Corrugated Base Papers
PRO CARTON, European Association of Carton and Cartonboard Manufacturers