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The state of packaging policy trends in Europe

Virginia Janssens, Executive Director of EUROPEN and speaker at the upcoming AMERIPEN Annual Conference, discusses the Circular Economy, EPR, and other European packaging policies.

Virginia Janssens, Executive Director, EUROPEN
Virginia Janssens, Executive Director, EUROPEN

Virginia Janssens is the Executive Director of EUROPEN, a material-neutral trade association for the European packaging industry and a sister organization to U.S.-based AMERIPEN. Janssens will be in the U.S. for a presentation on packaging policy trends from Europe at the 2018 AMERIPEN Annual Meeting, May 30 to June 1 in Washington, D.C.

Packaging World:

The Packaging and Packaging Waste Directive (PPWD) is currently being reviewed. What are some of the more significant changes you anticipate?

Virginia Janssens:

The legal review of the PPWD, as part of the European Union (EU)’s Circular Economy Package (CEP), will be formally adopted in April/May 2018 by the European Parliament and EU Council. The 28 Member States to the EU will then have two years to adopt the CEP into their respective national legislative frameworks.

One major change is the increase in the legally-binding EU recycling targets for all packaging materials (glass, metal, plastics, and paper) and the removal of the EU packaging recovery (incineration) targets. Overall, EU Member States have to achieve a 65% packaging recycling target by 2025 and 70% by 2030. These increased targets are accompanied by a new calculation methodology to measure national recycling rates, aimed at harmonizing Member States’ reporting, resulting in more accurate and comparable recycling rates. In addition, Member States have to reduce the volume of municipal waste, including packaging waste, sent to landfill to 10% by 2035.

Another key point is the introduction of EU minimum requirements for Extended Producer Responsibility (EPR). EPR for packaging is an economic instrument used in Europe and covers the producer’s full or partial financial and/or operational responsibility for a product to the post-consumer’s stage of a product’s life cycle. EPR is used as one key mechanism to meet EU and national recycling targets. Over the last 25 years, producers have been instrumental in many Member States in setting up packaging recovery organizations (i.e., EPR schemes) to finance separate collection and sorting to recycle the packaging that producers place on/import into the EU market. EUROPEN advocates for EPR rules that increase transparency and cost-efficiency of the scheme and for producers’ costs, clearly define roles and responsibilities, and enforce EPR obligations at national level.

In the new CEP, the European Commission proposes to place the “entire cost of waste management on producers or importers of products put on the EU market.” How does this change the current implementation of producer responsibility for packaging in Europe?

In practice, many parties are involved in waste management: producers, retailers, municipalities, private or public waste management companies, and consumers. For waste management to be effective and efficient, the specific role and responsibility of each actor needs to be clearly defined. This is part of our call for more accountability under EPR.

In Europe, EPR covers the separate collection, sorting, and treatment operations of used packaging to help meet EU and national packaging recycling targets. This responsibility can be purely financial and/or operational. The financial responsibility can be a partial cost or an “entire” cost. The situation is very different from one Member State to another.

EUROPEN members support EPR where the “E” stands for Extended, not Endless. Hence, an unlimited obligation on producers to cover the undefined “entire cost of waste management” in the CEP could lead to a disproportionate producer responsibility at Member State level. A clear cost demarcation for producers will need to be negotiated in each Member State. Financial responsibility should come with influence over decisions that drive costs.

The new rules have vaguely described the cost under EPR, allowing Member States some freedom to decide what should be added under “entire cost” and what should not, according to their national setup/infrastructures. So the answer to your question will reveal itself when Member States are changing their EPR rules within the next two years. For instance, Member States could add costs for litter clean-up—as opposed to litter prevention campaigns, which we support—that go beyond producers’ remit and control.

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