Such design requirements, as considered by the proposals for the revised EU packaging and packaging waste directive, would ask each member state to set their own requirements for packaging. This could be a certain level of recyclability, or limits on the quantities of heavy metal.
Europen, the European organisation for packaging and the environment, says free movement of goods around Europe is integral to its aims as an organisation.
But free movement would be hindered by national packaging design requirements, Virginia Janssens, managing director, EUROPEN, told attendees at Empack 2014 in Stockholm last week.
Conflicting design requirements?
“We have the internal market for the free circulation of market goods, now they want to go back to a system where design and everything is decided at a national level. This is an element we cannot support, and we will focus on the internal market in that perspective,” she said.
“You can imagine global companies will have to take into account 28 specific design requirements from separate countries - and possibly conflicting design requirements.
“We are of the opinion you can’t legislate very stringent design requirements for packaging, it really depends on the product it packages, the supply chain, so many elements, you can’t capture all the differences in legislation or you will discriminate against certain materials.”
Misleading methodology?
Recycling rates are currently calculated by individual members states, using different methodology – meaning figures are not standardized across Europe. This makes it hard to compare rates. Although the EC has suggested harmonising rates, it is still problematic, Janssens said.
“What they have suggested is to change the methodology to calculate recycling rates," she said. "Europe sees that each member state calculates recycling rates differently and they want to harmonise that. I think that’s a noble exercise, but they have done it in such a way that nobody understands the new methodology.”
Europen has done its own impact assessment of recycling rates from nine different countries, and – depending on the interpretation of the EC methodology – come up with three different scenarios.
In one case, it would put current recycling rates much lower than current figures suggest – making the new EC targets much more challenging.
“This is one concern we’re flagging up to the EU institutions. Hold on, you need to clarify your wording on the methodology before you set these high targets. If we know the baseline – which is now a question mark – we can assess whether we can meet these targets.”
Newer EU members – such as Eastern European countries - are already asking for more time to meet their current recycling targets, she said, as they have had less time to meet existing targets.
“EUROPEN said in the beginning to the EC: fine, set new targets, we don’t disagree, but make sure they’re realistic and adjusted to the different performances and cultures of the 28 member countries.”
Extended producer responsibility
‘Extended producer responsibility (EPR)’ is where producers are held to account for the cost of dealing with packaging environmentally – be it in the form of re-use, recycling, or original product design.
Member states would set their own targets (for example for recycling and recovery) but would have to comply with minimum requirements set out by the PPWD.
Europen says the wording of this proposal could mean ‘potentially unlimited costs on producers’ when it comes to waste management, and wants to see the wording changed to limit this.
The packaging and packaging waste legislation is anticipated to come into effect in 2017. It wants to reduce the impact of packaging on the environment and proposes targets for recycling rates for different materials in 2020, 2025 and 2030.
The focus is on preventing waste, followed by an emphasis is on reuse and recycling. Incineration is to be considered a last resort, and landfill is to be phased out.
“As EUROPEN we are quite progressive and we support the circular economy model. But the way they [EC] want to get there, the means, is a bit too disruptive and in some cases not clear,” Janssens said.