Making sense of the EU’s Circular Economy Package from the metal packaging value chain

New EU waste legislation adopted last year has redefined what can be considered “recycled” and resets targets for each packaging material. Gordon Shade goes through the expected changes and remaining challenges.

Gordon Shade is CEO of Metal Packaging Europe, a trade association.

In July 2018, European policymakers finally adopted the revised Waste Framework Directive (WFD) and Packaging and Packaging Waste Directive (PPWD) as part of their ambition to establish a circular economy in Europe.

These were last revised in 2008 and 1994 respectively, so a fundamental overhaul was long overdue, especially as the European Commission considers packaging waste and its visibility to European consumers a key part of its Action Plan[1].  It also offered Europe the opportunity to take the leadership role in circular economy thinking, with the obvious business and employment opportunities this could generate.

The legislative process has taken more than 3 years from start to finish, with extensive interaction between policymakers and the different players in the value chain. Member States are now required to implement it by July 2020.  The revised legislation generates a fundamental shift in policy, with the focus moving from “make, take, dispose” to the creation of a well-functioning circular economy around the radical reduction in waste.

So, what changes can we expect from the legislation, which challenges remain, and is the legislation sufficient to trigger a change in behaviour?

The new legislation has redefined what can be considered “recycled” and reset the targets for each packaging material, thereby creating much greater consistency across Member States.  It also means that incineration of non-recycled materials can no longer be included when calculating future recycling rates. This encourages Member States and the value chain to place products on the market, which are actually recycled. By redefining the point of measurement, it is quite likely that in the first instance, recycling rates for most materials will decrease, which will indicate the weakness of previous legislation.

The new recycling targets have been established for 2025 and 2030 and these need to be met by all individual Member States. It is clear that more and better recycling is a key outcome of the legislation and our industry is very supportive of this process. Fortunately, rigid metal packaging has at the heart of its design, safety, easy recovery and recycling at the product’s end-of-life. To underline this, we will intensify the use of the ‘Metal Recycles Forever’ logo on our products.

In our sector, the aluminium suppliers are looking closely at their recycling challenges and identifying appropriate actions both in terms of increased quality and quantity. Today, across Europe 3 out of 4 aluminium beverage cans are successfully collected and recycled and, globally,  they are the most recycled drinks package. In Europe there are still Member States, which fall short of expectations and the aluminium and steel industries are working with the different stakeholders to improve these positions.

Remaining challenges

The CEP is a very significant change in direction for packaging. We would underline that the packaging value chain plus policymakers, both national and European, have a number of key areas to address for the potential of circularity to be fully unlocked.  These include:

Modulation of EPR fees
The legislation has made the modulation of EPR fees based on real end-of-life costs mandatory. In 2019, the European Commission will work on guidelines for this. Whether the legislation will be successful, will largely depend on ensuring a clear cost differentiation between products that are easily recyclable, reusable and repairable and products and packaging materials that are difficult to recycle, or not recycled.

CONAI (Consorzio Nazionale Imballaggi), the Italian EPR scheme and largest of its type in Europe, began end-of-life cost allocation a number of years ago and serves as a best-in-class example.  Today, it has 6 product categories, which bear significantly different costs per tonne covering collection, sorting and recycling, ranging from €3/tonne for tinplate to €369/tonne for plastics which are not sortable or recyclable with current technologies.

Packaging sustainability indicators
Today, the value chain makes extensive use of Life Cycle Assessments (LCAs) to support the choice of packaging. However, in our view, this instrument is often poorly applied, frequently focusing only on carbon footprints in a limited or incomplete manner even excluding the product content and full end-of-life impact.

We recommend that the value chain come together and develop indicators which measure and encourage a circular approach. Such indicators could be developed by material to better reflect individual characteristics of the different packaging materials.

National implementation
It is crucial that Member States transpose the Circular Economy Package quickly into national law, fully reflecting the change in direction determined by the European institutions. Speed is also important in reporting recycling rates under the new definitions. Can we really wait up to 18 months to discover the effectiveness of legislation?

We don’t believe so and therefore encourage Member States to do their utmost to report quickly and accurately.

Is the legislation sufficient?
It is fair to say that, today, the legislation is a step in the right direction. However, timing is absolutely critical especially as packaging volumes continue to grow. Taking account of this and the pressure from deteriorating environmental trends means policymakers need to facilitate all the necessary means to ensure this legislative package can generate the results expected.

The metal packaging industry remains optimistic and is ready for the challenges ahead… But the clock is ticking.


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