The Circular Economy Package: the distinct case of packaging & packaging waste within the wider EU waste policy framework

The Circular Economy Package promises to be an important driver for sustainable growth and competitiveness for the packaging supply chain in Europe. From a policy perspective, relevant harmonisation across EU waste legislation will be needed, while at the same time keeping a distinct packaging waste stream policy approach. This distinct approach is needed in proposed policy measures such as the new targets, methodologies and extended producer responsibility.

The raw material suppliers, packaging producers and users of packaging (brand owners), represented by EUROPEN, are pleased that the Commission’s proposal recognises the enabling role of packaging in a Circular Economy. Packaging optimises resource use, helps to minimise (product and food) waste, protects products along different value chains and provides consumers with varied uses, choices and benefits of the products it contains. These roles and functionalities, but also packaging’s environmental performances, happen at different stages of a packaged product’s lifecycle and are different for each packaging type. It is this holistic approach that is also reflected in the EU Packaging and Packaging Waste Directive, allowing packaging supply chains to continuously improve their environmental performance in a sustainable manner.

The Circular Economy legislative proposals have implications for various sectors and waste streams, such as the electronics, batteries, end of life vehicles and indeed the packaging waste stream. The broader Waste Framework Directive covers many of these streams and is, rightly so, the centre of attention for potential harmonised / across the board policy measures, aiming for a clear policy framework to drive the different sectors and business opportunities that underpin the Circular Economy.

However, where many, including EUROPEN, would wish more harmonised EU waste legislation for definitions and calculation methods for instance, there will always be a limit to policy harmonisation due to the different market needs, challenges and opportunities for the different waste streams in Europe. These are partly covered by the Waste Framework Directive and partly by sector or waste stream specific Directives, like the Packaging and Packaging Waste Directive, which covers both packaging and packaging waste.

Some proposed measures in the Waste Framework Directive have been duplicated in the Packaging and Packaging Waste Directive but seem to be more appropriate for ‘products’. Two such examples are ‘repairability’, and combined preparing for reuse/recycling targets with a related calculation methodology. Some clarification will be needed on the method for counting and reporting towards the joint target for ‘preparation for re-use’ and recycling for packaging. The systems, measurement and reporting of preparing for reuse or reuse for packaging (versus “products/goods”) need to be carefully assessed on a case-by-case basis with rigorous analysis from an economic and environmental point of view.

EUROPEN welcomes the proposed regulatory framework on Extended Producer Responsibility (EPR) in the Waste Framework Directive. However, in a similar manner we will assess and monitor whether the broad EPR measures in the Waste Framework Directive which cater for all covered waste streams, will remain relevant and proportionate to EPR for packaging.

EUROPEN looks forward to further contribute to the Circular Economy debate and continue working constructively with EU policy-makers to achieve a clear, predictable and proportionate EU policy framework. In particular, we will contribute to the environmental and economic impact assessment of the suggested broader harmonised legislative measures which would be applicable on packaging and all packaged goods that circulate freely in the EU Internal Market.

****

Note: This article was published in the Parliament Magazine on 25 January 2016, the full issue can be consulted here