Draft reuse requirements for drinks packaging are an existential threat to beverage industries and effective existing recycling

2022-10-27

AIJN – European Fruit Juice Association, The Brewers of Europe, Natural Mineral Waters Europe, UNESDA Soft Drinks Europe are united in expressing our profound concern at the mandatory targets the European Commission intends to set for the reuse of our beverage containers.

According to recently obtained information regarding the upcoming revision of the EU Packaging and Packaging Waste Directive, the Commission may propose to set discriminatory reuse targets for our beverage packaging already at 20% by 2030 and then as high as 75% by 2040, to be imposed at national level and observed by each individual manufacturer. If imposed, these disproportionate and unjustified high targets would have a deep impact on our respective sectors, also forming an existential threat to our many SMEs. They would furthermore lead to the dismantling of a number of highly effective, existing recycling systems.

The financial cost of implementing such a dramatic reorientation in such a short space of time would be astronomically high. Established business models across Europe would inevitably and rapidly become unsustainable. Furthermore, the European Commission is assuming that high targets will lead to rapid consumer uptake. There is no evidence thereof.

While our sectors already have reusable packaging as part of the mix and are committed to increasing the offer of reusable beverage systems with the right policy measures in place, the reuse targets as currently formulated are unrealistic and incoherent. They overlook the ongoing huge efforts and investments that we are already making towards achieving packaging circularity through increased recyclability and collection of our beverage packaging and the use of more recycled content. Most importantly, there has been no environmental impact assessment indicating that these targets would achieve their supposed intention of protecting the environment.

In recent years, our sectors have worked tirelessly to ensure we are using 100% recyclable packaging and increased levels of recycled content in our packaging, and we have campaigned for measures to increase recycling rates. Reusable packaging is not de facto the only sustainable option as is now being suggested by the European Commission. It is part of the circularity solution as a complementary action to recycling and reducing beverage packaging in a reasonable manner.

Patricia Fosselard, Secretary General, Natural Mineral Waters Europe: “Our sector is already achieving high rates of collection for recycling and is steadily progressing towards full circularity. Introducing unrealistically high reuse rates will significantly compromise this progress and jeopardise the sector, while the environmental benefit of this policy measure is yet to be demonstrated.”

Nicholas Hodac, Director General, UNESDA Soft Drinks Europe: “Over the last years, we have been investing into more recyclability, more collection, more recycling, and more reuse to make our packaging fully circular by 2030. It is totally incomprehensible that the European Commission is disregarding it and asking us to switch entirely to reuse. We can achieve the Commission’s goal in a much more realistic way that is less harmful for the industry and that makes sense for the environment.”

Wouter Lox, Secretary-General, AIJN – European Fruit Juice Association: “Reuse should be seen as a complement to recycling, not as a substitute. Our sectors wish to continue paving the way for full packaging circularity, but that can only be achieved through the right enablers in place.”

Pierre-Olivier Bergeron, Secretary General, The Brewers of Europe: “There are more than ten thousand breweries in the EU, aiming to have a positive impact on the economy, people and the planet. Central to the circular European economy, our progress goes hand in hand with the aims of the Green Deal. Through our packaging and investment in effective systems, we have demonstrated that reuse and recycling need to be seen as complementary approaches to improving drinks’ packaging’s environmental performance.”

Together, our four associations represent thousands of businesses in the beverage value chain. We recognise and support the positive steps the European Commission is taking towards increased circularity, but we call upon the Commission to rethink its approach and to look at environmental policy as an opportunity to accelerate the circular economy for beverage packaging through enablers that support industrial policy.