EU Circular Economy Package – some positive developments with challenges ahead

EU Circular Economy Package – some positive developments with challenges ahead

The long anticipated EU Circular Economy package, with implications for 2 key EU directives concerning packaging and waste, has now been published. The expectation was of some bitter medicine that would have a major impact for foodservice packaging and indeed for UK businesses as a whole. The medicine isn’t quite so bitter but nonetheless the package provides us with a number of challenges.

To quote from the Commission’s press release:

The new circular economy package is ‘to help European businesses and consumers to make the transition to a stronger and more circular economy where resources are used in a more sustainable way. The proposed actions will contribute to “closing the loop” of product lifecycles through greater recycling and re-use, and bring benefits for both the environment and the economy. The plans will extract the maximum value and use from all raw materials, products and waste, fostering energy savings and reducing Green House Gas emissions. The proposals cover the full lifecycle: from production and consumption to waste management and the market for secondary raw materials’.

With a lot to read its very difficult to come to firm conclusions but we feel:

The recycling targets are very challenging and the hope has to be some of the €6 billion funding being made available will be used to develop the UK’s recycling infrastructure. With respect to paper and board by 2030 recycling will have to be compulsory to achieve the targets.

The target for reducing food waste is also a challenge but a welcome one. Excellent progress is being made in the UK foodservice sector  but nonetheless there is more to be achieved and we should rise to this challenge.

The Commission will start work developing quality standards for secondary raw materials, in particular for plastics. The circular economy seeks the conversion of waste into new raw materials but there are barriers to increasing the take-up of secondary raw materials such as inconsistencies in quality.

The target for reducing food waste is also a challenge but a welcome one. Excellent progress is being made in the UK foodservice sector but nonetheless there is more to be achieved and we should rise to this challenge.

Extended Producer Responsibility will still not be mandatory. EPR versus the current UK producer responsibility regime of Packaging Recovery Notes would have placed a huge cost on UK businesses. The Package uses the words ‘measures may consist of national programmes, incentives through extended producer responsibility schemes to minimise the environmental impact of packaging or similar actions adopted, if appropriate’ . In the summary below you will see a reference to  ‘Ensure that producers’ contributions cover the entire cost of managing the waste from their products, including net cost of separate collection, sorting and treatment necessary to meet the targets’. We need to examine this element more carefully and learn more about the Government’s response to the Package as they now must apply the Package for the UK.

The original proposals in 2014 which were subsequently withdrawn included businesses also paying for the full cost of litter. That isn’t contained within this revised package.

Further interpretations of the Package will be published soon but for the moment please read the key actions which include:

A common EU target for recycling 65% of all municipal waste by 2030 – that is every single item of waste collected

A common EU target for recycling 65% of packaging waste by 2025 and 75% by 2030

Broken down by material:

Plastics 55% by 2025 with so far no target for 2030

Paper & board 75% by 2025 and 85% by 2030

Glass and metals are identical to wood

Wood 60% by 2025 and 75% by 2030

A binding landfill target to reduce landfill to maximum of 10% of all waste by 2030

A ban on landfilling of separately collected waste

Promotion of economic instruments to discourage landfilling

Simplified and improved definitions and harmonised calculation methods for recycling rates throughout the EU

Concrete measures to promote re-use and stimulate industrial symbiosis –turning one industry’s by-product into another industry’s raw material

Economic incentives for producers to put greener products on the market and support recovery and recycling schemes including packaging

Actions to reduce food waste including a common measurement methodology, improved date marking, and tools to meet the global Sustainable Development Goal to halve food waste by 2030

Development of quality standards for secondary raw materials to increase the confidence of operators in the single market

Measures in the Ecodesign working plan for 2015-2017 to promote reparability, durability and recyclability of products, in addition to energy efficiency

strategy on plastics in the circular economy, addressing issues of recyclability, biodegradability, the presence of hazardous substances in plastics, and the Sustainable Development Goals target for significantly reducing marine litter

A series of actions on water reuse including a legislative proposal on minimum requirements for the reuse of wastewater

Funding of over €650 million under Horizon 2020 and €5.5 billion under the structural funds

With regard to producer responsibility:

Member states shall

Take measures to create incentives for waste holders to take part in the separate collection systems in place, “notably through economic incentives or regulations, when appropriate”

Ensure that EPR compliance schemes have a clearly defined geographical, product and material coverage; have the necessary operational and financial capacity; have an adequate self-control mechanism supported by regular independent audits; and make publicly available information about their ownership and membership, the financial contributions paid by producers, and the selection procedure for waste management operators;

Ensure that producers’ contributions cover the entire cost of managing the waste from their products, including net cost of separate collection, sorting and treatment necessary to meet the targets, taking account of revenues from reuse or sale of secondary materials; the costs of providing information to waste holders; the cost of data gathering and reporting; are modulated on the basis of real end-of-life costs of individual products or product groups, taking into account their reusability and recyclability; and are based on the optimised cost of services where operations are carried out by the public sector

Establish an adequate monitoring and enforcement framework, including an independent authority to oversee the implementation of EPR obligations where multiple compliance organisations are operating

Establish a platform to ensure regular dialogue between all public and private sector players.