DRS “shortcuts and loopholes”: Cross-industry platform calls for stronger PPWR revisions

13 Dec 2023 --- A platform of almost 50 organizations from 13 European countries is calling for the amendment of the final PPWR wording — acknowledging the key role of a deposit return system (DRS), as a “necessary tool” to ensure true circularity for single-use beverage containers in the EU. 

The group says that in the plenary, all amendments aimed at making DRS voluntary for member states were rejected by the European Parliament (EP), showing a firm position of the EP, in line with the original proposal by the European Commission (EC), to have DRS become the norm in Europe. 

But the platform stresses that the wording on DRS, a result of the EP’s vote, lacks the ambition and the strength of the initial wording of the EC and could open the door to shortcuts and loopholes that could delay the implementation of DRS across Europe. 

Mandatory DRS for best practices
Alexis Eisenberg, director at the Reloop Platform, which is one of the contributors to the joint position, tells Packaging Insights that reaching high targets such as 90% on plastic bottles and cans means using the best EPR tool to achieve this ambition. 

Organizations say standardized DRS is the only way of ensuring high can and bottle return rates.“That [reaching high recycling targets] is where DRS is in most European countries (14 now and 21 in 2025) the right tool to achieve this ambition. It provides full material circularity to get more recycled content, decarbonize packaging, and open the gateway to reuse systems as dual or mixed DRS for recycling and reuse. This is necessary to have the mandatory DRS lever in PPWR to push countries to reach the 90% targets with or without DRS in a close calendar.”

Chloé Schwizgebel, policy and campaign coordinator at the Recycling Network Benelux, adds: “We also know that all large-scale reuse systems (for example, for glass bottles) are facilitated by a DRS. It is also a known measure to reduce the prevalence of packaging in litter.”

“Making it mandatory would enable the spread of best practices. We know that making such a measure voluntary would enable the anti-DRS lobby, mostly packaging industry (producers but even more so retailers), to have more lobbying room,” she tells us. 

No support for digital DRS
The group of organizations asks for a final version of the PPWR that protects a proven-to-be-effective DRS by raising the threshold for exemption from adopting national DRS to a 90% collection rate instead of the 85% in the text proposed by the EP.

Furthermore, the group is demanding the phasing out of any escape route to countries opposing the introduction of a DRS, such as the possibility of presenting a “plan of action” to reach the 85% target while ignoring the spirit of the legislation and the targets already fixed in the SUP directive.

The organizations also stress that avoiding any mention of “digital” DRS (DDRS), which is an alternative proposed but not implemented anywhere, is “made up” by the industry to avoid the real implementation of proven DRS. 

“We are not convinced about DDRS as it is not ready to market, and it should not be an excuse for the status quo. There are still many technical issues for producers, retailers and consumers. The serialization is interesting for reuse packaging, especially in second and third packaging, but recent pilots in Belgium are not conclusive, especially on return rate and littering,” asserts Eisenberg. 

“It’s important to know that DDRS is a tech idea from anti-DRS stakeholders under the threat of having a DRS in their countries. The retailers’ motivation is to avoid managing DRS in stores, and the recyclers’ motivation is to keep the material in the curbside. DRS operators in Europe are not really interested in it.”Schwizgebel says a mandatory European DRS would help governments against the anti-DRS lobby.

Why the EU needs a solid DRS
The organizations say that mandatory DRS is the only measure to ensure separate collection rates of beverage containers above 90%. The collection of high-quality materials allows for:

• Closed-loop recycling (packaging-to-packaging) given maximized use of materials.
• Compatibility with reuse schemes (by enabling the infrastructure of such schemes) which supports compliance with the reuse targets proposed by the PPWR itself.
• Minimizing littering of beverage containers, thereby contributing to reduced costs for local authorities and reduced leakage of resources from circular management.

National spillover effect
Eisenberg says that some countries that are performing rather low on bottle and can return prefer to keep the status quo, even if they don’t perform, to preserve the economic contract and financial flow between municipalities and recyclers.

“This is all about material property, not about environmental considerations or circular economy perspectives. Unfortunately, because municipalities are involved, the local and political considerations are winning versus the European project.” 

An EU country example is France, which currently has 60% plastic bottle and 45% can return rates.

“France is now a disappointment on PPWR in Europe with the proposition to decrease the threshold of the DRS to 78%. This is a confession that the country is unable to reach the 90% or even the 85% target in 2026 proposed by the EC or the EP,” says Eisenberg.

Schwizgebel adds that a mandatory European DRS would not only assert, from the European point of view, that DRS is an effective measure (incentivization) but would also help governments against the anti-DRS lobby.

“Besides, the essential requirements would guide governments in implementing an effective system (cause not all systems are created equal). That would be the case of the scope of the packaging, take-back obligation etc.”

“In the case of Belgium, the three regional governments have indicated their willingness to go for DRS in 2022 (see Wallonia, Brussels and Flanders). However, there are discussions about a digital system — which has yet to be implemented anywhere in the world — which we fear might disrupt the European market and lead to a suboptimal system. So a mandatory DRS would help countries implement an effective DRS,” concludes Schwizgebel.

By Natalie Schwertheim