Fair is fair: EU beverage industry demands rPET priority access amid cross-industry “free-riding”

03 May 2022 --- Europe’s non-alcoholic beverage industry and leading NGOs Changing Markets Foundation and Zero Waste Europe are calling on EU decision-makers to create the “right” enabling policy framework to help accelerate the transition to a circular economy, including “priority access” to recycled PET (rPET) supply.

The European Fruit Juice Association (AIJN), Natural Mineral Waters Europe (NMWE) and UNESDA Soft Drinks Europe underline the need to ensure resource-efficient waste management systems to enable closed-loop recycling across all relevant industries, including textiles and automotive.

The associations also call for a “priority access,” or a similar mechanism that guarantees a “right of first refusal” to beverage producers to facilitate their fair access to the food-grade recycled materials coming from the products they placed on the market and which were successfully collected. 

Last week, NMWE warned the EU would fall short of its plastic recycling targets unless “dramatic” changes are implemented. Speaking to PackagingInsights, NMWE secretary-general Patricia Fosselard said: “It is a pity that in 2019, the EU Single Use Plastics Directive laid down targets for the incorporation of rPET into new beverage bottles without providing beverage producers with the necessary ‘enabling measures,’ in particular, security of rPET supply.”

“EU authorities are aware of the resulting challenges for our industry. The upcoming revision of the Packaging and Packaging Waste Directive (PPWD) legislation will most likely set mandatory recycled content targets for additional sectors. It will afford a good opportunity to introduce priority access for all obligated sectors under the new legislation.”The upcoming PPWD revision will “most likely” set mandatory recycled content targets for additional sectors.

Prioritizing closed-loop recycling
The EU Circular Economy Action Plan aims to accelerate the transition to a circular economy but will require significant changes in the way we collect, reuse, recycle and incorporate recycled materials.

Achieving fully closed and resource-efficient waste management systems for all materials should be the primary objective, says Europe’s non-alcoholic beverage industry. The more closed-loop a system is, the more resource-efficient it will be by delivering quality recycled materials that can be reused multiple times for the same application.

Therefore, for each sector, the ultimate goal should be to achieve closed-loop recycling. With the right enabling policy framework, this can be achieved, the organizations insist.

Fosselard comments: “For beverage bottles, the first elements of such an enabling policy framework already exist with the introduction of mandatory separate collection and recycled content targets in the EU Single Use Plastics Directive. However, it is clear today that a number of additional policy measures are needed for beverage producers to be able to meet those EU targets and move further towards a closed-loop system.”

Main policy conditions
According to Europe’s non-alcoholic beverage industry, the main policy conditions that should be created are:

• Mandatory minimum requirements for Deposit Refund Schemes (DRS) to facilitate the roll-out of efficient waste collection schemes and the achievement of the EU 90% separate collection target; 
• A mechanism that grants beverage producers fair and necessary access to the recycled materials deriving from the beverage containers they put on the market and which were successfully collected. This way, these materials can be used again as recycled content for new beverage packaging. This legal mechanism to guarantee a “right of first refusal” to beverage producers will enable them to comply with the mandatory EU targets for the incorporation of rPET and ideally meet their more ambitious voluntary pledges (for example, UNESDA’s Circular Packaging Vision of achieving 50% rPET in 2025 and 100% in 2030, and NMWE’s commitments to achieving 50% rPET by 2030) toward fully circular packaging.”
• A harmonized definition of high-quality recycling and, based on this definition, a ranking of recyclability classes. In such ranking, the highest position (priority) should be attributed to packaging that does not pose any recyclability issues, and the recycled material can feed a closed-loop scheme and allow further recyclability of the same quality (for example, food contact) when reaching their end-of-life.

Downcycling fears
The European non-alcoholic beverage industry has long been concerned that other industries like textiles and automotive have been using rPET without contributing equally to its supply. The organizations previously urged the European Commission to provide the non-alcoholic beverage industry with “priority access” – or a similar mechanism guaranteeing “right of first refusal” – to rPET in the upcoming revision of the PPWD.The textiles industry has been criticized for using rPET without contributing significantly to its supply.

Nicholas Hodac, director general of UNESDA Soft Drinks Europe, says: “Recent reports have illustrated that post-consumer rPET from beverage bottles is increasingly used by non-food sectors to boost their environmental sustainability credentials. This [cross-industry use] means that bottles are being recycled (‘downcycled’) into other, lower grade applications.”

“The new material created as a result of this process will no longer be recyclable for food-grade applications. ‘Breaking the loop’ (a loss from the circular bottle stream) goes against the very principle of circularity. In addition, it also creates an unfair situation because food and drink producers are obliged to comply with strict EU health and safety requirements for food contact materials.”

Creating textile circularity
A priority of upcoming EU legislation should be to look beyond beverage containers and enable the creation of closed -loops for all products and packaging applications, the organizations state. The revision of the EU Packaging and Packaging Waste Directive, the new Sustainable Products Initiative, and the Recycled Plastics Regulation and the Sustainable Textiles Strategy all offer great opportunities to achieve this, they highlight.

The EU Strategy for Sustainable and Circular Textiles acknowledges that a growing source of concern is the accuracy of green claims on textiles made using recycled plastic polymers where these polymers do not come from fiber-to-fiber recycling but from sorted PET bottles.

The European soft drinks industry wants to see resource-efficient waste management systems for all industries, including automotive.“Beyond the risk of misleading consumers, such a practice is not in line with the circular model for PET bottles, which are fit for being kept in a closed-loop recycling system for food contact materials,” according to the strategy. In addition, the strategy adds that textile businesses should be encouraged to “prioritize their efforts on fiber-to-fiber recycling and rather make claims on achievements to address this important challenge in closing the loop for textile products.”

Joan Marc Simon, executive director of Zero Waste Europe, says: “It is time to raise EU ambitions and define ‘high-quality recycling.’ Introducing such a definition in the EU legislation will incentivize investments in recycling infrastructure and foster resource efficiency across the whole production of products and packaging materials.”

According to AIJN, Changing Markets Foundation, NMWE, UNESDA Soft Drinks Europe and Zero Waste Europe, the shift toward truly circular products and packaging can only be successful if each producer invests in the design for recyclability, collection and incorporation of its own (recycled) materials, without “free-riding on others’ efforts.”

Tomorrow, PackagingInsights will publish further insights on this issue from Nicholas Hodac, director general of UNESDA Soft Drinks Europe, and Nusa Urbancic, campaigns director at Changing Markets Foundation.

By Joshua Poole