Unite behind circularity: Single Market fragmentation undermining EU Green Deal, warns industry

17 May 2022 --- European packaging industry associations have submitted a joint letter to EU leaders warning that fragmentation of the Single Market is undermining progress toward the EU Green Deal. The 59 associations called on the EU to create one single circular economy – not 27 separate ones – underpinned by an integrated Single Market. 

January 1, 2023, will mark the 30th anniversary of the establishment of the European Single Market. The signatories to the joint letter – who include CEFLEX, European Plastics Converters and Plastics Europe – refer to the Internal Market as “one of the EU’s greatest achievements” and “the key driver of EU economic integration.”

However, they say Europe faces new challenges and has new priorities. Chief amongst these is the European Green Deal and the need for a transition toward a circular and climate-neutral economy.

“The packaging industry, the consumer goods industry and downstream operators understand this imperative and are fully committed to resource-efficient circularity goals,” the letter reads. “Almost everything we consume is packaged. Packaging is an integral part of a product supply chain, and measures that relate to packaging affect most goods traded within the EU.”

“Preserving the integrity of the Single Market is key to ensuring that packaging materials and packaged goods can move freely around the EU, thus avoiding negative impacts on consumers, companies, the environment and on the resilience of essential systems, such as the food and pharmaceutical sectors.”

Despite this, Member States are increasingly introducing unilateral and often divergent requirements, the associations warn.

EU-wide approach needed
The signatories recognize the “well-intentioned efforts to improve design, manufacture and labeling of goods to improve their potential for repair, reuse or recycling” in the letter. Yet, many of these requirements preempt forthcoming legislative developments at EU-level, compromising the effectiveness of an EU-wide approach, they argue.

Member States are increasingly introducing unilateral packaging requirements and hampering the Single Market, the associations warn.“The increasing number of national measures on the labeling of packaged goods for later sorting is a case in point. These are often implemented at short notice, are contradictory and are not always notified as Single Market rules require. We rely on the Commission to ensure that these divergent rules and their non-notification do not go undetected,” the letter reads.

“Concretely, disparate national packaging requirements impede the use of a single packaging execution and therefore require the redesign of all packaging across the entire Internal Market destined for an individual country. This has the adverse consequence of diverting investments away from other activities to advance sustainability, such as R&D on eco-design and digital traceability of product information for more efficient recycling.”

Redesigning all packaging destined to an individual national market also entails costs for manufacturing, the signatories highlight. This requirement translates into additional production costs for the industry and adverse effects on consumer prices. The loss of economies of scale and the interruption of established distribution models reduce competition within European industry, which is obliged to operate within fragmented national markets.

Furthermore, at each step of the value chain, forecasts have to be revised against real consumption. These disruptions may lead to the destruction of certain products that cannot be placed on shelves. Resources are thus wasted all along the supply chain from raw material suppliers all the way to consumers. This applies to shops, distribution centers, bulk factories, packaging components in the factory and packaging accessories at suppliers.

National labeling requirements
National labeling requirements can also lead to a disruption of efficient distribution systems, requiring suppliers to ship their unsold goods over longer distances when this proves necessary to relabel them according to divergent national legislations, the signatories add. Additional transport increases fossil fuel consumption, with negative impacts on climate and air quality.

Finally, the multiplication of labeling instructions weakens consumers’ ability to sort packaging waste properly, reducing opportunities for recycling.Europe’s beverage industry previous requested priority access to recycled PET supply amid concerns of industry “free-riding.”

“We call on the Commission to take robust and rapid action to tackle national packaging legislation infringing Single Market principles and Article 18 of the Packaging and Packaging Waste Directive. Cooperation rather than unilateral and uncoordinated national action surely represents the best way forward,” the letter concludes.

Recycled PET supply
In related news, Europe’s non-alcoholic beverage industry and NGOs Changing Markets Foundation and Zero Waste Europe recently called 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 supply.

Calls were made by beverage industry associations for EU policymakers to prevent “free-riding” fashion and automotive businesses from disrupting the circular economy by using the recycled plastic supply without contributing a fair share. 

We spoke with experts in the field about how upcoming amendments to the EU Packaging and Packaging Waste Directive could fix this broken material loop.

By Joshua Poole