The European Container Glass Federation (FEVE) responds to the Packaging & Packaging Waste Regulation (PPWR) proposal.
By 2050, the container glass industry aims to achieve a major revolution in the way it produces glass that is fit for a circular and climate-neutral economy.
FEVE supports the objectives of the proposal for a PPWR to ensure a well-functioning internal market, tackle the negative environmental and health impacts from packaging and packaging waste and promote the circularity of packaging.
It also welcomes the European Commission’s ambition to further promote the circularity of packaging.
However, it believes that some of the proposed measures would have strong repercussions on EU consumers and industry in Europe and abroad, without contributing to achieving the objectives of the Regulation.
Below contains a summary of FEVE’s position on the PPWR proposal, which is further explained in its position paper (see link below).
Packaging waste prevention:
- FEVE supports material-specific waste reduction targets (as opposed to the proposed overall waste reduction targets) to ensure all packaging materials contribute individually, equally and fairly to waste reduction.
- Packaging performance criteria must acknowledge ‘product presentation’ to minimise the weight of packaging while allowing packaging design to provide for product identification by the end user or consumer. This would maintain the ability of brands to differentiate, to make products stand out on the shelf and to appeal to consumers. The packaging minimisation criteria should be consistent with intellectual property rights, such as trademarks, industrial design rights, geographical indications, which are recognised by and protected under EU laws.
- Reuse targets are acknowledged as an important waste prevention measure, but it is paramount to ensure that reuse can be implemented in a safe, economically viable and environmentally sustainable way that would bring tangible benefits compared to recyclable one-way packaging.
The recyclability requirements in the proposal are comprehensive and a good basis. FEVE would welcome more ambition in the Regulation with regards to closed-loop recycling, high-quality recycling, ‘recycled at scale’ and the timing for the implementation of the recyclability criteria.
The Regulation should emphasise the importance of separate collection as a prerequisite to guaranteeing high-quality recycling processes and to the fulfilling of the recyclability criteria.
Derogation for substances in glass packaging:
FEVE welcomes the reassertion of Decision 2001/171/EC of 19 February 2001 establishing the conditions for a derogation for glass packaging in relation to the heavy metal concentration levels to encourage recycling and ensure the uptake of recycled glass.
Deposit return schemes (DRS) for one-way glass packaging:
FEVE welcomes that the proposal does not include glass packaging in the scope of the mandatory Deposit Return Schemes (DRS) for single-use packaging, therefore acknowledging that DRS are not the best solution to improve the collection for recycling rate of one-way glass packaging and would put at risk the well-functioning existing glass collection systems in the EU (bottle banks and kerbside collection).
FEVE welcomes that no Recycled Content targets are set on glass packaging. Introducing mandatory targets on recycled content has been conceived as a market driver for materials that do not have well-functioning secondary raw material markets. This approach is not effective for fully recyclable materials such as glass for which demand of recycled material largely exceeds supply.
Packaging experts should be involved in the development of highly technical secondary legislation, and FEVE recommends the creation of a Packaging Forum.
Click the button below to read FEVE’s full response to the PPWR proposal.