Draft reuse requirements for drinks packaging are an existential threat to beverage industries and effective existing recycling systems

Brussels, Wednesday 26 October 2022

Our four leading European beverage associations (AIJN – European Fruit Juice Association, The Brewers of Europe, Natural
Mineral Waters Europe, UNESDA Soft Drinks Europe) are united in expressing our profound concern at the mandatory
targets the European Commission intends to set for the reuse of our beverage containers.

According to recently obtained information regarding the upcoming revision of the EU Packaging and Packaging Waste
Directive, the Commission may propose to set discriminatory reuse targets for our beverage packaging already at 20% by
2030 and then as high as 75% by 2040, to be imposed at national level and observed by each individual manufacturer. If
imposed, these disproportionate and unjustified high targets would have a deep impact on our respective sectors, also
forming an existential threat to our many SMEs. They would furthermore lead to the dismantling of a number of highly
effective, existing recycling systems.

The financial cost of implementing such a dramatic reorientation in such a short space of time would be astronomically
high. Established business models across Europe would inevitably and rapidly become unsustainable. Furthermore, the
European Commission is assuming that high targets will lead to rapid consumer uptake. There is no evidence thereof.

While our sectors already have reusable packaging as part of the mix and are committed to increasing the offer of reusable
beverage systems with the right policy measures in place, the reuse targets as currently formulated are unrealistic and
incoherent. They overlook the ongoing huge efforts and investments that we are already making towards achieving
packaging circularity through increased recyclability and collection of our beverage packaging and the use of more recycled
content. Most importantly, there has been no environmental impact assessment indicating that these targets would
achieve their supposed intention of protecting the environment.

In recent years, our sectors have worked tirelessly to ensure we are using 100% recyclable packaging and increased levels
of recycled content in our packaging, and we have campaigned for measures to increase recycling rates. Reusable
packaging is not de facto the only sustainable option as is now being suggested by the European Commission. It is part of
the circularity solution as a complementary action to recycling and reducing beverage packaging in a reasonable manner.

Patricia Fosselard, Secretary General, Natural Mineral Waters Europe: “Our sector is already achieving high rates of
collection for recycling and is steadily progressing towards full circularity. Introducing unrealistically high reuse rates will
significantly compromise this progress and jeopardise the sector, while the environmental benefit of this policy measure is
yet to be demonstrated.”

Nicholas Hodac, Director General, UNESDA Soft Drinks Europe: “Over the last years, we have been investing into more
recyclability, more collection, more recycling, and more reuse to make our packaging fully circular by 2030. It is totally
incomprehensible that the European Commission is disregarding it and asking us to switch entirely to reuse. We can achieve
the Commission’s goal in a much more realistic way that is less harmful for the industry and that makes sense for the
environment.”

Wouter Lox, Secretary-General, AIJN – European Fruit Juice Association: “Reuse should be seen as a complement to
recycling, not as a substitute. Our sectors wish to continue paving the way for full packaging circularity, but that can only
be achieved through the right enablers in place.”

Pierre-Olivier Bergeron, Secretary General, The Brewers of Europe: “There are more than ten thousand breweries in the
EU, aiming to have a positive impact on the economy, people and the planet. Central to the circular European economy,
our progress goes hand in hand with the aims of the Green Deal. Through our packaging and investment in effective
systems, we have demonstrated that reuse and recycling need to be seen as complementary approaches to improving
drinks’ packaging’s environmental performance.”

Together, our four associations represent thousands of businesses in the beverage value chain. We recognise and support
the positive steps the European Commission is taking towards increased circularity, but we call upon the Commission to
rethink its approach and to look at environmental policy as an opportunity to accelerate the circular economy for beverage
packaging through enablers that support industrial policy.

For further information, please contact:

AIJN – European Fruit Juice Association: Since 1962, AIJN – European Fruit Juice Association has been representing the
interests of the entire fruit juice supply chain, from fruit processors to packers of consumer products. AIJN provides a
platform for members to build international coalitions by coordinating collective actions and finding sector-specific
solutions. AIJN’s current membership consists of 18 national associations as Full Members, 1 national association as
Associated Member and 22 businesses as Observer Members. https://aijn.eu/en
Marton Gellert, Public Affairs & Communications Manager, +32 2 235 06 26, marton.gellert@aijn.eu

The Brewers of Europe: Uniting 29 national associations, The Brewers of Europe provides a voice in Brussels to promote
beer and represent the interests of Europe’s 10,000+ breweries. http://brewersofeurope.eu
Simon Spillane, Director – Communications & Public Affairs, +32 2 551 18 10, sws@brewersofeurope.eu

Natural Mineral Waters Europe: Natural Mineral Waters Europe has been the voice of natural mineral water and spring
water since 1953. Today, we represent 550 producers who provide European consumers with unique, healthy and high-quality products. Pioneers in environmental custodianship, our members have a long tradition of working in partnership
with local communities to safeguard the ecosystem around water resources. Our sustainability mission now extends to
achieving full circularity for all packaging. www.nmwe.org
John McLean, Communications Manager, +32 460 97 86 49, john.mclean@nmwe.org

UNESDA Soft Drinks Europe: Established in 1958, UNESDA Soft Drinks Europe is the Brussels-based trade association
representing the non-alcoholic beverages sector. Its membership comprises of 10 companies and 23 national associations
from across Europe. UNESDA members are involved in the production and/or distribution of a wide variety of non-alcoholic
beverages 3 including still drinks, carbonates, fruit drinks, energy drinks, iced teas and sports drinks. UNESDA’s policy
priorities are sustainability (e.g. beverage packaging, collection, recycling), responsibility (e.g. sugar reduction, school
policies, marketing practices towards children and labelling) and competitiveness (e.g. taxation, market access).
www.unesda.eu
Inês Rebelo, Communications Manager, +32 477 860 901, irebelo@unesda.eu