Brussels, 2 December 2022
Natural Mineral Waters Europe supports the revision of the Packaging and Packaging Waste legislation and wants to be a partner in achieving closed loop recycling for our packaging. While we welcome some aspects of the European Commission’s proposal, announced 30 November 2022, there is additional work to be done to make it fit for purpose for our sector.
Deposit return schemes and recycled content
Effective, scaled packaging collection is a fundamental prerequisite for producers to meet recycled content targets. The introduction of mandatory deposit return systems (DRS) for recycling is a very positive step towards enabling circularity through high quality collection. This model is already providing high quality PET bottles where it is in place.
However, if our sector is to reach the proposed recycled content targets (30% by 2030; 65% by 2040), the proposal needs to enable closed loop recycling by granting our sector priority access to a fair share of the recycled bottles it puts on the market. Currently, a large number of PET bottles are downgraded into lower-grade, non-recycled applications – such as textiles and other industries.
Finally, DRS should be in place by 2028 at the latest so that the system is mature before the 2030 recycled content and reuse targets kick in.
Reuse and refill
Our sector is already offering reusable packaging (which is returned to the bottler) and is ready to increase its share where it makes environmental sense. However, the environmental benefits of reuse over closed loop recycling are context specific. Blindly imposing mandatory reuse targets upon each bottler without due regard to the actual environmental benefit contradicts the broader EU decarbonisation objective and will put many of our producers at existential risk, most of which are SMEs. Reuse should be sector-based and employed only when it is more effective, taking into account the overall effect on emissions.
Additionally, the broad definitions included for refill and reuse fail to recognise the unique nature of natural mineral and spring waters. Under applicable EU legislation they must be bottled at source and delivered to consumers in their sealed container. Refill where the consumer manually refills their own bottle) is therefore not an option available to the industry and the proposal should reflect this.
“Our sector is determined to achieve full circularity for its packaging, through a combination of solutions, including closed loop recycling and reuse. As recognised in the Commission’s own press release, recycled plastic is a valuable material, as already shown in the example of PET bottles. We welcome the PPWR proposal as a work in progress, because we see it as a unique opportunity to provide the enablers needed to achieve this goal: swift deployment of DRS, priority access to a fair quota of our recycled materials, and a science-based approach to setting targets. But if these enablers fall short, as is the case in the current proposal, this is deeply concerning for us. We look forward to the integration of those enablers into the final text.
– Patricia Fosselard, Secretary General of Natural Mineral Waters Europe
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 “There will also be mandatory rates of recycled content that producers have to include in new plastic packaging. This will help turn recycled plastic into a valuable raw material – as already shown by the example of PET bottles in the context of the Single-Use Plastics Directive.”