How the European Parliament and the Council can develop rules for a more pragmatic and realistic introduction of reuse

By Peter Harding, President of UNESDA Soft Drinks Europe and CEO of Suntory Beverage & Food Europe

The EU is set to move towards a circular economy for beverage packaging. In just a couple of weeks, Members of the Environment Committee in the European Parliament will vote on their amendments to the EU Packaging and Packaging Waste Regulation (PPWR). In parallel, EU Member States are working towards adopting their position on this file by the end of the year. Among the key areas of attention in the PPWR is reuse and refill. It is absolutely critical that MEPs and Member States support sound measures that ensure that recycling, reuse and refill are complementary solutions, and reject proposals to increase the reuse and refill targets without further assessment of their environmental, economic and social impacts.

The EU is taking a leadership role in driving circularity and the PPWR is among the most ambitious EU policies in this regard. The European soft drinks sector, represented by UNESDA Soft Drinks Europe, supports the goals to better reduce, collect, recycle and reuse beverage packaging. We have already shown that we take bold voluntary actions to contribute to accelerating the green transition in Europe through our commitment to making our soft drinks packaging fully circular by 2030.

Our sector also supports reuse and refill systems as part of the solution to reduce packaging and packaging waste. We are already investing in these systems as a complementary action to our ongoing efforts to reduce and recycle our packaging.

It is fundamental that recycling and reusable systems are complementary solutions and MEPs and Member States should enshrine this in the PPWR. How?

Key ask 1 – Do not increase the reuse and refill targets (Art. 26) without further impact assessment

The European Commission’s impact assessment has been heavily criticised by many stakeholders, including our sector, over the last 9 months. The lack of a proper environmental and economic assessment of the implications of the reuse and refill targets proposed by the European Commission in the PPWR is worrying as legislation should always be developed on the basis of clear and granular data on the costs and benefits of the measures being proposed. So, first things first: the only way to assess the real impact of scaling up reusable systems across the EU is to thoroughly analyse the costs and benefits of setting up these systems in different Member States, different sectors and different distribution channels. As an example, the shift to 10% refillable PET as of 2030 in the EU is estimated to cost more than €16 billion, according to a PwC study.

It is very concerning to see proposals for increased reuse and refill targets for 2030 and 2040 that are not based on any further impact assessment that justifies them. Why forcing beverage manufacturers, of which a majority are SMEs, to make huge investments in reuse and refill systems in geographies or channels where existing well-functioning single-use systems make more sense from an environmental and economic perspective?

In our view, the proposed targets are already extremely challenging and therefore the focus now has to be on providing manufacturers with the necessary enablers and the flexibility to invest in the best packaging mix.

Key ask 2 – Maintain systems enabling refill in the reuse and refill targets (Art. 26)

We are all familiar with the traditional returnable refillable bottle, whereby the consumer buys a beverage bottle in a store and brings it back to the retailer for it to be refilled. This is not, however, the only system to reuse and refill – and it is not always the best solution from an environmental perspective. Asking beverage manufacturers to focus all their investment and innovation only in reuse on traditional returnable refillable bottles takes no account of consumer patterns of shopping and consuming beverages, and stifles the innovative solutions that open up possibilities to match consumers to more sustainable purchasing habits.

Today, there are several innovative reusable solutions that are convenient for consumers, are responding to new consumption habits and are helping reduce packaging as they use little to no packaging, such as home soda dispensers and refill stations in stores and horeca. Why, then, aren’t these at-home and on-the-go solutions, which are recognised by the Ellen MacArthur Foundation as reuse models, counting towards the achievement of the reuse and refill targets? It makes all sense to consider them for the attainment of the reuse and refill targets. The PPWR should secure a future for these innovative refill solutions and the EU co-legislators should therefore support a broad definition of reuse and refill that includes the whole spectrum of available reusable and refill models.

Key ask 3 – Create well-designed exemptions to ensure reusable packaging is only used where and when it makes the most sense

It is essential to make sure that reusable packaging is only introduced where it makes sense from an environmental, economic and consumer perspective. To enable it, the PPWR should provide a form of exemption if certain environmental criteria are met in order to avoid unintended adverse effects of the reuse and refill targets.

Some amendments tabled in the different European Parliament’s committees involved on this file can serve as a positive source of inspiration as they recognise the role of existing well-functioning circular systems. For example, many countries are investing in achieving 90% collection of PET bottles and aluminium cans through the introduction of Deposit and Return Systems (DRS). Let’s encourage these investments!

Now is the moment for the European Parliament and EU Member States to make the PPWR more supportive and more realistic. Our sector will remain constructive and engaged with all stakeholders to help create a stable and enabling policy environment.