Europe’s sustainable packaging rules should be bold – and fair
Packaging plays an essential role in protecting products during storage and transport, ensuring their quality and providing information about contents and usage. However, packaging waste takes its toll on the environment. Europeans generate an average of 180kg of packaging waste a year, and the European Commission estimates that without action, this would rise by 19% by 2030.
In the brewing sector, we have innovated and invested over many years to ensure our packaging becomes ever more sustainable, which is why we support the broad aims of the Commission’s proposals to cut packaging waste.
The Commission’s draft Packaging and Packaging Waste Regulation (PPWR) covers different containers, with a particular focus on beverage packaging. It aims to “tackle this constantly growing source of waste and of consumer frustration” as it seeks to ensure all packaging be reusable or recyclable by 2030. This could be one of the most significant pieces of EU environmental legislation of this Commission, which explains why Environment Ministers are debating the issue this week and four European Parliament committees are working on the PPWR.
As brewers, we not only understand but embrace these aims. Leading by example, brewers have a core belief that whilst making beer, we can have a positive impact on the planet. We take our responsibility to limit the environmental impact of beer packaging throughout the lifecycle by reducing, reusing and recycling. We support the circular economy and the systems intended to ensure containers be returned and don’t go to landfill or end up as litter.
We are part of the solution, but need legislation to be proportionate, well-targeted, non-discriminatory, and coherent.
What does that mean concretely?
Proportionate: a sustainable brewery with one filling line and selling all its beer in recyclable cans that are collected and recycled through a well-functioning return system should not have to rush through investments in an expensive additional bottling line just to meet new producer-level reuse targets.
Well-targeted: a well-functioning national return system, for reuse or recycling of beer containers, that already functions sustainably and exceeds targets, should not be disrupted by new EU governance structures or cannibalised by a need to meet other arbitrary targets in the PPWR. Countries and individual companies are at differing starting points on the balance between reuse and recycling, often linked directly to the local beer culture and the business structure of the operator in question.
Non-discriminatory: A container is a container and the rules should be agnostic towards its content. Competing beverage sectors must not be granted a priori EU-mandated exemptions from reuse targets and obligations around deposit return systems. Non-discrimination, which is a general principle of EU law and, regarding beer, acknowledged by the European Court of Justice, allows for products to be treated differently only if justified by objective reasons.
Coherent: The overall objectives of the EU Single market and Green Deal must be recalled when assessing each measure. For example, beer kegs and the volumes they hold must be taken into account when measuring progress against reuse targets – a 50-litre beer keg cannot be treated as a comparable unit to a 20cl bottle or a 33cl can. Equally, for deposit systems to function optimally, priority on-label must be given to the deposit logo over any other packaging handling instructions that ultimately may distract the consumer from returning the package through the right system.
While meeting targets and obligations will be a challenge and we will need time for necessary adaptations, the brewing sector’s commitment to a sustainable future for beer is real. We recognise our responsibility to continue to deliver, within a good functioning EU Single Market and an ambitious EU-wide environmental sustainability agenda, including for packaging and packaging waste.
However, for all the noble aims of the PPWR proposals, there are elements in the draft that are problematic. Some brewers, both big and small, would have to create new packaging lines purely to meet targets, even if the environmental cost was not justified. Well-functioning systems are not being ringfenced from the impact of one-size-fits all solutions proposed in the EU Regulation. Brewers, for the simple reason they are leaders in packaging sustainability, are being discriminated against versus their closest competitors on the market. Labels may be overcrowded with multiple logos that distract from the only information the consumer needs – a deposit can be redeemed against this package. Despite kegs perhaps being the ultimate sustainable packaging solution – a large container reused time and again over more than thirty years before being recycled – they risk being discouraged in order for misplaced targets to be met.
Even once these concerns are met, brewers cannot overnight change packaging equipment and distribution schemes. It is crucial therefore that appropriate transition periods, of on average five years, kick in not just after adoption of primary legislation but also after each implementing act, many of which will determine exactly how each operator needs to adjust its business to deliver on the objectives.
We expect these to be amongst the issues MEPs and ministers continue to discuss when they debate the PPWR, including in the Environment Council.
Last week, the European Parliament Beer Club held a special briefing on the PPWR. The experts included its President MEP Ivan Štefanec, the Vice Chair of the Parliament’s Intergroup on Climate Change MEP Franc Bogovič and Cor Waringa from The Brewers of Europe, as well as the European Commission’s Director for the Circular Economy in DG Environment, Aurel Ciobanu-Dordea.
Mr Ciobanu-Dordea recognised that brewers are pioneers in recycling and reuse. “I encourage the beer sector to remain champions of sustainability.” He also recognised that there is scope to amend provisions in the proposal. “We will reflect on your arguments,” he said.
We are grateful for the Commission’s willingness to review these elements. We look forward to working further with the Commission, EU Member States and the European Parliament to ensure a final Regulation that is proportionate, well-targeted, non-discriminatory and coherent.