REGULATION | ANALYSIS
tions do not convert waste to fuel or for incineration, backfilling, and landfilling.
Details The Single Use Directive will have to be amended to be in line with these new targets. In addition, the industry is awaiting the EU’s decision regarding the application of a mass balance approach to calculate recycled content in packaging, which would likely unlock investments in non-mechanical recycling technologies. The obligation to
introduce Deposit Return Systems (DRS) for single-use plastic bottles and single- use metal and aluminium beverage containers up to 3l is to be unequivocally welcomed, given the higher rates of PET bottle recovery in countries where a DRS is already operating and the high and growing demand for rPET. Member states will only be able to opt out of this obligation by achieving a 90% separate collection rate through other means in 2026 and 2027.
Similarly to be welcomed
are common Design for Recycling criteria with the aim to make all packaging recyclable from 2030 and, lifting “recyclability” from a
theoretical concept to a real-world activity, to be “recycled at scale” from 2035. Packaging with less than 70% recyclability will be banned from 2030. The devil lies in the detail
here as the definition of “at scale” is to be established at a later stage by delegated act, based on the volumes of packaging placed on the market, volumes separately collected, recycling rates for the specific type of packag- ing and installed recycling infrastructure. If the new recycled content targets will not generate sufficient investments into collection, sorting, and recycling infrastructure this measure could fall short of its potential. From entry into force of the new Regulation, which is expected to be around 2025, single-use plastic grouped packaging, single-use packaging for fresh fruit and vegetables, single use packaging for foods and beverages filled and consumed within HORECA premises, single-use packaging for condiments, preserves, sauces, coffee creamer, sugar and seasoning in the HORECA sector, and single-use hotel miniature
About the author
Silke Einschuetz is Senior Consultant Recycling & Sustainability at AMI Consulting, which has published a series of reports on developments in mechanical and chemical recycling of plastics. Find out more about the reports:
www.ami.international/cons/ markets/RecyclingSustainability
packaging will be banned. Especially where packag-
ing for fresh fruit and vegetables is concerned this is likely to generate a debate about the increase in food waste resulting from shorter shelf live that might result because of lack of packaging. A complex debate, as illustrated by an article in The Guardian last year which claimed that the fact that fruit and vegetables come in packages of multiples leads to food waste in households. Other types of packag-
ing, including tea/coffee bags, coffee or tea system single-serve units disposed together with the used coffee products, sticky labels attached to fruit and vegetables and very lightweight plastic carrier bags are required to be compostable in industrially controlled conditions in bio-waste treatment facilities two years following entry into force of the regulation. Further provisions are
aimed at packaging minimisation, with packag- ing to be designed so that its weight and volume is reduced to the minimum necessary for ensuring its functionality and a 40% maximum empty space ratio for grouped packaging, transport packaging
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or-e-commerce packaging, all from entry in force of the Regulation.
Detailed labelling
requirements, with labels and QR codes providing information about material composition and reusability of packaging, aim to make it easier for consumers to dispose of packaging in the correct way, enabling higher waste collection rates and less contamination of collected post-consumer packaging waste streams.
Targets Waste prevention targets to be met by all member states require a reduction of packaging waste per capita by 5% by 2030, by 10% by 2025, and by 15% by 2040, compared to 2018 levels. Most controversial are
the reuse targets formulated in the Regulation for a variety of packaging types and these are indeed the targets that have reportedly been watered down following the emergence of leaked information about the draft Regulation and strong criticism from industry lobbyists. Detailed life cycle assessments would ideally be required to establish whether a reuse system is more beneficial than optimised existing solutions.
January/February 2023 | PLASTICS RECYCLING WORLD 13
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