A circular economy is an alternative to the traditional ‘linear economy’ and is one in which resources are kept in use for as long as possible to extract the maximum value. At the end of the service life, products and materials are recovered and regenerated.
One of the challenges with the EC’s proposals is that while the provisions of the Packaging and Packaging Waste Directive (PPWD) are very specific to packaging, these are not. For example, ‘recycling’ targets have been replaced by targets for ‘preparation for re-use or recycling’.
Incpen is concerned that it is simply not clear how ‘preparation for re-use’ would apply to packaging. “A lot of the proposals have been written not even thinking about packaging,” said director Jane Bickerstaffe. “An old lawnmower can be renovated, but packaging doesn't work like that.”
‘Packaging doesn't work like that’
Those concerns are deepened by the fact that the EC's main reference point, the Waste Framework Directive (WFD), is concerned only with municipal waste. The most important types of reusable packaging are supply chain assets such as pallets and crates, which do not fall under the remit of the WFD.
Incpen also reported that requests for clarification from the EC had so far produced sharply divergent views on the difference between ‘reuse’ and ‘preparing for re-use’. “The problem with concepts that are not clearly defined is that they can often be misused not always intentionally,” said Bickerstaffe.
Industry is equally nervous about the targets appearing under the ‘preparation for re-use or recycling’ heading. For example, the UK recycled 68.3% of its glass packaging in 2013. Under the EC’s current proposals, the target rises to 75% in 2025 and 85% in 2030. Metal packaging has even further to climb.
“The numbers look unrealistic and are politically-driven,” said Bickerstaffe. “The process of recycling has its own environmental impact, from road transport to water and energy usage. So a higher target does not necessarily mean lower overall impact.”
It is also clear that, once very high levels of recycling are achieved, a series of extremely challenging barriers comes into play, including households that will not recycle at all or that sort their waste wrongly.
While plastics have a 2025 target of 55%, the EC suggested reviewing targets for 2030. One counter-proposal is that all 2030 targets should be left open until achievements and feasibility can be reliably assessed for each material type.
In some important ways, the proposals stick with the principles of the PPWD. The fact that the PPWD has its legal basis in the internal market, for example, means that Member States need to notify the EC in advance of any proposed changes at a national level. This might be important, according to Incpen, if the devolved administrations in the UK wanted to introduce measures that could be seen to fragment the market or distort competition.
Depending on priorities, legal implementation of the circular economy proposals could still be three years away.