Imagine, for a moment, that you are the owner of a small natural mineral water producer who is committed to sustainability (the vast majority of producers are local SMEs).
You work with a natural product. In recent years, you have been endeavouring to lower the environmental footprint of your packaging, meet the requirements of the Single Use Plastics Directive (SUPD), improv your water use ratio and lower your carbon emissions. You have invested in new bottling lines, funded extended producer responsibility schemes and purchased recycled PET at prices higher than virgin material. Your product is packaged in lighter bottles which have bodies which are 100% recyclable.
The Packaging and Packaging Waste Regulation (PPWR) represents an opportunity to continue to move forward, but it could also create insurmountable barriers for your business, or other unintended consequences, if it is too rigid and fails to acknowledge the practicalities of implementation.
For example, a dogmatic approach to reusable packaging may not make environmental sense, looking at your footprint. As is typical, you are producing natural mineral water in a remote area, and the quality of your product (and EU legislation) requires that you bottle at source. Perhaps you are a Greek producer serving dozens of islands. The reverse logistics of reuse would significantly increase your carbon footprint from returning empty reusable bottles. A recent study from the Norwegian Institute for Sustainability Research points out that, in some cases, closed loop recycling might have less impact on the environment, pointing at the impact of transport.
A simple complementarity approach between reuse and recycling would allow you to meet EU sustainability goals based on the most environmentally-beneficial outcome in your context.
A reuse model would also force you, and every producer, to invest millions of euros once again, in costly new bottling lines and reverse logistics. With no guarantee whatsoever that retailers (or shoppers) will purchase this packaging, your product may never reach the consumer.
By keeping reuse targets at retailer level, the PPWR would maintain exactly the same ambition, without crippling your business.
Supporting ambition with the necessary enablers
The PPWR’s success necessitates a pragmatic framework that fosters sensible change. Consider the example of grouped packaging, where a blanket ban is unlikely to achieve its aim and may cause more harm through unintended consequences.
The stated intent behind the Commission’s original proposal is to deter overconsumption. Therefore, extending the grouped packaging ban to natural mineral water and spring water or milk, where typical volumes support normal consumption in line with EFSA’s guidelines for daily intake, is ill-conceived.
Imposing a ban on grouped packaging for bottles would introduce logistical hurdles for retailers and inconvenience for consumers, without providing eco-friendly alternatives.
As trilogue negotiations begin, it is imperative we find solutions that maintain convenience and healthy choices, without compromising sustainability. We must reflect a collective commitment to a circular economy while acknowledging the practicalities of implementation.
The need for nuance
Ambition must go hand-in-hand with enablers if the PPWR is going to succeed. Ambitious targets should exist within a flexible, rational framework that supports industry evolution, and does not jeopardise the vitality of SMEs.
“Our sector is determined to continue its journey of transformation. We deserve to have the right legislative tools to support all producers who will implement change,” said Alessandro Pasquale, President of Natural Mineral Waters Europe.
For more on our position on these topics, and on Deposit and Return Systems and the principle of priority access to recycled material, please visit our dedicated PPWR webpage at www.nmwe.org/ppwr-position.