(Brussels, 22 January 2019) Europe’s food and drink sector supports the overall ambition of this Directive, while we regret the legal challenge it may pose to the Internal Market. The food and drink sector is committed to stepping up efforts to improve plastics use, reuse and recycling as well as maximising the use of available resources.
FoodDrinkEurope members are striving to improve waste management practices at every stage along the food supply chain, always prioritising and ensuring food safety. As reflected in FoodDrinkEurope’s Sustainable Packaging Roadmap, many food and drink organisations are already taking significant actions to find new and innovative ways to improve the circularity of packaging, including plastics, and to address the issue of plastic pollution.
FoodDrinkEurope would like to highlight in particular the following aspects:
Clarification of the scope and definitions
The food and drink industry welcomes the efforts to better frame the definitions and scope of the proposal, and is committed to working together with EU policymakers to facilitate a harmonised understanding during implementation of what constitutes a single use plastic product in the case of “food containers”.
Recycled content and collection rates
FoodDrinkEurope members, The European Federation of Bottled Waters (EFBW) and UNESDA - Soft Drinks Europe are active supporters of the circular economy and have already submitted voluntary pledges to collaborate with the recycling industry to use at least 25% recycled PET in their beverage bottles by 2025, on the basis of an EU average. This pledge was combined with a commitment to increase collection rates of PET bottles and their caps, as to achieve this ambition beverage producers require a consistent supply of economical and compliant, high-quality food-grade material. We are consequently concerned, particularly for SMEs, about the 2025 collection target being reduced to 77% and delayed to 90% only in 2029. This undermines the industry’s ambition, whilst also setting a mandatory 25% recycled content target for PET bottles by 2025 and a mandatory 30% target for all beverage bottles by 2030. Therefore, we urge the European Commission to address the secondary raw material supply challenges that are specific to the food and drink sector as a top priority in its new platform, the Circular Plastics Alliance.
PET is 100% recyclable and, like the EU, our industries are determined to help stop the littering of our bottles and their caps. An impact study undertaken by PricewaterhouseCoopers finds the European Commission’s proposal to introduce mandatory tethered caps on plastic beverage bottles could create between 50,000 to 200,000 tonnes more plastic; create additional CO2 equivalent of 58 to 381 million kg and an economic cost of at least €2.7 billion. Whilst FoodDrinkEurope, EFBW and UNESDA believe that a focus on high-performing infrastructure is much more efficient to achieve high collection rates for bottles and caps (see pledges to increase collection rates), we do welcome the recognition that implementing the Directive requirement of caps that remain attached will take more time than initially foreseen.
Extended Producer Responsibility
FoodDrinkEurope supports the principle enshrined in the revised Waste Framework Directive that preventing litter is a “shared effort between competent authorities, producers and consumers.” We have strong doubts about whether the waste management systems in the provisional agreement will work, since litter prevention must be taken forward through a comprehensive, shared and holistic approach to infrastructure, innovation and education and law enforcement. The food and drink industry will continue to take its share of the responsibility towards helping to prevent littering alongside other actors. We will continue to work together as brand manufacturers and with other stakeholders to invest in innovation to improve the recyclability of our products, contribute to develop well-functioning collection, sorting and recycling infrastructure and to provide consistent and clear information for consumers.