We, Europe’s non-alcoholic beverage industry, represented by the European Fruit Juice Association (AIJN), Natural Mineral Waters Europe (NMWE) and UNESDA Soft Drinks Europe, together with leading NGOs, including Changing Markets Foundation and Zero Waste Europe (ZWE), believe that we have the duty to contribute to building a better Europe for us all and for generations to come.
We are taking action. We are driving circularity forward. Our common vision is that an effective way to reduce waste is to prevent it in the first place, but also to give it a new life by collecting it properly and recycling it into a new product of the same quality. We believe that redesigning products for waste reduction, recycling and reuse, making products fully recyclable, achieving 90% collection of beverage packaging and using more recycled plastic in beverage bottles are essential steps to achieving a circular economy.
Our circularity efforts will only be successful if we can also count on enabling legislative measures. That is why we call on EU decision-makers to create the right enabling policy framework to help accelerate the transition to a circular economy in Europe. From a recycling perspective, this supportive regulatory framework needs to ensure resource-efficient waste management systems to enable closed-loop recycling. This means that waste is collected and recycled, preserving the value of the material, so it can be used again to make a product from the same category it originally came from, with minimal loss of quality or function.
To achieve this, we call for a “priority access”, or a similar legal mechanism that guarantees a “right of first refusal” to beverage producers to facilitate their fair access to the food-grade recycled materials coming from the products they placed on the market and which were successfully collected and recycled.
Going circular – How we can make it happen
The EU Circular Economy Action Plan has the ambition of accelerating the transition to a circular economy. This will require significant changes in the way we produce, use, reuse, collect, recycle and incorporate recycled materials in products. A circular economy entails retaining the values of materials for as long as possible and at its highest quality. Therefore, the more closed-loop a system is, the more resource efficient it will be by ensuring that high quality materials can be re-used multiple times for the same application. With the right enabling policy framework this can be achieved.
Patricia Fosselard, Secretary General of Natural Mineral Waters Europe (NMWE), comments: ‘’For beverage bottles, the first elements of such an enabling policy framework already exist with the introduction of mandatory separate collection and recycled content targets in the EU Single-Use Plastics Directive. However, it is clear today that a number of additional policy measures are needed for beverage producers to be able to meet those EU targets and move further towards a closed-loop system.’’
The main policy conditions that should be created are:
• mandatory minimum requirements for Deposit Refund Schemes (DRS) to facilitate the roll-out of efficient waste collection schemes and the achievement of the EU separate collection targets.
• a mechanism that grants beverage producers fair and necessary access to the recycled materials deriving from the beverage containers they put on the market and which were successfully collected and recycled. This way, these materials can be used again as recycled content for new beverage packaging. This legal mechanism to guarantee a ‘’right of first refusal’’ to beverage producers will enable them to comply with the mandatory EU targets for the incorporation of recycled PET (rPET) and ideally meet their more ambitious voluntary pledges (e.g. UNESDA’s Circular Packaging Vision of achieving 50% rPET in 2025 and 100% in 2030 and NMWE’s commitments to achieving 50% rPET by 2030) towards fully circular packaging.
• a harmonised definition of high-quality recycling1 and, based on this definition, a ranking of recyclability classes. In such ranking, the highest position (priority) should be attributed to packaging that does not pose any recyclability issues and where the recycled material can feed a closed-loop scheme and allows further recyclability of the same quality (for example, food-contact) when reaching their end-of-life.
Let us close the loop - plastic bottles should get recycled into new plastic bottles
A growing number of non-food sectors have laudably made circularity commitments, but they are still very far from investing in collecting and recycling their own materials to create new ones. Instead, they are using food-grade recycled plastic used in beverage plastic bottles to produce their products, such as clothes, toys and tires, which they then market as ‘’circular’’. Turning plastic bottles into non-food applications which then can no longer be recycled into new bottles cannot be defined as circularity.
As Nicholas Hodac, Director General of UNESDA Soft Drinks Europe, points out: ‘’Recent reports have illustrated that recycled PET from beverage bottles is increasingly used by non-food sectors (textiles, automotive, etc.) to boost their environmental sustainability credentials. This means that bottles are being recycled (“downcycled”) into other, lower grade applications. The new material created as a result of this process will no longer be recyclable for food grade applications. ‘Breaking the loop’ (a loss from the circular bottle stream) goes against the very principle of circularity. In addition, it also creates an unfair situation because food and drink producers are obliged to comply with strict EU health and safety requirements for food contact materials.’’
A priority of upcoming EU legislation should be to look beyond beverage containers and enable the creation of closed-loops for as many products and packaging applications as possible. The revision of the EU Packaging and Packaging Waste Directive, as well as the new Sustainable Products Initiative, the Recycled Plastics Regulation and the Sustainable Textiles Strategy - all offer great opportunities to achieve this.
Clothes made from plastic bottles need to become out of fashion
The EU Strategy for Sustainable and Circular Textiles acknowledges that a growing source of concern is the accuracy of green claims on textile made on using recycled plastic polymers where these polymers do not come from fibre-to-fibre recycling but from sorted PET bottles. “Beyond the risk of misleading consumers, such a practice is not in line with the circular model for PET bottles, which are fit for being kept in a closed-loop recycling system for food contact materials”, according to the strategy. In addition, the Strategy adds that textile businesses should be encouraged to “prioritise their efforts on fibre-to-fibre recycling and rather make claims on achievements to address this important challenge in closing the loop for textile products.”
Joan Marc Simon, Executive Director of Zero Waste Europe, says: ‘’It is time to raise EU ambitions and define «high-quality recycling»1. Introducing such a definition in the EU legislation will incentivise investments in recycling infrastructure and foster resource efficiency across the whole production of products and packaging materials.’’
Promoting circularity is everyone’s business
When it comes to recyclability of packaging, according to AIJN, Changing Markets Foundation, NMWE, UNESDA Soft Drinks Europe and Zero Waste Europe, the shift towards truly circular products and packaging can only be successful if each producer invests in the design for recyclability, collection and incorporation of its own (recycled) materials, without free-riding on others’ efforts. For each sector, the ultimate goal should be to achieve «closed-loop recycling».
Food and drinks producers are already investing heavily into separate collection to enable good quality material to be recovered. It is time for everyone to play its part.
By the European Fruit Juice Association (AIJN), Changing Markets Foundation, Natural Mineral Waters Europe (NMWE), UNESDA Soft Drinks Europe and Zero Waste Europe
1 High-quality recycling could be defined as: "Recycling that ensures that the distinct quality of the material (the polymer, or the alloy, or the glass, or the paper fiber) is preserved or recovered so as to ensure they can be re-used in products with the same market value (compared to the correspondent virgin product) and allows further recyclability of the same quality when reaching their end-of-life. Such “distinct quality” should include, for example, food-contact quality /suitability.”
