The three boxes the PPWR must tick to achieve its objectives.
We are only a week away from the European Parliament’s vote on the Packaging and Packaging Waste Regulation (PPWR). With packaging representing 36% (Eurostat, 2019) of municipal waste in Europe, the regulation has the potential to trigger a vital acceleration towards circularity. However, there is also a risk that its provisions will put a huge burden on industry, whilst missing consumer requirements, or limiting economic scopes, without even delivering the intended environmental impact.
Muriel Lienau is the CEO of Nestlé Waters in Europe.
At Nestlé Waters, preventing our bottles from becoming litter is a responsibility we take very seriously. Our packaging is already designed for closed loop recycling and widely collected. We support this by using increasing proportions of recycled content and promoting improved collection. As a result, we’re on track to deliver on our promise to use 50% recycled PET (rPET) globally by 2025, consistent with the PPWR’s proposed direction.
And yet more remains to be done, by us and our peers, to ensure our bottles do not become waste. This is why we firmly support an ambitious regulation on packaging circularity in Europe.
Destination: Circularity in Europe
The PPWR aims to ensure that all packaging is reusable or recyclable in an economically feasible way by 2030. There is no question on the urgent need to achieve this. Nestlé Waters and our counterparts across the natural mineral water industry are committed to doing our part. But to accelerate, we need a strong, consistent and evidence-based regulation, built to tackle barriers to circularity and shape the transition in an economically and environmentally sound manner.
From my perspective as the head of Nestlé Waters in Europe, there are three critical points I would ask MEPs to consider as they prepare to vote on this landmark regulation.
1. We need complementarity of reuse and recycling to ensure net environmental benefits.
The PPWR covers a diverse range of packaging types. As such, it includes provisions for a variety of routes for waste management, including both reuse and closed-loop recycling for beverage bottles. This makes absolute sense, provided the two remain complementary to each other and are implemented wherever they deliver the greatest environmental benefits.
While both models are designed to reduce the use of virgin PET, the overall environmental impact will depend on many factors including bottle weight, transportation distances, and the related infrastructure. In the case of natural mineral waters which – by law – must be bottled at source, for example, the implementation of reuse without considering these specifics could lead to increased carbon emissions. In addition to the potentially negative environmental consequences, the financial burden of proposed re-use targets puts the future of our industry at risk: We are already committed to financing better collection and high quality recycling, but would simultaneously need to invest in new production lines and logistics for reuse models.
This is why we’re urgently calling for a regulation with the flexibility to allow a range of solutions to co-exist for the most long-term sustainable outcome. Various provisions have already been proposed by MEPs in ENVI, outlining exemptions based on ambitious criteria to ensure reuse and recycling complementarity. This direction is widely supported by industry, as expressed in a joint letter published today. We believe these proposals would allow selection of the option offering optimum environmental performance, and urge MEPs to reconsider their inclusion in the PPWR. We would also ask MEPs to review the level of ambition of the proposed reuse targets – these should remain realistic and achievable, and be based on a robust impact assessment which is missing so far.
2. We need a framework for better collection that allows us to deliver on our commitments.
As an industry, we want to do our part to ensure packaging circularity. For us to achieve this, the PPWR must set in place the necessary enablers. This begins with effective, high-quality collection and sorting.
New bottles can be made of up to 100% recycled material, but this requires high collection rates and proper separate collection. Unfortunately, growing demand for high-quality recycled PET from other industries means insufficient quantity of food grade rPET for beverage manufacturers. This will worsen if we are forced to transition to reuse models without considering the impact of this on existing, well-functioning recycling and collection systems.
Deposit Return Systems (DRS) offer the most effective way to improve PET collection and sorting. They have already been proven to deliver collection rates of over 90% and enable high-quality bottle-to-bottle recycling.
As such, we strongly support a regulation that makes DRS for recycling mandatory (and run as not-for-profit) wherever existing collection schemes fail to deliver high separate collection rates. We believe this is the only way to ensure bottles are collected and separated at the levels required to make our bottles circular and meet the PPWR’s proposed recycled content targets.
3. We need fair access to recycled content to achieve true closed loop recycling and a viable future for the industry.
Separately collected PET bottles can be recycled to produce a new bottle in several loops. However, because of its superior quality, rPET is highly sought-after. This results in food grade material being downcycled into other products. When this happens, the potential for ongoing recycling in a high quality, low emission loop is lost.
MEPs have already recognized the value of closed loop recycling, but achieving this in practice requires a fair and well-functioning internal market for packaging.
To be able to increase recycled content in our bottles, we need those bottles back! This is why we are asking for a legislative and regulatory framework that gives us equitable access to collected bottles.
The natural mineral water industry needs a strong enabling framework.
At Nestlé Waters, we are making steady progress towards full circularity of our packaging.
It’s a vital journey and one that is integral to our business, where we are proud to be making an active contribution to delivering sustainable packaging and encouraging effective collective and recycling, focusing our investments for maximum environmental benefit.
At this critical time, we need a consistent and enabling framework that helps the industry shape this transition in a manner that is both environmentally and economically sound.
Supported by a strong enabling PPWR framework, we are confident that we and our peers will be able to accelerate progress and collectively deliver on packaging circularity in Europe.