They fail to acknowledge that both reusable and highly recyclable one-way packaging are complementary and necessary means to achieve the circular economy goals of the EU Green Deal. The former should not replace or compromise the latter.
“Metal Packaging Europe (MPE) continues to question setting reusable targets when, at the time of publication, there is no scientific evidence to confirm that reusable packaging always delivers better overall performance than optimized one-way packaging systems, which achieve high recycling rates”, said Leonie Knox-Peebles, CEO of Metal Packaging Europe. Before setting reuse targets for 2040, and in the spirit of fair competition, we ask the Commission that the positive impact of reuse on the environment be critically assessed.
With a recycling rate of 85.5% for steel packaging and one close to 76% for aluminium beverage cans with an ambition to reach 100% by 20303, the metal packaging industry welcomes the introduction of performance grades to assess the recyclability of packaging and the specific reference in the text to eco-modulation of extended producer responsibility (EPR) fees to incentivise the production and use of sustainable packaging.
The industry appreciates and asked for ambitious minimum requirements to ensure well-functioning deposit return systems (DRS) for beverage packaging. However, those presented in the proposal fall short of guaranteeing a level playing field and high collection targets among all materials, with transparent reporting and no cross-subsidisation.
Finally, this proposal contains a large number of definitions, some of which should be clearer, more concise, and more consistent. It is also important to ensure that definitions do not contradict existing legislation.