This position rightly considers the entire life cycle of packaging from its production to its end-of-life. The increased requirements for all packaging in the EU to be considered recyclable, the separate collection targets at 90% and the mandatory recycled content are clear signals that the role of the waste management and recycling industry is being recognized.
FEAD strongly believes that the sector must be stimulated through strong and binding measures to achieve a “real” circular economy. The new requirements support waste management activities by creating a real demand for recyclates and therefore trigger investments in separate collection, sorting, and highly innovative recycling.
However, FEAD wants to raise concerns about Compromise Amendments 16 and 25 which introduce the concepts of closed-loop recycling, priority access to recycled materials and substitution of plastic recyclates with bio-based plastics.
Closed-loop recycling does not consider the current recycling activities of packaging nor the overall sustainability of the process and runs the risk of reducing recycling rates we can achieve today and would limit market opportunities. Furthermore, priority access, if implemented, would be detrimental to the development of recycling capacities in Europe, promoting monopolistic control of recycled polymers and going against free-market principles. This is also the case for bio-based materials which, in these compromise amendments, are equated to recycled materials. Under current legislation, this goes against the principles that govern waste management: a bio-based material is made of raw materials from biomass and does not come from a waste recycling process, so it cannot be considered recycled content. These Amendments undermine all efforts to strengthen the European recycling sector and create unnecessary uncertainty and distrust.
The packaging waste management sector is crucial towards sustainability. That is why FEAD believes that the upcoming negotiations in Parliament and in the Council should take our concerns seriously, to create a strong and stable European recycling sector.
