Reuse of packaging in the EU Circular Economy Package

The proposal for the revised directive on waste is part of the European Commission’s Circular Economy Package, and it will soon be in the final discussions. The Circular Economy Package is an ambitious programme which aims to help the EU member states make the transition to a stronger and more circular economy where resources are used in a more sustainable way.

The part of the package of decrees on waste concerning packaging waste has met with some dispute; reuse of packaging having been one of the topics.

“The Environmental Committee will deal with the Circular Economy Package later this winter, and it has emphasised reuse as part of the circular economy,” says a committee member, MEP Merja Kyllönen.

“The Environmental Committee has taken the stand that there must be clear incentives that would invite the member states to introduce a waste hierarchy.”

Another objective is to encourage producers to use more reusable and recyclable packaging.

Reuse also plays an important role in the reduction of waste, but most of the member states do not want to include it in the packaging waste targets. The problems arise from different terminologies and practices in the member states.

Prevention before recycling

Reuse means using a product, or part of it, for its original purpose. Glass bottles, for example, that are washed and returned to the plant are reused. The same applies to wooden pallets, plastic bottle crates, metal beer kegs and other packages that remain in the circle for a considerable period of time.

“Terminology on the waste sector can be challenging and complicated. Reusing is not the same as recycling. It means putting products back into use without producing any waste in between,” explains Senior Environmental Adviser Riitta Levinen from the Ministry of the Environment.

The Finnish Waste Act is based on the current EU Directive on Waste and gives reuse a priority over recycling. The benefit of reuse is the fact that it prevents waste. It saves materials: One package can be used dozens or even hundreds of times. On the downside, transporting empty packages increases emissions in transport; however, this problem can be lessened with proper logistics.

“The waste hierarchy prioritises the waste management practices. The prevention of waste production has the highest priority, and reuse is part of this. Preparation for reuse has the second-highest priority, and only next do we find recycling, with the third-highest priority. Other practices come after these; use of waste in energy production, for example, and finally the landfill,” says Levinen.

Finland is keen to reuse

So far, so good. But we face problems when we consider the issue on the EU scale. As policies go, the entire Union is governed by the same regulations, but there are differences in the practices and emphases between individual countries.

Reuse has been considered very important in Finland, and it has been encouraged by the national target-setting efforts and previously also by taxation. The 2014 statistics published by the Ministry of the Environment show that 60 percent of packaging weight used in Finland was reused. Only 40 percent of the packaging ended up as waste.

Even most of the packaging that ended up as waste, 57 percent of weight, was recycled. The combined reuse and recycling rate for all packaging used in Finland in 2014 was a considerable 83 percent.

In terms of weight, reuse is significantly more widely spread that recycling according to the statistics. In 2014, the combined reuse and recycling rate for plastic packaging was 75 percent while the recycling rate was only 25 percent. The figures for wooden packaging were 61 and 13 respectively.

These are excellent figures, and Finland is considered to be one of the top countries in terms of reuse. This image may be slightly misleading in the light of the fact that Finland, along with Denmark, is one of the few EU countries that keep statistics of reused packages.

Even in Finland, some reusable packages have been replaced by recyclable ones; this is especially true for consumer packaging. For example, EU regulations concerning the equal treatment of materials in the single market have resulted in changes in taxation, which encouraged reuse.

“There has been reduction in the reuse of consumer packaging. At least in Finland, the reuse volumes are the strongest in the business sector. Glass bottles and gas bottles are reused to some extent. Even though the deposit bottle system works extremely well, most of the packages collected end up being recycled, not reused,” says Levinen.

Most of the EU countries do not have precise statistics about the reuse of B2B packaging, but reuse of wooden pallets, for example, is quite wide-spread in all member states. If the Circular Economy Package sets targets for reuse, the other countries will have to set up statistical measures for the practice.

Interpretation of terminology varies

Many countries are wary of regulation and in particular of targets that mix products and waste. Packaging is an exceptional product category as the line between waste and a product still in circulation can be very hard to define.

What does “preparation for reuse” mean, for example? The Finnish Waste Act, based on the Directive on Waste, says that it means checking, cleaning or repairing recovery operations, by which products are prepared so that they can be reused without further pre-processing.

In Finland, this has been interpreted to mean that if, for example, a wooden pallet is broken during use and it is repaired before it is used again for loading purposes, this is preparation for reuse. Washing glass bottles, on the other hand, is not preparation for reuse as the bottles are not actual waste at any stage. In other words, repairing wooden pallets has been included in the recycling targets while washing bottles has not.

“This issue has not been defined in any regulations, which is why it is such a big question in the preparation of the directive. Views on the issue vary, and it is possible that we have to review the calculation method for the targets in Finland,” explains Levinen.

In the original proposal published by the European Commission in 2015, the section describing the preparation for reuse would have been amended so that the preparation of not only waste but also of products and components of products would be included. The washing of deposit glass bottles could, thus, have been included in the proposed combined reuse and recycling target.

The Finnish Packaging Association has supported this proposal, although there are fears that it would water down the ambitious recycling targets. If the calculation method proposed by the Commission was applied, Finland would not need to do anything much as the country already meets the recycling targets set for 2030 in almost all packaging material categories.

Targets and incentives

Levinen admits that the target proposed by the commission does pose this risk. For this reason, Finland, together with a few like-minded countries, have proposed a solution that would cover not only the combined reuse and recycling target but also a minimum target for recycling.
“In this scenario, the minimum recycling target would be higher than the current target, but this proposal has not been widely supported,” says Levinen.

According to MEP Kyllönen, the EU’s Environmental Committee has, in fact, proposed targets that are much stricter than those described in the Commission’s proposal.

“The member states are very different from each other, but I think we should expect them to take more dramatic measures. We should ensure that Finland, Sweden and other countries which are quite advanced in terms of the circular economy can’t hold back because some countries are not quite there yet. There’s no reason that the more advanced countries could not be offered incentives,” says Kyllönen.

It is important to have recycling targets that bind all member states, but financial incentives are vital for reaching them. Kyllönen says that the committee has had debates over what kind of incentives and support measures would be best to ensure a more widely-spread use of recyclable and reusable packaging.

“Some countries produce vast quantities of packaging materials. If packages are widely reused, these countries will face financial losses. The countries that have traditional, especially plastic, packaging manufacturing are not very keen on the idea of having to have new investments and production lines in place by 2025 or 2030,” says Kyllönen.

The Environmental Committee and the Committee on Industry have already voted on the proposals for the waste directive. The issue will next be dealt with in the EU Parliament’s plenary session, and the Parliament is expected to give its views in March. The negotiations will then continue between the Parliament, the Council and the Commission. Levinen is still optimistic that reuse will be part of the package:

“We’ll see what happens at the Parliament and the ensuing tripartite meetings. I believe that there will be negotiations on a separate target for reuse and possibly on a combined reuse and recycling target as well.”

Matti Koskinen, photo Atte Lakinnoro