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CIAA Comments Ecolas Pira Report Final CIAA COMMENTS ON THE ECOLAS / PIRA INTERIM REPORT This document summarizes the comments made by CIAA, the voice of the European food and drink industry, following the expert workshop held on 26 May and the analysis of the Ecolas/Pira interim report. CIAA welcomes the opportunity to comment on this report, as we believe that the on- going stakeholder dialogue can significantly refine and improve the study on the implementation of the Packaging & Packaging Waste Directive carried out by the Ecolas and Pira consultants on behalf of DG Environment. GENERAL COMMENTS ON THE METHODOLOGY Although the interim report constitutes a starting point for the study, there are some concerns about the methodology chosen: - A study on the implementation of the Packaging and Packaging Waste Directive is a complex exercise, with many environmental, economic and geographic implications. The differing nature of each Member State, both from a geophysical, socio-demographic and environmental point of view (different experience in selective collection, different legal obligations of the stakeholders involved, etc.) makes it even more complex. Therefore, we can understand that the consultants have started by assuming some basic premises, which simplify the analysis, although some of them might be argued against (See p. 6 - Paragraph on key assumptions where it is decided to ignore transportation relating to collection, to assume that all plastics recycling is PET recycling, etc.). While trying to simplify the analysis, we should not however adopt a simplistic approach. Now, with these key assumptions, the consultants tend to ignore the reality of the packaging market giving too much attention on two specific materials: glass and plastics (with a unique focus on PET!). CIAA would welcome a broader approach with a detailed analysis of ALL packaging materials (for instance for the plastics, the analysis should not be restricted to PET only but should also include the plastic films). - To assess the environmental and economic impacts of the Packaging and Packaging Waste Directive 94/62, the availability of accurate data is crucial. Naturally if the measurement of the economic and environmental impacts is based on existing studies, then their inherent flaws will be repeated with the risk to come to misleading conclusions (see p. 5 section 1-2-1 and p. 13 section 1-3-5). Besides, the authors should be extremely cautious while extrapolating existing studies that have been carried out some time ago for another purpose. - The social aspect is so far being neglected in the report although it was agreed to follow a sustainable approach to evaluate the implementation of the PPWD. In the same way, to ensure the sustainable approach, the impacts of the Directive on the Internal Market should also be taken into consideration. CIAA understands that this aspect will be covered in another study carried out by DG Enterprise but we regret that both studies are not developed in synchronization. TASK 1: EVALUATION OF THE IMPLEMENTATION OF THE PACKAGING DIRECTIVE 94/62/EC INTRODUCTION It is important to note that the generation of packaging waste per capita has been decreasing - and not growing, as mentioned in the introduction (p.4) – at the EU 15 level, in 2001 vs. 2000. It is particularly the case for the UK, Austria, Luxembourg, France, Spain, Germany and Belgium. ENVIRONMENTAL IMPACTS * From an environmental point of view, it seems clear that the Packaging and Packaging Waste Directive has brought an improvement in the management of packaging waste in Europe. The targets were the same for all packaging material and it has led to the development of selective collection with the same level of requirements for all materials. * Among the 3 scenarios used to assess the environmental impact of the Directive, the “zero recycling” scenario has no real interest. Due to the low budget and tight timetable for this project, the consultants should rather focus on scenarios 2 and 3. For the “baseline policy” scenario (2), it is necessary to clarify what elements are taken into consideration or not. Besides, CIAA has some reservations regarding the modelling of this scenario that has to be based on estimates and extrapolations. We would recommend another approach that a linear extrapolation of the evolution. For the “packaging directive” scenario (3), CIAA would suggest to use the RDC/Pira study as a good basis to quantify the costs and benefits related to the Packaging Directive. In annex, you will find the comments CIAA had elaborated once the RDC/Pira report was published. * To better evaluate the environmental impact of the PPWD, a sensitivity analysis would be extremely useful and would allow to identify and focus on the key impacts that need to be assessed. * Regarding the environmental impacts to be reported, water as an input should be added in the table (See section 1.2.1, p.6). When looking at the energy input for the different packaging materials waste management, the authors of the report should also specify what type of energetic model is used for the electricity production. ECONOMIC IMPACTS * From an economic point of view, it would be interesting to think in detail about the technical burdens which may exist when recycling is to be promoted, as stated in point 1.3.5.4. Present technology has limits that must be considered and higher targets mean higher costs. 2 * Costs assumptions data: The consultants should clarify the methods to analyse the costs. It should also be specified whether these include taxes or not (VAT). Besides, in the interim report, the costs data available are often under-estimated: § Packaging recycling industry (p. 13 section 1.3.4.1): We need to be sure all costs borne by the collection schemes are reflected here, not just relating to the percentage of waste effectively recycled. § The last paragraph of section 1.3.5.2 p. 15 suggests that “the turnover of the compliance schemes may be an indication of the whole packaging recovery sector”. We have some reservations about this conclusion BUT more importantly it would then be essential to be sure of the cost of these schemes. The following sections (p. 16 - p. 36) are all based on cost assumptions that we believe to be well below the true costs of these schemes and therefore risk repeatedly understating this input in later, important comparisons such as those addressed on p. 36. § In section 1.3.5.2 p. 14, it is mentioned that some potential impacts of encouraging reuse would include “increase in turnover for packaging recyclers”. Presumably they mean reconditioners of reusable packs, who are not the same people as recyclers. It should also be stressed that encouraging reuse systems also decreases turnover of companies designing, manufacturing and recycling one-way packages (e.g. can manufacturers in Germany) and corresponding filling equipment. Besides, the reuse will lead to a significant increase of the transport. § In section 1.3.5.2 p. 14 it is suggested some potential impacts of Recovery & Recycling systems would include a “decrease of turnover for raw material producers through substitution by recycled material”, but this excludes the reality of “open loop” recycling, i.e. metal cans into engine blocks, plastic bottles into fibres etc. * In this economic section, costs of the implementation of the Packaging and Packaging Waste Directive for the community should be made available. For instance, figures on the costs of green dot systems should be included in the report. It would also be interesting to provide the costs borne by the municipalities as in general, municipalities are involved in packaging waste management as the PPWD foresees that “these systems shall be open to the participation of the economic operators of the sectors concerned and to the participation of the competent public authorities”. * When looking at the distributive effects, it should be clarified that it is the packaging packer/filler/importer who pays the green dot (recycling/recovery cost) and not the packaging producers (p.21 and p.24). In this section, the distinction between 2 types of “tax payers” should also be made: the consumer and the citizen (p.25). Finally, the term “benefits” should be replaced by “income” (p.24-25). * In terms of methodology, rather than looking at the turnover made by the various actors of the packaging chain, it is rather the economic impacts/costs related to the collection, sorting and recycling as well as the revenue from the sale of secondary materials that should be calculated. To do so, the SOFRES study “Cost-efficiency of Packaging Recovery Systems” can be a good starting point but it should be noted that this study focused on 4 Member States only and not on the EU 15. Moreover, this study compares the costs of the different packaging recovery systems but does not compare the performances of those systems. * In the section on increases or decreases in consumer prices (See 1.3.5.7, p.33), it should be mentioned that the increase in consumer price for recovery/recycling should 3 be partly balanced by a reduction in local taxes when municipalities are no more involved in packaging waste management (e.g. Germany, Austria, Sweden). TASK 2: PACKAGING PREVENTION INDICATORS FOR THE ENVIRONMENTAL PERFORMANCE OF PACKAGING CIAA has strong reservations regarding the use of such environmental indicators: - It is still very much unclear what the objectives/expected results of such indicators should be, who should use those indicators, how they should be implemented, which body should be responsible for their control, who should be in charge of the calculation, etc. Another difficulty is the modelling of the environmental indicators (how can we estimate all indirect effects?). - The approach associated with such indicators does not favour a continuous improvement of the environmental performance of packaging.
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