September 2023
Reuse is increasingly being promoted by government, industry and NGOs as a key solution to shifting away from single-use packaging. Indeed, we see many brands and retailers who currently sit in confidential Round Tables going round in circles to try and solve the problem of how to meaningfully transition to reusable packaging. The problem is that without consistent legislation to create a level playing field, even the most committed brands and retailers face a first-mover disadvantage which is inhibiting progress.
Change is hopefully coming in the European market with the EU’s Packaging and Packaging Waste Regulation (PPWR) proposals set to include reuse targets for specific products and categories from 2030. Yet there is a battle raging at the EU level, offering a warning of the difficulties we will face in the UK in adopting the legislation needed to create meaningful change. It’s important that we learn lessons from the debate in the EU, which demonstrates the lengths opponents of reusable packaging will go to in order to hinder progress.
Lobbying
We have seen the single-use packaging industry, supported by some food-to-go brands, mount one of the largest lobbying campaigns ever seen in opposition to the PPWR proposal to include reuse targets for specific products and categories from 2030.
The single-use packaging industry and food service brands have based this lobbying on questionable science, including multiple contentious Lifecycle Analysis (LCA) studies of reusable packaging that have been resoundly debunked by the consultancy Eunomia in their recent report “Unveiling the Complexities: Exploring LCAs of Reusable Packaging in the Take-Away Sector.”
Legislation
For business: the right legislation would:
Competition Law is regularly cited as a concern by business when asked to work together on projects to drive reuse. The UK’s Competition & Markets Authority (CMA) is currently reviewing the role of Competition Law in enabling collaboration to achieve improved sustainability outcomes across different sectors. The draft guidelines recently published set out a number of different scenarios that may be deemed compatible with the Competition Act, and are the first step to provide reassurance to businesses who need to work together on the system change required for reuse.
Most EU countries - including the UK - are bringing in Extended Producer Responsibility (EPR) regulations, designed around a ‘polluter pays’ framework to ensure businesses pay the full cost of the disposal of the packaging waste they create. In a world of dwindling local and national public budgets, it is becoming more and more unacceptable for businesses to privatise the profit, and socialise the cost, of packaging waste.
Alongside EPR is the implementation of Deposit Return Schemes (DRS) in many markets that adds a refundable deposit to the packaging to encourage its return. DRS already enables reuse in some countries, e.g. Germany, however, in the UK we have a proposed (and delayed) DRS designed to only accept single-use packaging, not reusable packaging. This should be addressed as the scheme progresses.
There are plenty of experts in the UK, Europe and globally with actionable reuse policy ideas, all of which include: financial disincentives and bans for certain single-use items; a focus on using modulated EPR fees to stimulate and invest in the necessary reuse infrastructure; targets and mandatory reporting as well as support for the growing reuse sector.
Conclusion
To us it seems that the key voice missing from the public debate is that of big business - the retailers and FMCG brands who need to develop, and mainstream, reusable systems. This is especially true of the debate raging in Europe where we see an active coalition of NGOs and new reuse businesses in a David & Goliath fight - with no real support from global brands or the voluntary groups that represent them (Plastics Pacts, the Ellen MacArthur Foundation’s Global Commitment etc.) We should remember these voluntary commitments were set up because business said that legislation wasn’t needed, as the change would come. Well it hasn’t, and the efficacy of voluntary commitments to reduce single-use packaging is now in question.
We have now seen both Nestle and Unilever publicly call for reuse targets (albeit with a 10 year transition period which we would argue is too long) as well as dozens of major brands who signed the Business Coalition for a Global Plastics Treaty, agreeing that “countries should start setting binding, quantitative, and time-bound reuse targets”.
What is needed now is more leadership from well known brands to come out and promote reuse to support lawmakers in implementing the right legislation to enable reuse to scale.
Catherine Conway is the Director of Unpackaged https://www.beunpackaged.com
The opinions expressed in this blog are held by the author and not necessarily those of the wider Link membership.
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