ECN acknowledges the efforts of the Commission in addressing the increase of packaging and packaging waste generation and tackling the limited competitiveness of secondary raw materials. Taking action towards a shift to a full circular economy that prioritises reuse and recycling is key to reaching resource efficiency and contributing crucially to the goals set in the EU Green Deal and Zero Pollution Action Plan to make Europe climate-neutral and toxic-free by 2050.
In light of the Commission’s proposal for a packaging and packaging waste regulation, as representatives of the bio-waste recycling sector, ECN would like to emphasize that biological treatment (composting and anaerobic digestion) is generally not foreseen as a recycling option for any packaging items.
The ECN supports the circular economy and our organisation and its members are committed to increasing separate collection and recycling of bio-waste and are engaged in producing quality compost and digestate to be used in growing media, as well as organic fertilisers and soil improvers applied in agriculture, horticulture and landscaping.
ECN’s feedback relates specifically to Article 8 ‘Compostable Packaging’ of the proposed legislation, which regulates the production and marketing of a specific and limited group of compostable packaging materials. Referring only to ‘compostable’ packaging is misleading as this does not cover all biological waste treatment techniques, like anaerobic digestion, which is a common biological waste treatment technology. It's used for the recycling of separately collected biowaste into quality products, like digestate. Biodegradation under anaerobic conditions shall be considered under Article 8 and especially the listed items in paragraph 1 shall degrade under all industrially controlled conditions in bio-waste treatment facilities.
The ECN firmly believes that policy makers in individual Member States need to have a prominent role in setting requirements and deciding which products can enter composting plants or anaerobic digestion plants based on national experiences. National policies should therefore be used to regulate ‘compostability’, and these policies need to be tailored according to the practices and infrastructures present in the specific countries, as a one-size fits all approach would prove inefficient and inapplicable.
Finally, the ECN calls the Commission to further push the Member States to start the separate collection of bio-waste and to set up the needed infrastructure on biological treatment, so that the mandatory separate collection set by 2023 will be realised.
The complete version of the ECN position paper on the proposal for packaging and packaging waste regulation can be accessed here.
The public consultation on the PPWR proposal is open until April, 10.
