CEGROBB is working on a Joint-Statement towards PPWR

CEGROBB and its members welcome the approach of the EU Commission to set a European legal framework for packaging – in particular also reusable packaging – with an EU Packaging and Packaging Waste Regulation (PPWR) and to launch this in the form of a regulation. The legislative approach results in correct and good rules to promote climate-friendly reusable packaging not only in Germany but in the entire European Union and to place it on the market in a sustainable manner. We expressly support the goal of expanding the circular economy and strengthening resource and climate protection. In addition to the opportunity to fundamentally promote and expand the reuse of packaging in accordance with the European waste hierarchy, the EU Commission’s proposal for the amendment of the Directive (94/62/EC), which has been in force since 1994, also poses considerable risks – especially for the wellfunctioning beverage reuse systems which existed in some countries for decades.

CEGROBB encourages its members to review the proposal and its impact on existing reuse-/deposit-systems, definitions and quotas related to our wholesaler’s business activities and established processes within our member-countries in order to avoid the following

A mix of overregulation and underregulation will force the stop of traditional ways to operate reuse systems and will create a chaos of rules and responsibilities

• A new rigid organisational structure with unrealistic rules for management, governance and reporting will destroy current systems and their traditions and will be very expensive to implement.
• The obligation to take-back reusable packaging will not be with retailers, but with the operators of the reuse system, i.e. retail might not have to take reusable bottles back, putting the business of beverage wholesalers at risk.
• EU targets are much lower than the actual market share in many countries where reuse systems already work, Member States will not be allowed to set their own targets that go beyond that.

Companies who use reusable packaging might be driven into bankruptcy because of unnecessary new requirements:

• There would be an obligation for a mandatory individual and permanent labelling of every single packaging unit.
• When the rules for mandatory recycled content enter into force, this material will likely be scarce and too expensive for companies to afford

Crates and other reusable transport packaging on the market will have to be taken off the market completely, latest by 2030, because:

• They do not contain the required recycled content that is mandatory from that date.
• They do not fulfil the rules for maximum empty space that transport packaging will be allowed to have.

CEGROBB is getting involved in this crucial period of the policy negotiations and focus on the following demands:

Labelling via adhesive wash-off labels must be allowed

The provision for individualized and indelible and serial labelling on every reusable container endangers existing reuse systems and may prevent them from staying in operation. It would lead to high operational costs and the forced premature destruction of billions of reusable containers. Individual serial labelling according to Article 11(2) is not necessary to track the performance of reuse systems and should therefor only be an option, not an obligation. Furthermore, adhesive wash-off labels are the industry standard for reusable beverage bottles. This needs to be reflected in permitting the use of adhesive wash-off labels to display the information that will be made obligatory under Article 11.

Exemptions for reusable crates from empty space requirement

The requirement in Article 21, stating that grouped or transport packaging may no longer contain empty space that exceeds 40 percent of the total packaging, cannot be met by the millions of reusable beverage crates currently in use throughout Europe. It would lead to the premature destruction of these beverage crates and may create serious problems regarding stackability, transportability, etc.. Reusable packaging and, in particular, reusable beverage crates, should therefore be exempt from the provisions in Article 21, which in our understanding is aimed at single-use packaging anyway.

Exemption from proposed rigid organisational structure for reuse systems

Annex VI (A) of the proposed regulation lays down mandatory requirements for reuse systems for packaging. For many traditional reuse systems, the implementation of such rigid obligations regarding e.g. centralised organisation, governance and reporting is counterproductive and highly unrealistic. On the contrary, such rules would jeopardize and destroy these systems. It is therefore imperative to exempt existing and well-performing reuse systems from the provisions set out in Annex VI.

Introduction of deposit return systems for single-use and reusable packaging in all EU Member States

The proposed PPWR suggests the introduction of deposit return schemes for single-use packaging as well as reuse targets for beverage packaging. Although several essential technical details of the Regulation still need to be greatly improved so that traditional systems are not jeopardized, this objective should fundamentally be welcomed. Deposit return schemes for single-use and reusable packaging should be the norm in all EU Member States.