Reducing packaging waste

25 maio 2023

Euroconsumers’ checklist for a regulation fit for consumers.

Empower people, improve the market

80 million tonnes. 177.2 kg per EU inhabitant on average. That is how much waste packaging is generated each year in the EU1. It’s no coincidence that consumers are increasingly worried about the environmental impact generated by overproduction and overconsumption, including packaging waste. Even more, consumers feel responsible and want to do their bit to tackle the problem.

A Euroconsumers survey identified waste management as one of the areas with the highest consumer responsibility2. In fact, this is where consumers put the most effort, with avoiding plastic packaging and opting for products with less packaging in the top five of sustainable actions already taken by consumers3. In addition, another survey on food packaging coordinated by Euroconsumers among 11 countries - including Belgium, Portugal, Italy and Spain - showed overall consumer support (85%) for rules for producers and retailers to use less packaging material or only reusable and recyclable ones4.

Ironically the same survey results also identified waste management as one of the areas where consumers still encounter the most barriers that prevent them from acting more sustainably. The problem is, however, quite basic: next to the issue of excessive or non recyclable packaging, consumers lament it is often not clear if and how packaging material should be recycled.

Making the green shift requires consumers to be on board. When it comes to waste management that seems to be the case. Consumers stand ready to do their part. But they can do even more. If truly empowered they can also push and steer markets towards more sustainable options, becoming an actual driver for more sustainability and improve the market. But for them to be able to make good use of that green consumer power the right framework needs to be in place. One that works for consumers and supports them in their endeavours to be more sustainable. One that provides the right information, offers sustainable alternatives and gives access to the right facilities.

That’s why Euroconsumers welcomes the European Commission’s proposal for a revision of EU legislation on Packaging and Packaging Waste and its aims to promote a more efficient use of materials and reduce packaging waste. However, in order to make sure it is fit for purpose and can truly live up to the challenge, Euroconsumers has developed a consumer checklist with five criteria to consider when designing legislation. Any regulation that aspires to be effective on ground, needs to tick the five boxes. So it can fit consumers, empower people and improve the market.

A five criteria checklist for a consumer fit packaging waste reductions

1. We start from science: ensuring a sound science-based approach to policy

At Euronsumers we always start from science. It is at the basis of all our tests, surveys and other activities. When assessing different options to reduce packaging and packaging waste that is no different. That’s why any decision should be based on independent technical and scientific studies that take into account the entire life cycle of packaging products. This also implies reuse should absolutely be prioritised if environmental impacts – with consideration of the overall life cycle – are lower than for single use packaging.

The Commission’s proposal strongly favours the reuse of packaging, with a wide range of re-use and refill targets for different sectors and packaging formats and with requirements for economic operators to produce reusable packaging and ensure proper reuse systems.

It is definitely true that a reusable approach leads to lower quantities of waste produced. However, when considering the whole life cycle analysis (LCA), it might happen that a reusable approach leads to a higher environmental impact than drop-off points or Deposit Refund Systems for single-use packaging (DRS)6. That’s because for a full scientific analysis the environmental impact generated by transport, reverse logistics, washing, disinfection and sterilisation of reusable packaging also needs to be taken
into account.

That’s why it is crucial to develop an entire life cycle analysis (LCA) to really ensure the most sustainable approach to packaging and packaging waste. This science-based approach will allow us to understand which system has a lower environmental impact and if that is the case for all types of materials (e.g. glass, plastics, aluminium, etc.).

While the legislative proposal currently on the table has some clear positive impacts, other impacts are still unclear (see table below). This can only be understood by an assessment based on independent, technical studies across Europe. That’s why Euroconsumers calls on the European Commission to support the JRC platform to deliver a full life cycle assessment of all waste reduction options on the table.

2. Safety first: reuse and recycling at no (health) risk

For any waste management system - reuse or recycling - to be effective, consumers need to be able to trust that their health and safety is not put at risk. That’s why any assessment of the most suitable packaging waste management system should not only consider the full Life Cycle Analysis (LCA) but also be accompanied by an assessment of its environmental and health impacts.

Recycling can lead to a significant pollution or introduction of problematic chemicals in new product cycles. By no means should toxic substances be reintroduced. Likewise reuse systems equally need to safeguard consumers’ health and safety by addressing both hygiene requirements and chemical concerns.

Consumer concern to that regard is particularly real when it comes to food packaging, as chemicals in packaging can leach into food. A recent consumer survey showed 70% of consumers worries about the impact on their health of chemicals present in packaging, with 9 in 10 supporting stricter rules to prevent health impact9. This comes at a time when reusing food packaging and food containers is fairly common among consumers and 1 in 5 even report reusing such items for purposes that may increase their exposure to food-related risks.

Therefore, ambitions for either reusable packaging and recycled content both require measures to minimise and cut out hazardous substances in packaging materials at the outset of the product cycle. If missing, this could result in an increased exposure of consumers to toxic chemicals. While the current proposal for a new packaging and packaging waste regulation mentions this as a general ambition, clear measures to achieve this are shockingly absent. Human health is not something to be bargained with.

3. Keep it simple: careful with too many overlapping systems

Any waste reduction system, be it reuse or recycling, will depend heavily on consumers’ engagement. Without their active participation it simply won’t work. While this is not an easy thing to predict, especially when it comes to returning packaging, recent research identifies efficient and easy-touse recycling facilities, environmental benefits, and financial incentives as the most important driving factors behind the recycling habits of European consumers.

This resonates with the findings of a Euroconsumers survey that pointed out the need for more hands-on information, the lack of simple and understandable recycling systems and the costs associated with recycling (e.g. trash bags) as the key barriers to shift consumers’ recycling habits.

That’s why to ensure consumers are on board and fully empower them to drive this systemic change, there must be a system in place that is easy, convenient and above all fit for consumers.

The Commission’s proposal requires economic operators using reusable packaging to participate in one or more re-use systems for this packaging. It is important to keep in mind that the introduction of any new system or process for packaging disposal will require a buy-in from consumers. The dual prioritisation of i.e a deposit system with reward and a reusable system with deposit, or the introduction of any other parallel system, will be a communication challenge. Running multiple systems for the same type of packaging materials at the same time could create confusion for consumers, with the real risk of losing their support.

4. Price matters: sustainability at an affordable cost

When it comes to reducing packaging and packaging waste, consumers will need to make efforts and take upon an active role. They will need to change the way they consume, reuse products and packaging and the way they dispose of valuable goods – either in unsorted waste or recycling streams.

We know from extensive consumer surveys that the higher costs related to adopting a more sustainable lifestyle are still by far the main barrier for consumers. This is the case across all sectors, including the waste management sector. Respondents indicated for example that the required specific trash bags come at a high price. Overall consumers call on financial incentives to be able to choose sustainable products and manage more sustainable systems. That’s no different when it comes to waste management. That’s why any new system not only needs to be easy and understandable, but above all affordable for consumers. A system that comes at a higher cost, will be challenging to accept and risks not reaching the much needed target.

5. The power of information: communication and labelling

Consumer empowerment starts with getting the right information. Consumers are expected, rightfully, to take upon responsibility and contribute to the reduction of packaging waste, but they cannot do this without easy access to trustworthy information. They need to know what package needs to be recycled or reused, what exactly they need to do and where it needs to go.

This requires elaborate communication and ongoing education campaigns. For more than twenty years European member states have been running initiatives to raise awareness on how to separate waste and access dropoff points. For example, the city of Rome recently launched “Roma non è indifferente”, an awareness campaign aimed to convince Romans to sort their waste. And last year Altroconsumo, together with many other civil society organisations, joined "A Buon Rendere - molto più di un vuoto",
a campaign that aims to raise awareness among citizens, politicians, the beverage industry and organised distribution about the benefits of a deposit system. Nevertheless, low recycling rates in most of the European countries show the ongoing need for strong and recurrent education campaigns to shift consumers’ behaviour.

In addition, standard labelling on packaging products will equally be key. At present more than 400 different labels holding a sustainable or environmental packaging claim are used across the EU. It doesn’t need much explaining that this is utterly confusing for consumers, especially when they are travelling across Member States. To ensure consumers are fully aware of the environmental impact of packages and what exactly they need to do with them, we need to secure the same approach and standard labels across the EU.