The European Federation for Waste Management and Environmental Services (FEAD, Brussels / Belgium; www.fead.be) has prepared a list of the main criteria that it believes the European Commission should take into account in reinforcing the essential requirements for packaging under Annex II of the packaging and packaging waste directive. DG Environment is currently undertaking a study on “Effectiveness of the Essential Requirements for packaging and packaging waste and proposal for reinforcement” with completion expected by the end of 2019. FEAD said the EU Commission’s examination of the potential reinforcement of Annex II’s essential requirements was of “utmost importance in the transition to a circular economy.”

The association’s criteria centre on three key areas – product design, market issues and issues with current technology. Within product design, FEAD highlighted 10 separate areas of concern, ranging from multilayered and lightweight packaging, dealing with additives and hazardous substances, to making clear distinctions between certain terminology such as bio-based and biodegradable, and recycled and recyclable, to better inform consumers. “The use of biodegradable plastics must be so specific that the correct recycling route is clearly identifiable for the consumer/user. The mere risk that this might happen has already been known to discourage manufacturers to use recycled content,” FEAD stated. Another crucial design factor would be to reduce the use of features such as labels, printing, colours, glues, covers and caps in order to increase a package’s recycling potential and value.

Labelling and imports were the key focus for market issues. FEAD members suggested the development of a common label showing the percentage of recycled material in plastic packaging would build trust between consumers and producers as well as increase demand.

With regard to imports, FEAD said products using plastic packaging should follow EU rules on content, which it deemed was not necessarily the case at present. The association highlighted the potential for “discrepancies” between the additive and substances content of packaging made in the EU and non-EU third countries, giving rise to a “multitude of challenges” for the waste management sector. “The language of the essential requirements of Annex II should be clear, facilitating interpretation for the producers of imported products,” FEAD said, adding that stronger enforcement of the essential requirements of Annex II should also be imposed, preventing third-country producers from deviating from the rules.

Finally, although current mechanical recycling technology can achieve high-quality material, FEAD said it requires a closed loop, better ecodesign requirements and better compatibility between the plastic types and the Near InfraRed (NIR) detection system used in sorting and recycling facilities. The association added that chemical traceability of plastic packaging was “crucial” and improved data collection was of “paramount importance” for the uptake of recycling and for developing legal and financial instruments to trigger increased demand for secondary raw materials.