European industries The effectiveness of the latest EU regulations for packaging will depend on their fairness towards all sectors. Bella Brown October 2, 2023 I am not able to reword this text. The EU acknowledges that packaging is an important area where we can all make an effort to reduce waste. In November, the European Commission revealed its plans to make sure that all packaging can be reused or recycled in a feasible way by 2030. The proposed Packaging and Packaging Waste Regulation (PPWR) aims to decrease packaging waste by 5 percent compared to 2018 levels by the end of the 2020s, and by 15 percent by the end of 2040. The beer industry supports the general goals of the PPWR, as they align with our principles. By setting an example, breweries hold a fundamental belief that, while producing beer to unite communities and support the EU economy, we can also make a beneficial impact on the environment. The details of the proposal, currently under review by the Council and facing a vote by MEPs on October 24, contain provisions that unfairly target specific industries, such as beer brewing. These restrictions, targets, and exemptions are misguided and unjustified, ultimately harming trade, distorting the single market, and going against the proposal’s sustainability goals. This would not only be unjust for brewers, but also negatively affect citizens and the environment. It would be a disappointment for Europe. The fine print of the proposal, which is under close examination by the Council and is scheduled for a vote by MEPs on October 24, currently contains provisions that unfairly target specific industries, particularly beer producers. What are the differences in treatment of different sectors by the PPWR? We will examine the process of packaging beer. Similar to other beverage industries, brewers utilize glass bottles and aluminum cans. However, we also incorporate beer kegs, which can hold up to 50 liters of beer. These kegs make up approximately 15 percent of the total beer volume in Europe. With the use of kegs, establishments such as bars, cafes, and restaurants are able to serve draught beer straight from the tap to their customers. It is hard to imagine a more sustainable form of drinks packaging than kegs. They are effectively reusable, oversized beer cans. Kegs are collected and reused on average 165 times over 30 years before being crushed and recycled for further use. The kegs are simply filled at the brewery, with the beer then dispensed into customers’ glasses at the venues, before the empty kegs are brought back to the brewery. It is difficult to conceive of a more environmentally friendly method of packaging beverages than kegs. They are essentially large, reusable beer cans. Unfortunately, even though kegs are the most environmentally-friendly packaging option, they may not be used as frequently due to pressure to meet sales targets for reusing packaging in the wrong context. If kegs are classified as transport packaging, such as crates and pallets that hold individual packages, instead of sales packaging that directly comes into contact with the beer itself, they would not be included in the achievement of sales packaging reuse goals. The proposed PPWR plan may unfairly treat kegs as single units, similar to other types of packaging, when calculating reuse targets. This could result in producers replacing kegs with smaller units in order to meet targets, leading to more packaging and waste in the market. To address this issue, kegs should be considered as sales packaging and converted into volume or equivalent units when measuring reuse targets. This would promote fairness to brewers and sustainability. This would incentivize manufacturers to substitute keg sizes with several smaller units. This would result in increased packaging and ultimately, more garbage. The current PPWR proposal has multiple issues, not just the one mentioned above. The draft contains other policies that are biased, poorly aimed, lacking consistency, and jeopardize the single market. For instance, consider the varying approach towards the beer industry. Unlike other alcoholic beverage sectors, brewers on average already sell more than half their products in reusable packaging, be it kegs or glass beer bottles, two-thirds of which are reused, while the other third can be recycled. However, the proposed PPWR says some alcohol sectors would be totally exempted from any obligation to hit reuse targets. Regarding containers that cannot be used again, they are usually brought back through established and efficient collection systems, and then processed for recycling. Some countries have a mandatory deposit return system specifically for recyclable drink containers, but the PPWR proposal oddly excludes other alcoholic drinks from this requirement. What is the reason for this specific favoritism? If beer brewers are able to reuse packaging and incorporate their recyclable materials into a DRS, why are other industries not allowed to do the same? This would be equitable for both brewers, the public, and the ecosystem. There are additional problems with the proposal. The call for all brewers to establish new systems for reusing materials is not fair. In several nations, the DRS effectively motivates individuals to recycle beverage containers, like bottles and cans. While some smaller brewers already have a high rate of recycling, they may only have one packaging line that is not reusable but can still be recycled. It is unclear why brewers who already have a high recycling rate for their packaging should be required to invest in an expensive additional line without any significant environmental advantages. Why do brewers, who have a high rate of recycling for their packaging, need to invest in an expensive extra packaging line with no significant environmental advantages? The blame for achieving targets is inaccurately placed. The manufacturers will ultimately be held accountable for meeting these targets, so it is unnecessary and unfair to enforce reuse targets at the distributor level. This misdirected approach could potentially lead to distributors passing on the responsibility to breweries to not only meet their beer targets, but also any targets for all alcoholic beverages. Some of the proposed labeling plans are unnecessary. The most effective labeling is easy to understand, accurate, and provides actionable information. When it comes to beer containers with deposits, the national deposit logo is the most crucial packaging instruction. Additional waste sorting logos would only cause confusion and hinder consumers from properly disposing of their empty packaging. These matters hold significance for us not only due to the expenses they will incur, but also because the existing text is unjust and goes against our mutual goal of a sustainable world. As brewers, we have made significant investments in minimizing our impact on the environment. We prioritize reducing, reusing, and recycling our beer packaging at every stage. Additionally, we are committed to promoting a circular economy and have implemented numerous sustainable practices in our production, marketing, distribution, and disposal processes. We are actively working towards finding solutions and strive for ongoing innovation. Our goal is to constantly discover new methods of promoting sustainability. However, legislation must exhibit proportionality, precise targeting, lack of discrimination, and cohesiveness. To promote a sustainable packaging policy, the EU must revise the proposed PPWR, which is ineffective and biased. As it stands, this could result in the disruption of functional reuse and recycling programs in multiple countries. Additionally, it would impose unnecessary financial and logistical challenges on brewers, especially smaller ones. EU Member States and MEPs considering the PPWR proposal need to scrutinize it carefully. As it stands, it undermines both the EU’s single market and the sustainability aims it proclaims. But it is still possible to resolve these issues and brewers stand ready to work with the EU institutions to ensure the PPWR achieves its aims of reducing packaging in Europe.