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The European Union has rightly identified packaging as an area where we all can and should do more to cut waste. Last November, the European Commission released plans intended to ensure that all packaging be reusable or recyclable in an economically feasible way by 2030. The draft Packaging and Packaging Waste Regulation (PPWR) aims to slash packaging waste by 5 percent from 2018 levels by the end of this decade and by 15 percent by the end of 2040.
The beer sector welcomes the overall aims of the PPWR. It fits with our values. Leading by example, brewers have a core belief that while making beer to bring communities together and contribute to the EU economy, we can have a positive impact on the planet.
But the small print of the proposal, being scrutinized by the Council and on which MEPs are set to vote on October 24, currently includes measures that discriminate against certain sectors, notably beer brewers. It includes misguided restrictions, ill-conceived targets and unjustified exemptions that damage our trade, distort the single market and undermine the sustainability aims of the proposal. The result would not just be unfair for brewers but would also hurt citizens and the environment. That would be a failure for Europe.
The small print of the proposal, being scrutinized by the Council and on which MEPs are set to vote on October 24, currently includes measures that discriminate against certain sectors, notably beer brewers.
How is the PPWR treating some sectors differently from others?
Let’s take a look at how we package beer. Like many beverage sectors, brewers use glass bottles, as well as aluminum cans. Unlike others, we also use beer kegs, barrels that contain up to 50 liters of beer. They represent around 15 percent of the overall beer volume in Europe. Thanks to kegs, venues including bars, cafés and restaurants can serve draught beer directly from the tap to the customer.
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 hard to imagine a more sustainable form of drinks packaging than kegs. They are effectively reusable, oversized beer cans.
However, despite being the ultimate sustainable packaging solution, kegs risk being discouraged for misplaced sales packaging reuse targets to be met.
Firstly, if kegs are considered as transport packaging, like crates and pallets (which themselves carry individual packages) rather than the sales packaging (with direct contact with the actual beer) that they are, then they wouldn’t even count towards the attainment of sales packaging reuse targets.
Secondly, the current PPWR proposal still risks treating kegs as single packaging units like any other for the purpose of calculating reuse targets. That means a 50-liter vessel would be treated in the same way, and as if it held the same volume of beer, as a 25cl bottle or a 33cl can. If not amended, to meet reuse targets, it would encourage producers to replace keg volumes with multiple smaller units. That would mean more packaging, and ultimately more waste, on the market compared to the current situation. This has to change. For measuring the attainment of reuse targets, kegs should be considered as sales packaging and converted into volume or equivalent units. It would be fairer to brewers and promote sustainability.
it would encourage producers to replace keg volumes with multiple smaller units. That would mean more packaging, and ultimately more waste.
This is not the only problem with the current PPWR proposal. The draft includes other measures that are discriminatory, mistargeted, incoherent and put the single market at risk.
Take, for example, the different treatment that the beer sector faces.
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.
As for non-reusable containers, they are still typically returned through well-established, well-functioning collection systems, from which they are then recycled. In many countries, there is a mandatory deposit return system (DRS) for recyclable beverage containers, yet the PPWR proposal also inexplicably offers other alcoholic beverages an automatic exemption from the DRS obligations.
Why this special treatment? If brewers can reuse packaging and integrate their recyclable packaging into a DRS, why can’t others? That would be fair for brewers, citizens and the environment.
There are other issues with the proposal.
The demand for all brewers to set up new reuse systems is disproportionate. In many countries, the DRS successfully encourages people to recycle drinks containers, such as bottles and cans. Some small brewers are already recycling at a high rate, but with just one, non-reusable but recyclable packaging line. Why should brewers with packaging already recycled at a very high rate, have to set up an expensive additional packaging line for no meaningful environmental benefit?
Why should brewers with packaging already recycled at a very high rate, have to set up an expensive additional packaging line for no meaningful environmental benefit?
The liability for hitting targets is also misplaced. The responsibility for meeting them will ultimately fall on the manufacturers, so it is superfluous and competition-distorting to impose reuse targets at the distributors’ level. Indeed, this mistargeting may even result in distributors placing the obligations on brewers to meet not just their targets for beer, but also any targets for alcoholic beverages as a whole.
And some of the plans for new labeling are also unnecessary. The best labeling is clear, precise and actionable. For deposited beer containers, the national deposit logo is the most important packaging instruction. Further waste sorting logos would confuse rather than enable the consumer to correctly dispose of empty packaging.
These issues are important for us not just because of the costs that they will entail. Rather, it is because we can see that the current text is both unfair and runs counter to our shared vision of a more sustainable world.
We brewers have already invested heavily in reducing our environmental footprint. We have reduced, reused and recycled beer packaging throughout the lifecycle. And beyond packaging, we lead by example when it comes to the circular economy. Over the years, we have launched a variety of green initiatives that span production, marketing, distribution, use and disposal stages.
We are part of the solution, and we want to continue innovating. We want to keep finding new ways to become more sustainable.
But we need legislation to be proportionate, well-targeted, non-discriminatory and coherent.
If the EU is to develop a truly sustainable packaging policy, it needs to change the proposed PPWR, which is ill-targeted and discriminatory. In its current form, it could lead to the dismantling of well-functioning, existing reuse and recycling collection systems in many countries. It would also add needless burdens and costs for brewers, particularly small brewers.
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.
