Definition of ‘high-quality’ recycling takes centre stage in EU packaging law

The European Union wants to reduce waste by encouraging recycling and reuse in its new packaging law, but the pressure is on to get the right definition and criteria for what constitutes “high-quality” recycling.

Update: the article was updated to clarify the position of Tetra Pak.

The European Commission tabled its proposal for a Packaging and Packaging Waste Regulation in November 2022, aiming to promote reusability and recyclability while reducing waste.

The draft law mentions “high quality” recycling as one of the regulation’s key objectives and sets criteria for packaging to be considered recyclable.

However, the paper-based packaging industry is concerned that the definition of high-quality recycling will leave them out of the market, leading to a surge in plastics, which are easier to recycle in a closed loop.

Environmental groups, meanwhile, warn against downcycling high-quality materials into lower-quality products, saying paper risks becoming the largest source of packaging waste in the EU.

Closed-loop recycling is not a panacea

One way to guarantee quality is to set up a closed-loop system where packaging is recycled into the same product each time, like with plastic bottles.

However, a closed-loop recycling system is more challenging to put in place for paper packaging because recycled fibres are currently not allowed in food contact materials.

“If we wanted to move into a re-utilisation of materials into packaging, this is something that we totally share,” said Francesca Priora, sustainability director for Iberia and South Europe at Swedish beverage carton maker Tetra Pak.

But for this to happen, “we need the right norms and the right processes” to ensure food safety standards are respected, she told Euractiv.

Environmental organisations, too, say closed-loop recycling is not a silver bullet. For them, open-loop recycling, where waste materials are extracted and used in different categories of products, must also be considered.

“Open-loop recycling could be very efficient and result in up-cycling to a product of better quality and value. Conversely, closed-loop could be very energy intensive and polluting and not worthwhile,” said Jean-Pierre Schweitzer from the European Environmental Bureau (EEB), an umbrella group bringing together around 180 environmental citizens’ organisations.

However, Schweitzer added that many open-loop recycling processes downcycle materials into lower-quality products, saying this can result in greenwashing.

Environmental NGOs are also concerned about lowering the ambition on recycling criteria when the European Parliament examines the draft legislation. According to Lauriane Veillard from Zero Waste Europe, materials need efficient collection systems and go through the most environmentally friendly recycling to keep their quality.

Defining high-quality recycling

Despite concerns, Tetra Pak’s Priora sees the definition of high-quality recycling as an opportunity for frontrunners to stand out.

“The beauty of PPWR is that there will be criteria on the so-called high-quality recycling. So far, it is tough for different producers to differentiate themselves in the market without a clear definition,” she told Euractiv while at a paper mill in Tuscany, adding that mandatory targets help.

The mill, operated by Lucart, has teamed up with Tetra Pak to recycle used beverage cartons and scraps, recovering all the materials they are made from – a process that is increasingly becoming the norm in Europe. The recycled paper fibres are used for hygienic paper, like kitchen towels. Meanwhile, the plastic lining of the carton is recycled into plastic pellets used to make paper towel dispensers, reusable pallets, and other goods.

“It is an opportunity for the producers to have quality material in the production of the recycled products, which is really the ideal state,” Priora told Euractiv, saying beverage cartons increase the quality of the mix and capacity to recycle.

But the European Environmental Bureau (EEB) sees it differently, likening the process to downcycling.

“If the fibres are recycled today, they are mostly turned into hygienic paper. This is open-loop downcycling as the end product has less value and the cartons depend still on virgin material,” said Schweitzer, adding that this is nevertheless still better than burning or landfilling the material.

Beyond this, organisations like the EEB and Zero Waste Europe warn against over-relying on paper in transitioning to more sustainable packaging.

“What we fear is that we have single-use paper being the new single-use plastic. Really, what we’d like to see is a broad stopping of substitution and move towards a change of consumption and models, moving towards reuse in a system,” said Veillard.

A recent report from a coalition of NGOs, including the EEB and Zero Waste Europe, found paper packaging rarely includes recycled content and drives global deforestation and industrial water consumption.

‘Renewable’ feedstock

The feedstock for paper packaging also needs to be considered as it risks driving deforestation and creating monoculture pulp plantations with limited biodiversity benefits, Schweitzer pointed out.

Asked about the risk that growing demand for paper packaging will overwhelm Europe’s forests, Priora emphasised that “virgin fibres, if managed with Forest Stewardship Council systems, with very strict requirements, will continue being consumed”.

At the same time, “the share of recycled content will keep growing into valuable applications, such as in secondary and tertiary packaging,” she added, saying there is a “massive opportunity” to replace virgin forest fibres with recycled cellulosic content.

“Pushing towards a closed-loop system will lead to more plastic placed on the market and to the paradox of decreasing the usage of recycled paper – a renewable material, when responsibly sourced,” she argued.

In short, the more paper products are made with these recycled materials, the less virgin material will be needed, the industry’s argument goes.

“So there is no concern on the availability of the cellulosic-based products under the condition that the virgin part is controlled through due diligence systems and certification,” Priora explained.

Alongside this, the paper industry is pushing for EU legislation to recognise fibres from sustainably managed forests as “renewable” material.

“Renewability and recyclability are the two advantages of sustainable futuristic packaging,” according to Priora, who said these combined can drive a better carbon footprint.

[Edited by Frédéric Simon]

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