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In the third part of our series on extended producer responsibility (EPR), in collaboration with CEFLEX, Victoria Hattersley spoke with Archana Jagannathan, senior director for sustainable packaging at PepsiCo, about the pressures EPR requirements put on brand owners and what strategies this company is employing to meet these.

In the first two parts of this series, we’ve discussed both the revisions the EU’s Waste Framework Directive that will transform how recycling volumes are measured, ultimately leading to higher targets. Combined with new minimum requirements for EPR systems, this obviously puts pressure on brand owners to conform – and to demonstrate quite clearly that they are doing so.

How are brand owners responding to this pressure? As we reported recently, PepsiCo is one of many businesses along the packaging value to chain to publicly announce its support for the adoption of EPR in a statement published by the Ellen MacArthur Foundation.  

“Working to build a world where packaging never becomes waste has been a key vision for PepsiCo for some years so as a brand owner we are supportive of the new EU minimum requirements,” says Archana Jagannathan. “They are an opportunity to strengthen EPR, making it fit for higher recycling and more efficient, transparent systems – ultimately we want more to be recycled and this is a progressive step towards that.”

For this to happen, there do of course need to be clear, harmonized guidelines across the EU. According to Archana, such harmonized methods should include: “Ambitious plastic packaging recycling targets, including for flexible film packaging; end-to-end accountability of PROs to encourage closer integration with recycling operations; a clear definition of EPR fee modulation to reflect the net and true cost of selling sorted bales to recyclers; and greater transparency on the recycling rates of different packaging material and types.”

‘Support and strengthen’

The question next becomes, how can brand owners ensure they are meeting these EPR regulations in a way that benefits both themselves and the wider society?

“We need to support and strengthen EPR schemes so more gets recycled,” says Archana. “High recycling will also lead to other positive outcomes such as reduced greenhouse gas emissions, and ensuring that packaging is treated according to the waste hierarchy. We have identified two main levers that will help meet that goal: setting up ambitious plastic recycling targets for EPR schemes, in a way that will incentivize the collection, sorting and recycling of packaging; and adopting modulated fees that reward eco design and truly correspond to the cost of collection, sorting and closing the gap that today makes recycling of some packaging such as flexible film not profitable.”

Taking the example of PepsiCo itself: alongside the above-mentioned EMF statement, the company is part of EPR schemes established in 23 EU countries, any many more worldwide.

“Besides our financial contribution, we commit time and resources by taking part in the Board of Directors when applicable, we participate in dedicated EPR schemes’ projects that foster the recycling of our types of packaging, such as the CITEO PP Club for flexible packaging. Outside of Europe, PepsiCo has been closely involved in setting up the EPR schemes in Canadian states - some of the most advanced outside of Europe – and we have been instrumental in the creation of the voluntary EPR project in Mexico, the first one in South America.”

‘Improving the fee structure’

However, when it comes to EPR fees themselves, some have argued that they are not yet a fair reflection of the recyclability of the individual materials themselves, and that more clarification / adjustment is required here. For example, there have been proposals by CEFLEX, among others, that fees for each type of packaging should be ‘ringfenced’ according their true environmental impact. How does Archana see this question?

“There is a general need for improving the fee structure to reflect recyclability and the net cost of collection and sorting, although some EPR schemes are already on a good track. We agree that each material and packaging type should pay its own way to create a healthy EPR ecosystem for all packaging, avoiding competition and giving a chance for all packaging to be recycled.

“For flexible packaging, we need to incentivize the right infrastructure for recycling.  This will require investments that we can collectively support through appropriate EPR modulated fees that cover the true cost of collection and sorting, but also take into account the revenue from the sales of sorted plastic waste to recycling operators.”

EPR clearly puts the onus on producers rather than legislators, but how can individual governments can better enforce and communicate schemes to ensure we achieve the most efficient use of resources?

“Through legislation, governments can set high recycling targets for plastics to drive collection and sorting and they can disincentivize any other end of life that is not recycling such as banning landfill. Public administrations should also implement separate collection of waste and support consumers in understanding how to properly dispose of waste in the household. Even though EPR schemes are often responsible for these campaigns, national and local governments can support them with specific budgets and channels to reach a maximum number of citizens.”

‘Fit for purpose?’  

Finally, I was interested to know, in light of the above, whether Archana feels that current EPR schemes are ‘fit for purpose’: Do they go far enough, and what improvements could be made to ensure all of those who are contributing to the vast problem of packaging waste are ultimately part of the solution? Archana feels we have made good progress but there is still plenty of work to be done.

“Most EPR schemes in the EU are built on solid foundations and with the implementation of the new minimum requirements can be strengthened to increase recycling rates also for plastic and flexible packaging in particular. Managing waste in the most environmentally sound manner will require work from all involved. As producers of packaged goods we are designing packaging to be 100% recyclable, following the CEFLEX guidelines in the case of flexible film, but we will need the right infrastructure in place to sort and effectively recycle it. The upgrading of the sorting and recycling infrastructure to achieve recycling of flexible film will require investment from companies, from EPR schemes and from public funding.”

Next time... we continue our look at EPR from the brand owner perspective with a conversation with Nestle’s Jochen Hertlein.