A cross-industry coalition representing the European hospitality and beverage industries and its packaging value chain has called for an improved impact assessment surrounding the proposal for a Packaging and Packaging Waste Regulation (PPWR), cautioning that businesses and consumers alike could suffer under the inefficient rollout of reuse and refill schemes.

360FoodService, The European Fruit Juice Association (AIJN), The Brewers of Europe, European Vending & Coffee Service Association (EVA), European Aluminium, The European Container Glass Federation (FEVE), HOTREC, Metal Packaging Europe, Natural Mineral Waters Europe (NMWE), Petcore Europe, SMEUnited, Serving Europe, and UNESDA Soft Drinks Europe are listed as signatories.

In an open letter, the organisations argue that the Commission’s impact assessment “is not robust enough and needs further clarification” – warning that, without the appropriate evidence that the proposed measures will have positive benefits, they could have a “detrimental impact” on the wellbeing of various companies within the beverage and hospitality sectors; on accessibility, choice, and convenience amongst consumers; and on the environment.

In the coalition’s view, the impact assessment as it relates to reuse and refill targets for certain Member State operators and different beverage categories is currently insufficient. It is said to only present unfounded EU aggregated numbers without breaking down the figures per country, product category, or reuse solution.

Arguing that the economic impact of said targets have been underestimated, the companies point to a study conducted by PwC suggesting that a 10% refillable PET target at EU level would cost the soft drinks sector €16 billion, excluding the setup of appropriate deposit return schemes (DRS). On the other hand, the PPWR’s impact assessment anticipates capital and operating costs of €1.48 billion for all reuse schemes, including DRS-related costs for refillables.

The coalition also expresses its doubt that the current environmental impact assessment’s predicted CO2 savings from reuse system deployment are accurate – pointing to a contradictory study by Carbon Trust. It points out that circular reuse systems make more sense in certain contexts than others, and that single-use systems or a combination of both can sometimes be the most sustainable solution. Factors such as packaging and material weight, transport distance in reuse schemes, the average number of rotations a package undergoes, and the consumption of electricity, hot water, detergent, and fuel can all impact a reuse system, and the companies do not believe that the Commission’s current targets take this into account.

The PPWR’s approach is also described as “one size fits all” in its coverage of all Member States, sectors, product categories, and reuse systems “at the same time”. The coalition criticises this approach as unrealistic and incapable of properly assessing the proposed measures’ true impact. Rather, it expects that the revisions will force companies to invest in setting up reuse systems and possibly delay or halt their investments in bottle and can recycling streams, even where single-use systems would be more environmentally beneficial.

While the companies clarify that they agree with a transition into reuse schemes in principle, they fear that the involvement and engagement of consumers in reuse schemes are not mentioned in the impact assessment. Especially in the wake of the COVID-19 pandemic, consumers’ negative ideas and experiences surrounding hygiene, for example, can impact the success of a reuse solution, and their blanket implementation across various sectors is not expected to instil confidence in their effectiveness.

Furthermore, the coalition warns that rushing into new measures could cause an influx of non-compliant reusable products in packaging markets – a development that apparently disadvantages European business before they can make their own transition while also putting consumers at risk.

In light of the “rushed and incomplete preparatory work” behind the upcoming reuse and refill targets, and the speed at which co-legislators are being asked to make decisions “without any certainty on the impact of the proposed measures”, the coalition encourages the Commission to re-evaluate its impact assessment before enforcing the new legislation.

UNESDA, AIJN, The Brewers of Europe, and NMWE previously made their own statement criticising the mandatory reuse targets set by the European Commission, which they described as ‘discriminatory’ and potentially harmful to established sustainability efforts and businesses.

The Alliance for Beverage Cartons and the Environment (ACE) has also called for such changes as exempting microbiological sensitive products from reuse targets, the implementation of a stakeholder/industry advisory body to contribute to Design for Recycling guidelines, and a mandatory collection target of 90%.

Members of the European packaging value chain at large previously accused the upcoming revisions as a whole of being ‘ambitious’ and ‘arbitrary’, lacking the appropriate evidence, and failing to address prominent issues facing the packaging industry.