As part of the New Green Deal and in line with the development of the circular economy, the European Union is planning to introduce a “digital product passport” early next year. This particular initiative, which aims to increase the proportion of products on the common market which are recycled or reused, stands out because it stresses the virtues of both reuse and recycling equally.
This is an important conceptual step for the EU, given that its sustainability drives to date have largely favoured recycling over reuse – to the overall detriment of the environment. European societies, with their heavy emphasis on consumerism, produce a staggering amount of waste, and with the pandemic adding millions of tonnes of used single-use products to that pile, the question of how to curb the sheer scale of disposed waste is becoming a hotter topic than ever.
Updating the Waste Shipment Regulation
The EU’s drive towards a more sustainable economy is both laudable and necessary, but it would be much more efficient were the bloc to finally adopt waste hierarchies that correctly prioritize reuse as the first option for waste over recycling. From that perspective, the Commission’s new proposals pertaining to the Waste Shipment Regulation (WSR) – one of the cornerstones of the EU’s green transformation project – represent a missed opportunity, with the Commission instead clinging to the notion that the path to sustainability lays almost exclusively in recycling.
By 2050, Europe and other developed parts of the world aim to reach net zero emissions and zero pollution targets, but doing so requires a basic understanding of what constitutes “waste” and what is worth recovering to achieve maximal economic and environmental benefits. This requires policymakers to make a clear distinction between, for example, consumer packaging and industrial packaging.
The current WSR treats both categories as waste, with the result that consumer and industrial packaging are often disposed of in the same unsustainable ways. However, industrial packaging is clearly very different from consumer packaging, and the EU needs to explore specific rules to promote its reuse.
Reuse over recycling
While the WSR proposals stress the importance of recycling, the EU is repeating its past mistakes by overlooking reuse and prioritizing recycling as a solution to be applied across the board. Environmental experts now believe encouraging reuse is practically always the better option, both economically and from the standpoint of pollution. Once industrial packaging has reached the end of its useful lifecycle, it can then be recycled and reprocessed to obtain raw materials.
The benefits of reuse are particularly evident in the case of industrial products such as steel drums, plastic drums, and intermediate bulk containers (IBCs). These types of industrial packaging can frequently be cleaned and reconditioned in both closed loop as well as open loop supply chains, thereby generating substantial financial and carbon savings compared to the recycling process or simple disposal. The widespread use of such packaging across multiple industries means the EU and its member states can secure a significant offset in waste output by prioritizing their reuse.
This approach would also be in line with the concept of waste hierarchy, which is often summarized as “prevent, reuse, recycle”. Instead of following this hierarchy, the current system sees industrial packaging often shipped off for recycling to non-EU countries where environmental laws are lax and reprocessing is a major source of pollution. The WSR proposals do allude to the importance of “aligning WSR provisions with the waste hierarchy,” but remain vague on how the Commission plans on achieving this goal.
Respecting the hierarchy
In failing to adequately recognize the distinctions between recycling and reuse and between normal packaging and industrial packaging, the proposed additions to the WSR represent a significant oversight on the part of the Commission.
Indeed, by neglecting to differentiate between shipments intended for reuse, recycling, and “lower forms of recovery”, the WSR is unwittingly encouraging harmful practices like incineration in blatant violation of the waste hierarchy.
Current EU legislation remains unequipped to grasp subtleties that could prove crucial in improving sustainability. By embracing the hierarchy, the EU could do so much more for the emergence of a truly circular economy across the single market.
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