-  Positions

CIAA COMMENTS ON THE RDC/PIRA STUDY

This document constitutes the comments of the CIAA following the stakeholder meeting of 20 June organised by the Commission and the analysis of the RDC/PIRA draft report.

GENERAL COMMENTS

The CIAA welcomes the opportunity to comment on the RDC/Pira study as we believe that the on-going stakeholder dialogue can significantly refine and improve the RDC results.

We support the Commission decision to gather reliable and comparable data taking into account the diverse situations and performances of the different Member States.

The CBA methodology used, even in its early stages, is a new and valuable tool in comparison with classic LCAs.

However, due to the limitations to CBA, the budget and time restrictions and the limitations of data collection, the results of this Costs Benefits study should be cautiously interpreted.

SPECIFIC COMMENTS

RDC/Pira study is particularly interesting as it draws three main conclusions:

- The calculation of optimised recycling rates
- The comparison between packaging systems for a specific material
- The predominance of the industrial packaging in the global packaging stream.

- The calculation of optimised recycling rates

This optimum is to be found within a target range below and above which costs exceed benefits. The RDC study shows the importance of having maximum rates because beyond a certain limit, recycling is not economically nor environmentally efficient or preferable. The revision of the Packaging Directive should, therefore, take this fact into consideration and set both minimum and maximum targets for recycling.

- The comparison between packaging systems for a specific material

* The CBA methodology reveals that internal costs predominate over external costs.

* The monetisation of the impacts should be further explored to improve the robustness of the study.

* We would also like to stress that the Cost Benefit Analysis, like Life Cycle Assessments, is not a tool to compare packaging materials. Other elements such as techniques, health and marketing also need to be considered. For instance, for numerous beverages (milk, bier, wine), the comparison between glass and PET makes no sense. We, therefore, suggest modifying the presentation of the results to avoid confusion. The CBA should be limited to compare refillable packaging and one-way packaging for one specific material and not for different materials.

* The CIAA supports the new highlight promoted by RDC on the debate on one-way packaging versus refillables. Indeed, the report concludes that refillables for beverage packaging should not be promoted. It is particularly true for PET, and one-way PET is usually the best option. For glass, the reuse is no longer a good option when the distance it is transported increases.

- The predominance of industrial packaging in the global packaging stream

Setting a global optimum recycling target (household + industrial) is clearly the best solution as it allows certain flexibility required by the various national situations. However, the RDC/Pira study reveals that a high amount of industrial and commercial packaging is being put on the market.

Although the definition of household packaging and industrial and commercial packaging can be different in Member States, we encourage RDC to further reinforce the reliability of the data collected so far and to make a CBA on wood packaging. If such verification cannot be made, further sensitivity studies should be carried out to measure the impact of a significant variation of some fraction of industrial packaging on the global recycling target.

ADDITIONAL REMARKS

- No CBA on chemical recycling

The CIAA regrets that the different scenarios of the study consider only mechanical recycling. Other recycling processes to treat the packaging waste stream such as chemical recycling should be taken into account. A Cost Benefit Analysis of chemical recycling for PET, based on the TBI results that have been submitted to RDC by Eco-Emballages, should be included in the study.

- Glass collection

When the glass collection exceeds 50-60%, it implies a collection per colour that leads to further costs. These costs have not been incorporated in the calculation of recycling targets for glass although they could significantly influence the optimum recycling rate.
These additional costs should, therefore, be included in the final RDC report.

- Population density

A selective collection of packaging on 100% of the European territory is impossible. It should be reasonable to set a population density limit below which selective collection of packaging is neither economically nor environmentally justified. The CIAA recommends to identify the zones where the population density is below 50 habitants/km2. Besides, sensitivity studies should be carried out to determine the population density for which costs of the selective collection exceed benefits.

- Plastic packaging

* Fluctuations of the market prices of plastic

The study shows that the results of the CBA for packaging recycling largely depend on the market price of materials. The RDC results are based on the current and high sales prices for the recycled materials. However, the possible variations of the market price of some materials such as plastics are not taken into consideration.

The CIAA favours an approach that would integrate the possible variations of PET market price to complete the RDC report and suggests that a sensitivity analysis on PET packaging based on average historical prices to be made.

* The RDC study should consider that some fraction of household packaging waste is not collectable. Indeed, a fraction of PET or HDPE bottles could be considered non-recyclable for technical reasons (spoiled, too small size, etc) or for health and safety reasons (they have contained hazardous substances).

We propose that the final RDC report takes into account the ratio of household packaging that can not be collected and recycled and to which optimised targets would not apply. Here, a collection rate of 0% should be applied.

- Packaging mix

RDC uses the actual packaging mix for each Member State and does not take into consideration future significant modifications that could happen between now and 2006. For instance, the beer market could use more PET than glass in the future.

The CIAA, therefore, favours RDC carrying out a sensitivity analysis on the variations in packaging mix.