EPR plays a vital role in coordinating and convening elements of a circular economy for packaging. Many of the key challenges ahead fall within their scope: incentivising sustainable design, supporting investment and delivery of collection, sorting and recycling; as well as stimulating essential end markets.

Mike Jefferson of CEFLEX spoke to Victoria Hattersley in April 2021 about why the ongoing development of EPR schemes is so important for achieving the goal of a circular economy – and what the implications are for the flexibles industry in this interview originally published in Packaging Europe

For those of us with less knowledge of the subject, can you explain why EPR schemes can contribute to more efficient resource use overall and move us further towards the goal of a circular economy?

Extended Producer Responsibility (EPR) for packaging is a mechanism where producers are responsible for the recovery and recycling of the packaging that they place on the market after it has been used. Typically, this is through providing financial support to facilitate the collection, sorting and recycling of packaging waste. Some Producer Responsibility Organisations (PROs) may also get operationally involved, in particular in the sorting and recycling elements of the supply chain. EPR schemes are therefore important as they provide the necessary funding to ensure collection and recycling takes place. Whilst EPR schemes may not have full control of all elements of the supply chain for packaging waste, for example municipalities have the ultimate say in how packaging wastes are collected for recycling, they play an important coordination and facilitating role either directly through contractual agreements or indirectly by working in partnership with those in the supply chain. EPR schemes are now also required to introduce eco-modulation of fees so that they reflect the recyclability of the packaging being placed on the market and some have also introduced incentives to incorporate recycled content in packaging. So, they are key actors throughout the circularity loop.

CEFLEX have been looking at how this facilitating and coordinating role that EPR schemes play can be best leveraged to meet circularity objectives for flexible packaging. This has culminated in the development of CEFLEX’s EPR Criteria for Circularity (C4C) which looks at how EPR can operate to create optimal conditions to maximise the circularity of flexible packaging.

EPR schemes put the onus on producers to take responsibility for the waste generated by their products. Just so we’re clear, does this apply mainly to brand owners or the packaging producers themselves?

There are some differences between countries, but in most cases it is those placing packaging onto the market that pay the EPR fees, so brand owners or importers of packaged products into a country.

Do you feel current EPR regulations have the balance right in terms of who shoulders the burden for dealing with packaging waste and recycling?

The principle of EPR is that producers pay for the end of life management of the product they place on the market, or in this case packaging. Currently if we look across the EU then the full costs are not always paid by those placing packaging on the market and others do pay into the system, for example municipalities. There was an amendment to the Directive on Waste in 2018 which included minimum requirements for extended producer responsibility systems. This includes a requirement for EPR schemes to cover the full net costs of collection, treatment and recycling. Also, to cover costs related to providing information to waste holders and for data collection. Of course, from a brand owner’s perspective it is important that fees paid are only used to cover the costs associated with packaging collection, sorting and recycling and not used to fund other activities.

In its EPR Criteria for Circularity, CEFLEX propose that fees for each type of packaging, for example flexible packaging films, are ringfenced and used only to fund the collection, sorting and recycling of that particular stream. That way each packaging type has fees commensurate with the true cost of its treatment post use and there is no cross subsidy. It is also important that there is good transparency of spend.

What are the issues and challenges surrounding the implementation of Europe-wide – or indeed global – EPR systems? For example, are these legislative, are certain regions finding meeting new targets more challenging, or are certain material producers finding it more difficult to adapt to these schemes?

I think it is first worth stating that EPR has been a great success in Europe and it has driven a significant increase in the recycling levels of packaging waste since it was introduced in the late nineties. It is also used in North America and increasingly being implemented, or actively considered, in other parts of the world. It is also worth noting that there are important differences between EPR schemes in different European countries. These differences often relate to the system design and level of control the PROs have at different points in the supply chain, for example whether they have a say in the specifications or even manage the flows of packaging waste produced by sorting centres. Another key difference between countries is whether or not there is competition in the market. Competition can of course have advantages, but a challenge that needs to be considered when drafting national legislation is how it works in the context of important areas such as eco-modulation of fees and also ensuring sufficient funding for communication and research and development. In particular, to ensure that proactive PROs are not disadvantaged commercially. In terms of other challenges, then recycling targets for 2025 are certainly stretching in particular for plastic packaging. However, I believe CEFLEX stakeholders recognise the importance of achieving significantly higher levels of recycling for flexible packaging than have been achieved in the past and this is reflecting in the rapid increase in the number of stakeholder over the last three years since the platform was started.

Why has take-up taken so long to come about, given that the concept has been around for decades?

As you say, EPR has been around for several decades and is well established. However, legislation both at an EU and national level continue to develop.

Many of the current areas of focus, such as design for recycling and how to incorporate new recycling technologies such as dissolution and chemical recycling within the legislation, are very relevant to the recycling of flexible packaging. CEFLEX recognises the central role that EPR plays in the recycling supply chain and therefore keen to engage with EPR schemes to achieve the shared goal of circularly for flexible packaging.

Can you give any examples of current collaborations and projects?

CEFLEX recognise the need for action right along the length of the supply chain. There is no one action that on its own that can achieve circularity for flexible packaging. As such, the work needs to be inherently collaborative. As well as brand owners, CEFLEX contains waste management and recycling stakeholders which add value and strengthen the work being done and conclusions being made.

Current ongoing work includes building on the recycling design guidelines for flexible packaging through the development of testing methodologies and recyclability trials . Also, the quality recycling work which looks at the latest sorting and recycling technologies to assess what quality of recycled polymer can be obtained from various household film inputs from sorting centres. These also look at potential future sorting options for the flexible film fraction to maximise the quality of the recycled polymer that can be produced by recyclers. These trials have produced recycled polymer that has been used in non-food contact pouches and shrink wrap.

More recently, CEFLEX have started extensive waste compositional work across a number of different countries both on waste entering the sorting centres and of the residual fraction. This is giving detailed insights into the types of flexible packaging types being captured in recycling systems but also on those still ending up in the residual fraction. Understanding the mix and flows of mono and multilayer materials as well as other formats is key to informing the working being done. There is also commercial and market assessment work being carried out that provides insight for relevant stakeholders, be they EPR schemes, recyclers or brand owners. Externally, CEFLEX also looks to work on a collaborative basis and liaises closely with many European associations, including the main polymer platforms that also have an interest in increasing the circularity of flexible packaging.

Mike Jefferson, CEFLEX

Mike Jefferson, CEFLEX