Recycling Netwerk Benelux calls on the State Secretary to reconsider the design of the circular standard.

A consultation concerning the Pre-publication to amend the Packaging Management Decree 2014 runs until 30 November. In a letter dated 2 July 2020 to the House of Representatives, State Secretary Stientje van Veldhoven (D66) already informed about the upcoming changes in Packaging Policy. According to the letter, in line with the circular economy policy, the policy is aimed at 1) reducing the use of packaging, 2) stimulating the repeated reuse of packaging and 3) improving the quality of collection and recycling. The goal of the circular economy policy is to halve the use of minerals, metals and fossil materials by 2030 compared to 2014 and to reduce it to a minimum by 2050.

The letter further indicates that agreement has been reached with the packaging business community on 'a package of ambitious and achievable targets for more reuse and recycling of packaging' and that studies by Wageningen UR and Rebel Group form the basis for the package.

In this article, we argue that the policy as formulated in the letter of 2 July is not in line with the circular economy policy. We further argue that the announced 'circular standard' for packaging does not aim to reduce the use of packaging (which means it cannot be a circular standard), nor does it stimulate the reuse of packaging, even though this is the objective according to the letter. Instead, the 'circular standard' has a restraining effect on further developments towards a circular economy. In addition, the recycling targets for packaging are poorly substantiated, they are not ambitious, and there is no steering towards better quality recycling.

Finally, we conclude that the packaging industry enjoys a privileged position to influence policy, which does not benefit the ambition of the policy.

We request a fundamental political discussion on the future of packaging policy and the way the government shapes that policy. More specifically, we ask:

that a circular standard be developed that aligns with the Dutch circular targets for 2030 and 2050 and is therefore a benchmark for raw material reduction compared to 2014 (or directs in an alternative way whereby prevention as the highest step in the waste hierarchy also plays an important role);

that targets for the reuse of packaging be established to promote the transition to reuse;

that the recycling targets for packaging are better substantiated and adjusted:

For glass packaging, the target should not be weakened as the current policy intends. The ambition level of the recycling target of 90% must be maintained;

For plastic packaging, the recycling target must be more ambitious than what is already expected under current policy. To this end, research must be carried out again into an ambitious recycling target. The current research is inadequate because, de facto, no scenario was investigated involving new (realistic) developments, but only existing policy was taken into account, where the government does not take up its steering role. The recycling target should be adjusted based on that research. Until then, we request that the government adopts the target of 70% recycling from the plastic pact, to be achieved by 2030.

that policy is formulated to improve the quality of recycling in order to promote market sales and increase environmental benefits;

that policy on packaging and other circular economy topics is not only coordinated in advance with the interested packaging business community, but that the government applies a balanced approach towards all stakeholders.

The 'circular standard'

In the letter of 2 July, State Secretary Van Veldhoven indicates that it is undesirable that "existing recycling targets only steer towards waste recycling and leave reuse out of consideration." Reference is also made to the European Waste Package which requires member states to focus on reuse.

To promote reuse, the State Secretary is introducing a so-called 'circular standard' alongside the recycling targets, in which the reuse of packaging also counts. According to the letter, the proposed 'circular standard' would "encourage producers to set up systems with which packaging is refilled and reused." For glass there will be a 'circular standard' of 86%, for plastic, metal, wood, paper and cardboard packaging, the 'circular standard' will be at the same level as the recycling standard.

We conclude that the 'circular standard' is not a circular standard and should not be called that (which is why we consistently use quotation marks to refer to this standard) because the sub-standards for reuse and

Recycling Netwerk Benelux calls on the State Secretary to reconsider the design of the circular standard.

A consultation concerning the Pre-publication to amend the Packaging Management Decree 2014 runs until 30 November. In a letter of 2 July 2020 to the House of Representatives, State Secretary Stientje van Veldhoven (D66) already informed about the upcoming changes in Packaging Policy. According to the letter, the policy is aimed, in line with the circular economy policy, to 1) reduce the use of packaging, 2) stimulate the repeated reuse of packaging and 3) improve the quality of collection and recycling. The goal of the circular economy policy is to halve the use of minerals, metals and fossil materials by 2030 compared to 2014 and to reduce it to a minimum by 2050.

The letter further indicates that agreement has been reached with the packaging business community on 'a package of ambitious and achievable targets for more reuse and recycling of packaging' and that studies by Wageningen UR and Rebel Group form the basis for the package.

In this article, we argue that the policy as formulated in the letter of 2 July is not in line with the circular economy policy. We further argue that the announced 'circular standard' for packaging does not aim to reduce the use of packaging (which means it cannot be a circular standard), nor does it stimulate the reuse of packaging, even though this is the objective according to the letter. Instead, the 'circular standard' has a restraining effect on further developments towards a circular economy. In addition, the recycling targets for packaging are poorly substantiated, they are not ambitious, and there is no steering towards better quality recycling.

Finally, we conclude that the packaging industry enjoys a privileged position to influence policy, which does not benefit the ambition of the policy.

We request a fundamental political discussion on the future of packaging policy and the way the government shapes that policy. More specifically, we ask:

that a circular standard be developed that aligns with the Dutch circular targets for 2030 and 2050 and is therefore a benchmark for raw material reduction compared to 2014 (or directs in an alternative way whereby prevention as the highest step in the waste hierarchy also plays an important role);

that targets for the reuse of packaging be established to promote the transition to reuse;

that the recycling targets for packaging are better substantiated and adjusted: For glass packaging, the target should not be weakened as the current policy intends. The ambition level of the recycling target of 90% must be maintained;

For plastic packaging, the recycling target must be more ambitious than what is already expected under current policy. To this end, research must be carried out again into an ambitious recycling target. The current research is inadequate because, de facto, no scenario was investigated involving new (realistic) developments, but only existing policy was taken into account, where the government does not take up its steering role. The recycling target should be adjusted based on that research. Until then, we request that the government adopts the target of 70% recycling from the plastic pact, to be achieved by 2030.

that policy is formulated to improve the quality of recycling in order to promote market sales and increase environmental benefits;

that policy on packaging and other circular economy topics is not only coordinated in advance with the interested packaging business community, but that the government applies a balanced approach towards all stakeholders.

The 'circular standard'

In the letter of 2 July, State Secretary Van Veldhoven indicates that it is undesirable that "existing recycling targets only steer towards waste recycling and leave reuse out of consideration." Reference is also made to the European Waste Package which requires member states to focus on reuse.

To promote reuse, the State Secretary is introducing a so-called 'circular standard' alongside the recycling targets, in which the reuse of packaging also counts. According to the letter, the proposed 'circular standard' would "encourage producers to set up systems with which packaging is refilled and reused." For glass there will be a 'circular standard' of 86%, for plastic, metal, wood, paper and cardboard packaging, the 'circular standard' will be at the same level as the recycling standard.

We conclude that the 'circular standard' is not a circular standard and should not be called that (and we therefore consistently use quotation marks to refer to this standard) because the sub-standards for reuse and recycling are not expressed in terms of their contributions to reducing (abiotic) raw material use and a sub-standard for preventing raw material use (packaging use) is missing. But in addition, the 'circular standard' also fails to stimulate reuse and we believe it has a potential restraining effect on circular developments that should lead to a halving of abiotic raw material use by 2030. We therefore call on the State Secretary to reconsider the standard because Dutch packaging policy, and potentially other circular economy policies as well, risk steering in a completely wrong direction.

The 'circular standard' explained

The 'circular standard' is a completely new standard that combines recycling and reuse in one percentage. On page 2 of the Technical Explanation to the House of Representatives letter of 2 July, it is represented in a diagram. We have reproduced that diagram below. The core of the 'circular standard' is that the recycling percentage and the return percentage of reusable packaging are averaged together relative to the share of that packaging on the market.

Criticisms of the 'circular' standard:

The 'circular standard' is not a circular standard because it does not attempt to standardise the contribution to less abiotic raw material use (in principle compared to 2014) through reuse and recycling of packaging. Any prevention of the use of packaging (prevention) is not included in the standard at all. With the current interpretation of the 'circular standard', raw material use may even increase.

The proposed 'circular standard' gives a far too rosy picture of the actual circularity of packaging. Circularity is a much higher goal than recycling and therefore more difficult to achieve. It is therefore strange that the current collection and processing of, for example, glass packaging, according to the 'circular standard' method, actually scores higher (86%) than what is recycled at all (76%). This gives the idea that glass packaging is already almost circular, which is far from being the case yet. This has a restraining effect on further steps towards circularity.

According to the explanation in the letter, the 'circular standard' should steer towards more reuse, but it does not or hardly does so, whereas a standard specifically aimed at reuse would.

A circular standard should steer towards sustainability, more specifically on less raw material use compared to 2014, but the proposed standard mainly gives a rosier picture of the current handling of packaging. It seems as if businesses must comply with a new weighty standard, but in fact it is about consolidating current practices.

According to the letter of 2 July, the goal of the 'circular standard' is to stimulate reuse. It does not do that, and it is also much better to implement a reuse target that establishes what share of the packaging placed on the market is intended to be reused. The packaging industry must then report on how they comply with this. This gives a clear picture of the state of affairs regarding reusable packaging, while the circular standard in its current form mainly creates confusion and has a restraining effect.

A reuse target is separate from a recycling target. A recycling target relates to waste and the reuse of the material. A reuse target relates to reuse of the product before it has become waste. A reuse target can therefore be introduced independently without having a negative effect on recycling. Through better collection of reusable packaging, there can even be a positive effect on the recycling rate when the packaging reaches the end of its life and is not reused but recycled.

The packaging recycling policy

Dutch packaging policy must at least meet European packaging directives. This imposes the same requirements on all member states, but the letter from the State Secretary says that the Netherlands "wants to lead the transition to a circular economy." The European Packaging Directive was last updated on 30 May 2018 and had to be transposed into Dutch policy by 5 July 2020 at the latest.

The old European targets were set in 2004 and had to be achieved by 31 December 2008. The Netherlands previously set stricter targets with the Packaging Management Decree 2014. The revised European directive formulates targets for 2025 and 2030.

Apart from new targets, there is also a new measurement method to determine the rate of recycling. The new calculation rules set out in Article 6a of the directive must ensure that losses occurring during sorting and preparation for recycling are no longer included in the reported weight of packaging entering the recycling process. This method gives a better measure of actual recycling.

Currently, the old method is still used, whereby after sorting the waste, at the recycler's weighbridge, the waste is weighed and counted as recycled, even if it is further sorted by the recycler into fractions that are incinerated or exported without monitoring of what happens to them next. A recent study by Lighthouse Reports and NRC recently showed that Dutch packaging waste counted as recycled is now ending up in landfills in places like Turkey.

Although European recycling targets have been tightened and there is a better measurement methodology, it has also been established that packaging that is reused (think of a refillable beer bottle) may count towards the achievement of the recycling target for a maximum of 5%. This means that in systems where reusable packaging has already been partially adopted, such as glass packaging, the recycling target becomes easier to achieve. This should also be taken into account when setting the targets.

Commissioned by the Ministry of Infrastructure and Water Management, Wageningen UR calculated in two studies, one for plastic packaging and one for other packaging materials, the expected effect of shifting the measurement point for determining the recycling percentage. According to State Secretary Van Veldhoven's letter, these studies also form part of the basis for determining new Dutch recycling targets, which have the European targets as a lower limit.

Table 1: recycling targets and recycling results of packaging

Misinformation from Government and packaging business community about packaging recycling

For years, the Dutch government and the Dutch packaging business community, represented by the Packaging Waste Fund, failed to provide correct interpretations of packaging recycling figures. Using a methodology that greatly flattered recycling figures, especially for plastic packaging, the suggestion was made that the Netherlands was performing very well in terms of recycling, and this was actively promoted. In addition, two other important aspects remained out of consideration in the recycling figures, namely the quality of the recyclate and the actual use of recycled material in high-quality applications.

Recycling Netwerk indicated in 2013 that the recycling figures are overestimated and asked for them to be corrected. We also requested that more steering should be directed at the quality of recycling and advocated for reliable monitoring.

The central government and the packaging industry united in the Waste Fund are to blame for the repeated misrepresentation of facts. While the recycling percentage for plastic packaging rose 'on paper' to 50% and higher, the CPB Netherlands Bureau for Economic Policy Analysis concluded that the collection of plastic packaging waste yields little environmental benefit. The misrepresentation of actual recycling likely had a restraining effect on environmental policy.

Even if actions were taken within the limits of European rules, and overestimations also occur in other European countries, it is up to the Dutch government itself to provide a correct interpretation of the figures.