Eunomia assessment of the deposit return scheme collection plan for cans in the public domain by Afvalfonds executive summary

Eunomia bases its assessment on an international benchmark and interviews with Dutch experts and people with practical experience from both industry (with knowledge of deposit return schemes and the beverage market) and municipalities (with knowledge of waste management, planning and municipal services).

Eunomia's findings in brief:

Eunomia estimates that the Afvalfonds proposal is insufficiently consumer-friendly to expect that the statutory 90% separate collection target can be achieved. Afvalfonds makes too many choices that compromise consumer-friendliness and thus present risks that, according to Eunomia, are likely to “have a cumulative effect resulting in too many cans being 'lost' to achieve the 90% target”;

Regarding the statutory deadline of 31 December 2022, Eunomia concludes that they consider it highly problematic to organise everything for this parallel and complex system within the legal timeframe. The lack of detail in the Afvalfonds plan and the lack of transparency about the current state of affairs made answering this question somewhat more difficult, but Eunomia still feels confident enough to say this. 

Eunomia. Deposit Return in the Netherlands An assessment of the Afvalfonds proposal for beverage can collection in the public domain (PDF download)

The full report

Background to the Eunomia study

Former State Secretary Stientje van Veldhoven decided on 3 February 2021 that from 31 December 2022, there will be a deposit on cans and a collection system must be operational to collect 90% of cans separately. Because supermarkets refuse to collect cans in their shops, the Afvalfonds (representing the packaging industry) published an alternative plan on 14 December 2021: they want to collect deposit cans outside supermarkets via deposit return machines in public spaces.

Various stakeholders, including the environmental movement, Members of Parliament, the Consumers' Association and Metal Packaging Netherlands, responded with critical comments and questions about the Afvalfonds plan to collect cans in public spaces. In the meantime, VNG and NVRD have also expressed their concerns more explicitly. Partly for this reason, the environmental organisation Recycling Netwerk requested a review of the Afvalfonds plan from international research consultancy Eunomia, known for its work on the circular economy and research for the European Commission. In this press release, we provide a summary of the key findings.

Key elements of the Afvalfonds plan

In December 2021, the Afvalfonds published its plan for collecting cans via deposit return machines in public spaces. The key points of this plan are as follows:

After full roll-out, there will be 3,300 return points where people can return cans and get their deposit back. All return points will have at least one deposit return machine;

Approximately 3,000 of the return points are planned not in, but “near” supermarkets; the remaining 300 locations are planned in so-called high-traffic locations such as public transport stations and petrol stations;

For residential shopping areas with one supermarket, the Afvalfonds envisages a return point in a nearby public space, and in the case of areas with multiple supermarkets (2-8), the target is a collection point within a 500-metre radius of the most central supermarket;

Outdoor deposit return machines will be covered and sheltered, in so-called ‘shelters’;

It is a phased implementation model. On 31 December 2022, an 80% roll-out is envisaged: 1,300 deposit return machines outside shops and at high-traffic locations, and 1,500 additional locations guaranteed by supermarkets. The goal is to provide the 3,300 return points by April 2024, some of which will still be temporary. During 2023 and 2024, the temporary locations guaranteed by supermarkets will be replaced by locations “near” the supermarkets;

In addition to the return points where consumers receive their deposit back, 5,000 voluntary return points are expected to be set up by 2023 where consumers can dispose of their cans in designated collection bins, and the owner of the bin can claim the deposit. In the long term, 10,000 of these voluntary points are expected;

The Afvalfonds presents the public return points as a first step towards ‘circular hubs’ where other material flows can also be collected in the future (scaling up).

Eunomia Methodology

Eunomia Research and Consulting has extensive experience with deposit return schemes

Eunomia bases its assessment on an international benchmark and interviews with Dutch experts and people with practical experience from both industry (with knowledge of deposit return schemes and the beverage market) and municipalities (with knowledge of waste management, planning and municipal services).

Eunomia's findings in brief:

Eunomia estimates that the Afvalfonds proposal is insufficiently consumer-friendly to expect that the statutory 90% separate collection target can be achieved. Afvalfonds makes too many choices that compromise consumer-friendliness and thus present risks that, according to Eunomia, are likely to “have a cumulative effect resulting in too many cans being 'lost' to achieve the 90% target”;

Regarding the statutory deadline of 31 December 2022, Eunomia concludes that they consider it highly problematic to organise everything for this parallel and complex system within the legal timeframe. The lack of detail in the Afvalfonds plan and the lack of transparency about the current state of affairs made answering this question somewhat more difficult, but Eunomia still feels confident enough to say this.

Eunomia. Deposit Return in the Netherlands An assessment of the Afvalfonds proposal for beverage can collection in the public domain (PDF download)

The full report

Background to the Eunomia study

Former State Secretary Stientje van Veldhoven decided on 3 February 2021 that from 31 December 2022, there will be a deposit on cans and a collection system must be operational to collect 90% of cans separately. Because supermarkets refuse to collect cans in their shops, the Afvalfonds (representing the packaging industry) published an alternative plan on 14 December 2021: they want to collect deposit cans outside supermarkets via deposit return machines in public spaces.

Various stakeholders, including the environmental movement, Members of Parliament, the Consumers' Association and Metal Packaging Netherlands, responded with critical comments and questions about the Afvalfonds plan to collect cans in public spaces. In the meantime, VNG and NVRD have also expressed their concerns more explicitly. Partly for this reason, the environmental organisation Recycling Netwerk requested a review of the Afvalfonds plan from international research consultancy Eunomia, known for its work on the circular economy and research for the European Commission. In this press release, we provide a summary of the key findings.

Key elements of the Afvalfonds plan

In December 2021, the Afvalfonds published its plan for collecting cans via deposit return machines in public spaces. The key points of this plan are as follows:

After full roll-out, there will be 3,300 return points where people can return cans and get their deposit back. All return points will have at least one deposit return machine;

Approximately 3,000 of the return points are planned not in, but “near” supermarkets; the remaining 300 locations are planned in so-called high-traffic locations such as public transport stations and petrol stations;

For residential shopping areas with one supermarket, the Afvalfonds envisages a return point in a nearby public space, and in the case of areas with multiple supermarkets (2-8), the target is a collection point within a 500-metre radius of the most central supermarket;

Outdoor deposit return machines will be covered and sheltered, in so-called ‘shelters’;

It is a phased implementation model. On 31 December 2022, an 80% roll-out is envisaged: 1,300 deposit return machines outside shops and at high-traffic locations, and 1,500 additional locations guaranteed by supermarkets. The goal is to provide the 3,300 return points by April 2024, some of which will still be temporary. During 2023 and 2024, the temporary locations guaranteed by supermarkets will be replaced by locations “near” the supermarkets;

In addition to the return points where consumers receive their deposit back, 5,000 voluntary return points are expected to be set up by 2023 where consumers can dispose of their cans in designated collection bins, and the owner of the bin can claim the deposit. On the long term, 10,000 of these voluntary points are expected;

The Afvalfonds presents the public return points as a first step towards ‘circular hubs’ where other material flows can also be collected in the future (scaling up).

Eunomia Methodology

Eunomia Research and Consulting has extensive experience with deposit return schemes in countries around the world and has worked with governments, manufacturers, retailers, system operators and NGOs. For this report, in addition to their own rich knowledge, Eunomia also conducted targeted interviews with Dutch experts and people with practical experience, including both “industry” perspectives (a category of interviewees with expertise and insight into deposit return provision and the Dutch beverage market) and “municipal” perspectives (a category of interviewees with expertise and insight into waste management, planning and municipal services).

The vast majority of interviewees chose to remain anonymous. These requests are respected throughout the report and in some cases limit Eunomia's ability to provide specific information and sources related to the Dutch context. The input from the Dutch interviewees was used by Eunomia to test their own international knowledge and experience against the Dutch context and to highlight unique challenges or opportunities in the Dutch context.

Eunomia's Key Findings

Risks for achieving 90% separate collection

Eunomia first examined how likely it is that the Afvalfonds set-up for collection outside supermarkets will achieve the statutory target of 90% separate collection for cans by 2024. “Achieving the 90% separate collection target means matching the best deposit return systems in the world,” says Eunomia. A collection target of 90% means that only 1 in 10 cans may fall outside the system. “Well-performing deposit return systems put people first, because public participation determines whether a deposit return scheme succeeds or fails.”

For this main question, Eunomia therefore compared the Afvalfonds plan against the characteristics of deposit return schemes with a return rate of 90% or more.

These characteristics are:

the amount of the deposit, which forms the economic incentive to participate;

a highly accessible network of return points, the absolute number of return points and their placement relative to daily routines; a consistent and straightforward system design, which facilitates understanding and motivation to participate;

clear communication to the consumer, to support all of the above.

No single factor determines the operation of the deposit return scheme on its own. It is the combination of and interaction between these factors that determines how convincingly user-friendly the system is and whether the 90% separate collection target can be achieved.

The minimum deposit amount is legally set at 0.15 euros, and this is applied to cans.Since the deposit amount is neither low nor high compared to the international context, the other factors are decisive.

Here, Eunomia identifies some substantial risks for achieving the collection target.

First, the number of collection points in the Afvalfonds plan is far below the number of collection points in deposit return schemes that achieve 90% return rates, see table 5-1. The Afvalfonds plan provides for 2.5 deposit return machines and 1.9 collection points per 10,000 inhabitants. In comparison, Germany has 5.3 deposit return machines and 16 collection points per 10,000 inhabitants. This means that the Afvalfonds plan gives people significantly less opportunity to return their cans in exchange for the deposit they paid at the time of purchase.

Eunomia also refers to an earlier study by EY Parthenon (2019) on system design for small plastic bottles commissioned by the Dutch government, in which EY concludes that with around 12,000 return points in retail outlets, a collection rate of 92-93% would be achieved. This confirms Eunomia's analysis that the low number of collection points in the Afvalfonds plan poses a risk to achieving the 90% collection target, not only in relation to practice abroad, but also in the previously researched Dutch context.

According to Eunomia, the voluntary return points, which are a major part of the Afvalfonds plan, do not qualify as part of the deposit return scheme, simply because people do not get their deposit back there and these points therefore do not offer the economic incentive to return your can. Even when they are included, the density of the collection network is still “much lower” than in deposit return schemes with a return rate of 90% or more.

Apart from the numbers, the location of the return points also creates a barrier to consumer participation. ‘Return-to-retail’, meaning collection in retail outlets such as supermarkets, performs quantitatively better internationally than systems where people have to go to another location, due to its consumer-friendliness. Furthermore, there is no deposit return scheme in the world that achieves a 90% return rate without return-to-retail (see figure 3-3). In other words: only deposit return systems with collection in retail outlets achieve return rates of 90% as legally prescribed in the Netherlands.

Eunomia concludes that the Afvalfonds plan to place deposit return machines “near the supermarket” cannot be compared to return in supermarkets in terms of consumer-friendliness. For instance, the deposit return machines in public spaces are unmanned, which means there is no one to quickly resolve the issue in case of error messages, something supermarket staff can normally handle quickly. Eunomia also points out that under the Afvalfonds plan, consumers will have to go out of their way to return cans instead of returning them where they already go: the supermarket. Furthermore, expert interviews conducted by Eunomia show that there are doubts as to whether it is practically possible to guarantee the ‘maximum 500 metres to the central supermarket’ target across the Netherlands as communicated by Afvalfonds, which will further increase the inconvenience for consumers.

In addition, Eunomia also takes into account the habits and preferences of the Dutch consumer. Eunomia emphasises that Dutch consumers have already developed the habit of returning their deposit-bearing beverage packaging to the supermarket. According to a survey by the Consumers' Association, 89% of Dutch consumers also have a (strong) preference for returning both cans and bottles to retail outlets. Deviating from these habits and preferences puts consumer-friendliness and thus participation under pressure.

Finally, Eunomia emphasises that there is no other deposit return system in which the consumer has to go to different locations for different types of packaging. Even in the case of a phased introduction, as in the Netherlands, consumers can normally return all deposit beverage packaging at the same collection points in exchange for the deposit. The fact that, according to Afvalfonds, consumers must go to different locations for different beverage packaging makes the system less user-friendly and also goes against existing routines.

Goodinformative and motivating communication about the system is made more difficult by the introduced complexity. Eunomia mentions here, for example, the fact that consumers must be directed to a different location for cans than for plastic bottles and glass beer bottles. The research consultancy also points out that this plan does not establish a nationally coherent system for cans, because the implementation will be “hyper-local” due to the need to find suitable locations at municipal level. This raises serious barriers to setting up a national communication campaign. The fact that the Afvalfonds plan envisages a phased roll-out also means that communication will have to be adapted over time and target new consumer behaviour at different stages.