Dutch multinationals are slowing down the plastic transition

System change must focus on raw material reduction

The “Dutch Sustainable Growth Coalition” (DSGC), led by the CEOs of AkzoNobel, DSM, FrieslandCampina, Heineken, KLM, Philips, Shell and Unilever, advocated last month for system change in the plastics value chain, but overlooks the fact that more is needed than just recycling. A genuine system change means a significant reduction in the amount of plastics, and therefore raw materials, used in our society. Even though the coalition expresses the intention to use fewer materials and operate zero waste, it barely addresses prevention or reuse strategies. Yet that is precisely where the emphasis should lie. Otherwise, total raw material consumption will still increase, in conflict with sustainability.

To achieve the transition towards a circular economy, single-use plastics will have to be phased out as much as possible, redundant packaging avoided, circular product design made mandatory, and reuse systems scaled up (see the work of Mission Reuse).

R-ladder requires innovations focused on product functions

The coalition of multinationals seems to embrace the concept of circular design and zero waste. However, they make some crucial errors in reasoning that steer measures in the wrong direction. On page 7, the report refers to the ten “R” strategies in their zero waste hierarchy.

This differs in important aspects from the R-ladder used by the Dutch government (see figure below).

The DSGC's Zero Waste Hierarchy also starts with Refuse, but applies this to the amount of material used, not to the number of products. This means that more products could be produced, but just slightly more efficiently with fewer raw materials (equivalent to the second step, Reduce). Using raw materials efficiently is important, but lightweight plastics are not always the best solution. Less material in a packaging (if taken too far) can compromise robustness, making it no longer reusable. Refuse in the R-ladder is about the question of whether we need a certain product at all? This calls for creativity to radically rethink product functions.

A correct R-ladder for the circular economy places products, and more specifically their functions, at the centre. The question is how products can be packaged with minimal raw material use and environmental pressure per functional unit “x-number of times packaging a product”. That means reusable packaging, or completely different packaging concepts, must also be seen as an alternative to single-use packaging.

There are many examples of R-strategies where redundant/disposable packaging is effectively avoided. Fresh vegetables do not need to be packaged if the producer uses laser marking (strategy R0 in the R-ladder). One-litre bottles for soft drinks could be replaced by a flavour and CO2 tablet (R1). The amount of material in both reusable and single-use bottles can be reduced (R2) through design (for example, with a ‘waisted bottle’). Reusable (glass) packaging is already used for beer (R3), and this could be extended to other beverages. For take-away cups and food containers, there are innovative reuse systems that need to be scaled up. Wooden pallets are already frequently reused (R3) and repaired for reuse (R4) when damaged. The strategies Refurbish (R5) and Remanufacture (R6) are particularly relevant in construction (e.g. for plastic window frames, doors). Repurpose (R7) could be applied to some plastic furniture.

Furthermore, the multinationals' zero waste hierarchy has a separate step for Redesign, although that is not a distinct strategy in itself. Redesign is essential for all strategies focused on prevention, reuse, and recycling, but that does not make it a strategy on its own. It is actually an inherent part of any approach aimed at the circular economy.

Life cycle assessments must not become a loophole for bans on single-use plastics

The report states that the choice for a specific R-strategy should depend on a life cycle assessment (LCA), which would be an “objective” tool. According to the coalition of multinationals, in that case, reuse should not always be pursued, but some single-use plastics banned by the European Single Use Plastics Directive (SUPD) would be permitted based on an LCA.

However, the authors ignore the fact that plastic pollution (litter and plastic soup, which the SUPD aims to reduce) and microplastics are not included in an LCA. Moreover, the outcome of LCAs is often determined by the underlying assumptions, which can be influenced by the clients. Because they benefit from a certain outcome, favourable assumptions are often

System change must focus on raw material reduction

The “Dutch Sustainable Growth Coalition” (DSGC), led by the CEOs of AkzoNobel, DSM, FrieslandCampina, Heineken, KLM, Philips, Shell and Unilever, advocated last month for system change in the plastics value chain, but overlooks the fact that more is needed than just recycling. A genuine system change means a significant reduction in the amount of plastics, and therefore raw materials, used in our society. Even though the coalition expresses the intention to use fewer materials and operate zero waste, it barely addresses prevention or reuse strategies. Yet that is precisely where the emphasis should lie. Otherwise, total raw material consumption will still increase, in conflict with sustainability.

To achieve the transition towards a circular economy, single-use plastics will have to be phased out as much as possible, redundant packaging avoided, circular product design made mandatory, and reuse systems scaled up (see the work of Mission Reuse).

R-ladder requires innovations focused on product functions

The coalition of multinationals seems to embrace the concept of circular design and zero waste. However, they make some crucial errors in reasoning that steer measures in the wrong direction. On page 7, the report refers to the ten “R” strategies in their zero waste hierarchy.

This differs in important aspects from the R-ladder used by the Dutch government (see figure below).

The DSGC's Zero Waste Hierarchy also starts with Refuse, but applies this to the amount of material used, not to the number of products. This means that more products could be produced, but just slightly more efficiently with fewer raw materials (equivalent to the second step, Reduce). Using raw materials efficiently is important, but lightweight plastics are not always the best solution. Less material in a packaging (if taken too far) can compromise robustness, making it no longer reusable. Refuse in the R-ladder is about the question of whether we need a certain product at all? This calls for creativity to radically rethink product functions.

A correct R-ladder for the circular economy places products, and more specifically their functions, at the centre. The question is how products can be packaged with minimal raw material use and environmental pressure per functional unit “x-number of times packaging a product”. That means reusable packaging, or completely different packaging concepts, must also be seen as an alternative to single-use packaging.

There are many examples of R-strategies where redundant/disposable packaging is effectively avoided. Fresh vegetables do not need to be packaged if the producer uses laser marking (strategy R0 in the R-ladder). One-litre bottles for soft drinks could be replaced by a flavour and CO2 tablet (R1). The amount of material in both reusable and single-use bottles can be reduced (R2) through design (for example, with a ‘waisted bottle’). Reusable (glass) packaging is already used for beer (R3), and this could be extended to other beverages. For take-away cups and food containers, there are innovative reuse systems that need to be scaled up. Wooden pallets are already frequently reused (R3) and repaired for reuse (R4) when damaged. The strategies Refurbish (R5) and Remanufacture (R6) are particularly relevant in construction (e.g. for plastic window frames, doors). Repurpose (R7) could be applied to so

Furthermore, the multinationals' zero waste hierarchy has a separate step for Redesign, although that is not a distinct strategy in itself. Redesign is essential for all strategies focused on prevention, reuse, and recycling, but that does not make it a strategy on its own. It is actually an inherent part of any approach aimed at the circular economy.

Life cycle assessments must not become a loophole for bans on single-use plastics

The report states that the choice for a specific R-strategy should depend on a life cycle assessment (LCA), which would be an “objective” tool. According to the coalition of multinationals, in that case, reuse should not always be pursued, but some single-use plastics banned by the European Single Use Plastics Directive (SUPD) would be permitted based on an LCA.

However, the authors ignore the fact that plastic pollution (litter and plastic soup, which the SUPD aims to reduce) and microplastics are not included in an LCA. Moreover, the outcome of LCAs is often determined by the underlying assumptions, which can be influenced by the clients. Because they benefit from a certain outcome, favourable assumptions are often made for single-use plastics. An LCA and how the results are interpreted and communicated are therefore not always completely objective; this depends on how it has been executed. In short, the DSGC's recommendation to adapt the Single Use Plastics Directive so that companies can still use certain single-use packaging based on an LCA is certainly undesirable. In principle, bans in European Directives should be implemented categorically, with exceptions possible for medical applications.

Design for recycling: place sustainability above marketing

One of the problems highlighted by the DSGC in the report is the insufficient supply of high-quality recycled plastic. The authors point to sorters and recyclers at the end of the chain to solve this problem. However, it is the producers (i.e. plastic converters) and brand owners (including the members of the DSGC) who hold the most important cards to facilitate the quality of recycling from the very beginning of the chain, by following circular principles during the design or purchasing phase.

The report rightly states that there are too many different types of plastic and that it is necessary to focus primarily on plastics that retain their value and can be easily recovered. Factors that can disrupt the sorting and recycling process include: non- or poorly-recyclable plastics (for example under RIC code 7), films and laminates, certain additives, adhesives, labels, multi-layer packaging or components made of other materials (such as beverage cartons with plastic and aluminium on the inside) that cannot (easily) be separated from each other.

However, brand owners like Unilever have the power to decide how they make their products and which substances they use in them. They can therefore eliminate the above-mentioned factors themselves by designing their products/components circularly and imposing product requirements on their chain partners.

Currently, brand owners mainly set product requirements related to the look of packaging, such as transparent plastics or colour schemes that cannot (easily) be supplied by recyclate. Instead of marketing, brand owners must put sustainability first. By prescribing simple designs and mono-materials (PE, PP, and PET), uniform packaging is created, which makes reuse, collection, sorting, and ultimately recycling easy. This is possible for product groups such as beverage, food, and cosmetics packaging.

The DSGC does state that the complexity of plastic products must be reduced through circular design guidelines, sector-specific standards, and roadmaps to phase out certain materials. But as long as this remains voluntary, it will not happen fast enough. For companies, marketing still comes before sustainability, even if it is worse for the environment. Therefore, it is necessary to enforce circular design through regulation, specifically the Packaging and Packaging Waste Directive. Design for prevention or reuse must be paramount here. New regulations, guidelines, and standards must not only be formulated in cooperation with industry, as the report suggests (p.9), but also with innovative medium and small enterprises and civil society parties, including environmental organisations.

Be careful with end-of-pipe solutions like chemical recycling

The DSGC places a lot of trust in technological recycling innovations, i.e. “advanced” recycling, which is actually a euphemism for chemical recycling. However, it does not yield as much environmental benefit as claimed in the report. Rather, it is an energy-intensive process that uses harmful chemicals.

Perhaps chemical recycling can be used for residual streams that cannot be processed by mechanical recycling, but currently, chemical recycling also requires relatively clean plastic waste streams. However, most plastic waste can be mechanically recycled, as long as plastic products are initially designed for recycling and collected correctly.

Moreover, chemical recycling requires high investments. Pumping millions of euros in subsidies into this route quickly comes at the expense of other strategies higher up the R-ladder. High investments in expensive facilities for chemical recycling also create a lock-in situation because they require a continuous supply of plastic waste. This means there is less incentive to focus on reduction, prevention, and reuse.

Collection: ensure clean mono-streams

To produce high-quality recyclate, it is essential to collect as many clean mono-streams without contamination as possible during the collection of (plastic) waste. Deposit-return schemes are the tool par excellence for this, but other collection systems are also possible.

For certain plastic products in which substances of concern may have been incorporated, such as electronic equipment, controlled loop systems are desirable. These are systems in which plastic products (components and materials) return to the producer (or producers from the same sector) at the end of their lifespan via a return system, after having passed through a processing chain with a high degree of traceability. The advantage of this is that producers know exactly which materials and substances their products consist of and can process them again in their production process.

The report refers to post-sorting of plastic waste instead of sorting at source. It is indeed true that post-sorting techniques have improved over the years and the difference in yield with sorting at source is currently not very large, but that is mainly because the quality of source separation is inadequate. Improving source separation, combined with circular design, remains necessary for those types of plastic waste where neither deposit-return nor controlled loop systems function to achieve clean mono-streams. This requires, among other things, clear communication from municipalities to citizens as well as a centralised approach.

Conclusion

The vision of the Dutch Sustainable Growth Coalition therefore seems primarily a continuation of the current disposable model, in which the loop is closed better but there is no significant reduction in plastic and therefore raw material consumption. Some policy recommendations are welcomed by Recycling Netwerk Benelux, but the proposals discussed in this article will only delay the transition towards a circular economy. If the members of the multinational coalition truly want to work on the transition, they will have to redesign their own business models, production processes, and value chains according to the official R-ladder. That would truly set system change in motion.