How State Secretary for Infrastructure and Water Management Vivianne Heijnen can accelerate the transition to a circular economy

Environmental organisation Recycling Netwerk makes several policy proposals in a letter to State Secretary for I&W Vivianne Heijnen for a faster transition to a circular economy.

The new Dutch cabinet Rutte IV has been officially installed since 10 January. It was previously announced that Stientje van Veldhoven (D66) would not continue as State Secretary for Infrastructure and Water Management (I&W). Steven van Weyenberg was state secretary from 10 August 2021 to 10 January 2022. In the meantime, Vivianne Heijnen (CDA) has started her new role.

In the coalition agreement "Looking out for each other, looking forward to the future", the Rutte IV Cabinet speaks about its ambitions in the area of climate change and circularity. The Netherlands wants to belong to the "leading group" in the transition to a green economy. The cabinet wants to be climate neutral by 2050.

As an environmental organisation, we welcome these intentions. State Secretary Heijnen plays an important role in the circular economy dossier. Based on our expertise, we wrote her a letter in which we highlight policy topics that we consider essential to realize the ambitions in the coalition agreement. These are the topics that are central to the transition to a circular economy and that require decisive policy.

Raw material reduction in construction, mobility, electronics, textiles and packaging 

A circular economy aims to reduce the use of raw materials. Various industries are currently still heavily dependent on new raw materials, resulting in a huge environmental impact.

However, this issue is not central to the coalition agreement. The coalition agreement rightly makes the link between climate and the circular economy (p.7), because after the energy transition, a circular economy is the second domain with which CO2 emissions can be strongly reduced. But reducing raw material consumption is of broader strategic interest for the Netherlands. The environmental gain achieved by it also goes much further than lower CO2 emissions.

The government-wide Circular Economy program 'A Circular Netherlands in 2050' drawn up in 2016 contains the ambitious target of halving abiotic raw material use by 2030 compared to 2014 and achieving full circularity by 2050. We ask the State Secretary to reconfirm these goals in this government term and to work out binding raw material reduction plans for domains such as construction, mobility, electrical appliances, textiles and packaging. It is important to note here that many policies are currently focused on handling and treating waste, not on reducing raw materials. A fundamental reorientation of the policy approach is necessary to strongly reduce raw material consumption.

Extended producer responsibility

For more and more product groups, Extended Producer Responsibility (EPR) exists in the Netherlands. With this, the government makes producers responsible for the life cycle of their products and product systems, with the aim of greatly reducing their impact.

In the Netherlands, EPR systems already exist for car tyres and car wrecks, packaging, electronic equipment, and batteries and accumulators. The government has drawn up draft regulations to at least add textiles to this from 2023. Recycling Netwerk recently submitted a view for this.

To give substance to the objectives, the producers for whom the EPR applies set up producer responsibility organisations (PROs). These PROs implement the policy on behalf of the producers involved.

Encouraging producers to make their products more sustainable and reduce their impact is a good thing. However, we also see that the instrument of producer responsibility often leads to ineffective environmental policy. Producer organisations have a mandate through regulations to reduce the environmental impact of products. But some PROs also appear to exert additional, negative, influence on environmental objectives and regulations. They represent the financial interests of producers through lobbying practices and thus oppose more ambitious environmental policies.

Producer organisations should not be substitute interest groups. Governments and society depend on producer organisations to implement policy. The PROs should also focus on implementation and not on weakening it. Therefore, we propose that the government regulates the governance of PROs better. To this end, the government must start a broad discussion with various stakeholders, including academics, environmental organisations, waste collectors and also producers. We at Recycling Netwerk have already started research into better governance for producer organisations.

Focus on prevention

A circular economy must g

Environmental organisation Recycling Netwerk makes several policy proposals in a letter to State Secretary for I&W Vivianne Heijnen for a faster transition to a circular economy.

The new Dutch cabinet Rutte IV has been officially installed since 10 January. It was previously announced that Stientje van Veldhoven (D66) would not continue as State Secretary for Infrastructure and Water Management (I&W). Steven van Weyenberg was state secretary from 10 August 2021 to 10 January 2022. In the meantime, Vivianne Heijnen (CDA) has started her new role.

In the coalition agreement "Looking out for each other, looking forward to the future", the Rutte IV Cabinet speaks about its ambitions in the area of climate change and circularity. The Netherlands wants to belong to the "leading group" in the transition to a green economy. The cabinet wants to be climate neutral by 2050.

As an environmental organisation, we welcome these intentions. State Secretary Heijnen plays an important role in the circular economy dossier. Based on our expertise, we wrote her a letter in which we highlight policy topics that we consider essential to realize the ambitions in the coalition agreement. These are the topics that are central to the transition to a circular economy and that require decisive policy.

Raw material reduction in construction, mobility, electronics, textiles and packaging

A circular economy aims to reduce the use of raw materials. Various industries are currently still heavily dependent on new raw materials, resulting in a huge environmental impact.

However, this issue is not central to the coalition agreement. The coalition agreement rightly makes the link between climate and the circular economy (p.7), because after the energy transition, a circular economy is the second domain with which CO2 emissions can be strongly reduced. But reducing raw material consumption is of broader strategic interest for the Netherlands. The environmental gain achieved by it also goes much further than lower CO2 emissions.

The government-wide Circular Economy program 'A Circular Netherlands in 2050' drawn up in 2016 contains the ambitious target of halving abiotic raw material use by 2030 compared to 2014 and achieving full circularity by 2050. We ask the State Secretary to reconfirm these goals in this government term and to work out binding raw material reduction plans for domains such as construction, mobility, electrical appliances, textiles and packaging. It is important to note here that many policies are currently focused on handling and treating waste, not on reducing raw materials. A fundamental reorientation of the policy approach is necessary to strongly reduce raw material consumption.

Extended producer responsibility

For more and more product groups, Extended Producer Responsibility (EPR) exists in the Netherlands. With this, the government makes producers responsible for the life cycle of their products and product systems, with the aim of greatly reducing their impact.

In the Netherlands, EPR systems already exist for car tyres and car wrecks, packaging, electronic equipment, and batteries and accumulators. The government has drawn up draft regulations to at least add textiles to this from 2023. Recycling Netwerk recently submitted a view for this.

To give substance to the objectives, the producers for whom the EPR applies set up producer responsibility organisations (Producer Responsibility Organisations, PROs). These PROs implement the policy on behalf of the producers involved.

Encouraging producers to make their products more sustainable and reduce their impact is a good thing. We also see that the instrument of producer responsibility often leads to ineffective environmental policy. Producer organisations have a mandate through regulations to reduce the environmental impact of products. But some PROs also appear to exert additional, negative, influence on environmental objectives and regulations. They represent the financial interests of producers through lobbying practices and thus oppose more ambitious environmental policies.

Producer organisations should not be substitute interest groups. Governments and society depend on producer organisations to implement policy. The PROs should also focus on implementation and not on weakening it. Therefore, we propose that the government regulates the governance of PROs better. To this end, the government must start a broad discussion with various stakeholders, including academics, environmental organisations, waste collectors and also producers. We at Recycling Netwerk have already started research into better governance for producer organisations.

Focus on prevention

A circular economy must be about reducing the use of raw materials. But the Dutch government's policy focuses mainly on waste treatment. Although high-quality recycling makes reusing raw materials possible, more attention should be paid to prevention and reuse. An example: In 2019, Recycling Netwerk showed that manufacturers of alcoholic beverages, shampoo and fabric softener make their packaging unnecessarily heavy for marketing reasons. This leads to material waste. By making this packaging lighter, raw materials can be saved. Prevention and product reuse, and not recycling, are at the top of the R-ladder because they directly contribute to achieving circular goals. Furthermore, the European Waste Framework Directive obliges governments to follow the priority order of the waste hierarchy when drafting legislation. Unfortunately, this is hardly happening yet.

Focus on reuse

A large part of single-use packaging can be replaced by reusable packaging. This is also necessary to meet the requirements of the European Single Use Plastics (SUP) Directive. Former State Secretary Stientje van Veldhoven wrote in her letter to parliament in February 2021 that she wanted to commit to "national agreements to offer reusable cups, cutlery and packaging to users wherever possible and to phase out the use of disposables in the coming years where possible". We call on the cabinet to turn this policy ambition into concrete regulations for 2023.

Currently, Dutch policy ambition and implementation are limited, certainly compared to neighbouring countries. In 2026, a measurable, quantitative reduction in consumption for plastic beverage cups and food packaging must be demonstrated in Europe, and reuse must be encouraged. This should not only focus on single-use plastics, as this risks a shift to other raw materials.

Scaling up reuse also requires infrastructure to facilitate return logistics. Practical ease of use for the consumer is paramount here (see consumer studies by Mission Reuse and Kantar). Stakeholders must work together to achieve this. The government must facilitate and financially support this, for example with higher costs for disposable products, a tax on disposable products, extended producer responsibility, encouraging reuse, and subsidies for necessary logistical components such as washing facilities.

Deposit is an indispensable instrument for a circular economy

Reuse of both products and raw materials is necessary for the transition to a circular economy. A deposit is the way to achieve a clean collection stream that makes product and raw material reuse possible.

The Rutte III Cabinet decided to introduce a deposit on both bottles and cans. Support for a deposit on these beverage containers is enormous. This political decision was therefore received very positively by society at large. Frequent experiences in other countries prove the important role that deposits play in the transition to the circular economy. It is an ‘easy to implement’ system, low-hanging fruit.

However, we note that the previous cabinet, when implementing the deposit system in the Netherlands, made choices that undermine the effectiveness of the deposit concept and thus undermine the intended environmental gains. Take, for example, the relatively low deposit amount of 0.15 euros, the confusing exception for juice bottles, and the removal of the return obligation for points of sale, which means consumers can get their deposit back in fewer places.

The deposit system stands and falls with consumer participation. But the design of the Dutch deposit system does not make it easy for the consumer to participate in it. Businesses, led by the resisting supermarkets, are further eroding the functioning of deposits. The current plan of the Waste Fund to send consumers to another collection point located outside the supermarket, the so-called "circular hubs", for deposit cans is not the only, but the most recent and most striking example of this.

We call on the current cabinet urgently to safeguard the effective functioning of the deposit concept. Only then will support for this political decision and deposit as an instrument remain intact, and can the Netherlands achieve maximum environmental gains with it.