How policy can reduce single-use plastics and litter

In recent months, the central government prepared regulations to reduce single-use plastics in litter and thus make the Netherlands cleaner. This is part of the implementation of the European directive for single-use plastics that was introduced in the Netherlands this year. For this purpose, the Ministry of Infrastructure and Water Management launched a consultation. Responses to the draft version of the ministerial regulation can be submitted until 6 December 2021. In the run-up to the AO Circular Economy on 18 November, a coalition of environmental organisations is proposing policy suggestions aimed at optimising the approach to litter for a clean Netherlands.

With the introduction of the ministerial regulation (MR), very important steps are being taken in the fight against single-use plastics. Extended Producer Responsibility (EPR) will be introduced for litter, which means that producers will for the first time be obliged to pay for, among other things, the clean-up, processing, and transport of litter. Currently, these costs are still borne by, among others, area managers, including local authorities and therefore the citizen. In addition, there are more and more clean-up initiatives in which thousands of volunteers participate annually. Shifting the costs to producers is a significant development. Below are the main positions of the environmental movement to strengthen the new regulations:

General policy suggestions on extended producer responsibility (EPR) for litter

The introduction of EPR for litter is a good development. We advocate also formulating concrete reduction targets to make the Netherlands (as much as possible) litter-free. Concrete reduction targets are necessary in order to monitor the effective use of resources, concrete results, and impact.

The scope of the scheme is limited to litter that is within the public management area of a government body and is cleaned up by government organisations. However, the question is why only government organisations qualify for reimbursement of such costs, as the draft regulation currently proposes. Our organisations propose that private area managers of publicly accessible areas should also qualify for such reimbursement, such as Natuurmonumenten, Landschappen, and estate owners.

The scope of the ministerial regulation is currently limited to plastic products. However, there are also many other materials that are significantly present in litter and cause environmental problems, such as chewing gum. We propose to include these in the EPR immediately as well. An integrated, material-neutral approach to litter is crucial to prevent producers from shifting to other materials.

An advisory group is needed to evaluate the functioning of the implementation organisation and the implementation of the scheme. This advisory group should consist of a balanced composition of stakeholders with an equal number of representatives from the environmental movement and from the business community.

Improvements for litter monitoring and cost calculation

Rijkswaterstaat is responsible for the National Litter Monitor. Six times a year, measurements are taken of how much and what kind of litter is in the Netherlands. A total of 25,200 measurements are carried out across 1,400 locations. To get a representative picture of the litter problem, we advocate better measurements and more different types of monitoring locations (including roadsides and motorway exits). During the measurement, counting must be done properly, and the litter should also be cleaned up immediately.

Litter monitoring does not have to be limited to the data collected by Rijkswaterstaat. For years, litter measurements by environmental organisations and volunteer activities have provided a wealth of information. We advocate that the following valuable data sources also be included in the monitoring: the Litter Compass by GoClean, Clean Rivers, actions by the Plastic Cigarette Butt Collective, Boskalis Beach Cleanup Tour, Maas Cleanup, World Cleanup Day, data from Litterati, and data collection by private initiatives such as that of Dirk Groot.

In the draft regulation, the government has a central role in determining the costs and reimbursement. We advocate that environmental organisations are involved early and actively in the process, both in the cost study and the litter monitoring. All data on litter monitoring, cost determination, and producer contributions should also be fully public.

Improvements for reduction measures

The draft regulation proposes a partial ban on offering single-use cups and food packaging for on-site consumption. However, there is an exception when the operator uses recyclable cups/food packaging and these are collected separately on-site for "high-quality recycl

In recent months, the central government prepared regulations to reduce single-use plastics in litter and thus make the Netherlands cleaner. This is part of the implementation of the European directive for single-use plastics that was introduced in the Netherlands this year. For this purpose, the Ministry of Infrastructure and Water Management launched a consultation. Responses to the draft version of the ministerial regulation can be submitted until 6 December 2021. In the run-up to the AO Circular Economy on 18 November, a coalition of environmental organisations is proposing policy suggestions aimed at optimising the approach to litter for a clean Netherlands.

With the introduction of the ministerial regulation (MR), very important steps are being taken in the fight against single-use plastics. Extended Producer Responsibility (EPR) will be introduced for litter, which means that producers will for the first time be obliged to pay for, among other things, the clean-up, processing, and transport of litter. Currently, these costs are still borne by, among others, area managers, including local authorities and therefore the citizen. In addition, there are more and more clean-up initiatives in which thousands of volunteers participate annually. Shifting the costs to producers is a significant development. Below are the main positions of the environmental movement to strengthen the new regulations:

General policy suggestions on extended producer responsibility (EPR) for litter

The introduction of EPR for litter is a good development. We advocate also formulating concrete reduction targets to make the Netherlands (as much as possible) litter-free. Concrete reduction targets are necessary in order to monitor the effective use of resources, concrete results, and impact.

The scope of the scheme is limited to litter that is within the public management area of a government body and is cleaned up by government organisations. However, the question is why only government organisations qualify for reimbursement of such costs, as the draft regulation currently proposes. Our organisations propose to also allow private area managers of publicly accessible areas to qualify for such reimbursement, such as Natuurmonumenten, Landschappen, and estate owners.

The scope of the ministerial regulation is currently limited to plastic products. However, there are also many other materials that are significantly present in litter and cause environmental problems, such as chewing gum. We propose to include these in the EPR immediately as well. An integrated, material-neutral approach to litter is crucial to prevent producers from shifting to other materials.

An advisory group is needed to evaluate the functioning of the implementation organisation and the implementation of the scheme. This advisory group should consist of a balanced composition of stakeholders with an equal number of representatives from the environmental movement and from the business community.

Improvements for litter monitoring and cost calculation

Rijkswaterstaat is responsible for the National Litter Monitor. Six times a year, measurements are taken of how much and what kind of litter is in the Netherlands. A total of 25,200 measurements are carried out across 1,400 locations. To get a representative picture of the litter problem, we advocate for better measurements and more different types of monitoring locations (including roadsides and motorway exits). During the measurement, counting must be done properly, and the litter should also be cleaned up immediately.

Litter monitoring does not have to be limited to the data collected by Rijkswaterstaat. For years, litter measurements by environmental organisations and volunteer actions have provided a wealth of information. We advocate that the following valuable data sources also be included in the monitoring: the Litter Compass by GoClean, Clean Rivers, actions by the Plastic Cigarette Butt Collective, Boskalis Beach Cleanup Tour, Maas Cleanup, World Cleanup Day, data from Litterati, and data collection by private initiatives such as that of Dirk Groot.

In the draft regulation, the government has a central role in determining the costs and reimbursement. We advocate that environmental organisations are involved early and actively in the process, both in the cost study and the litter monitoring. All data on litter monitoring, cost determination, and producer contributions should also be fully public.

Improvements for reduction measures

The draft regulation proposes a partial ban on offering single-use cups and food packaging for on-site consumption. However, there is an exception when the operator uses recyclable cups/food packaging and these are collected separately on-site for "high-quality recycling". We advocate for a complete ban on single-use cups and food packaging, without exceptions.

The draft regulation contains a partial obligation for food outlets to offer reusable meal packaging for take-away or delivery consumption. We foresee the risk that operators will limit themselves to allowing reusable packaging brought by consumers themselves (so-called Bring Your Own). As far as we are concerned, the responsibility lies with the operator to set up reuse systems, or to engage an external service provider. Only then will this measure effectively contribute to the national transition to reuse.

It will be prohibited to provide plastic single-use cups and food packaging to consumers free of charge. However, it is up to the provider to determine the level of the amount per cup and food packaging. We advocate a fixed environmental levy of 0.25 euros per single-use cup and 0.50 euros per single-use meal packaging. This avoids a perverse incentive to sell single-use plastic packaging, and the revenue can be invested in reuse systems.

Based on a calculation, the Ministry of Infrastructure and Water Management expects that these measures will result in a reduction of single-use cups and food packaging of approximately 40% in 2026 compared to the year 2022. We believe it is important that instead of a forecast, a binding reduction target is formulated for single-use cups and food packaging. We advocate a target of 50% in 2025 for the share of reusable drinking cups, and 80% in 2030. And a target of 30% in 2025 for the share of reusable meal containers, and 50% in 2030.

It is a good thing that producers have to draft plans for awareness-raising measures and report annually on implementation and effectiveness, but the question is to what extent it is evaluated whether these awareness-raising measures actually contribute to prevention and reduction.

Every year, billions of cigarette butts end up in the environment, which are very difficult to clean up. The clean-up costs for cigarette butts are currently not known to area managers and are also not clearly mapped out with current national efforts. In our view, it is therefore more effective to introduce a ban on plastic cigarette filters. Until that is in place, area managers must invest much more in both mapping the scale of the pollution and cleaning it up than is currently the case. We advocate a reduction target of 70% in 2026 (compared to 2022) with producers as the standard-bearer.

Extended producer responsibility should also be introduced for sanitary products (such as sanitary pads and tampons) to move this sector towards a circular economy as well. Indeed, sanitary pads, tampons (including applicators), and nappies are also single-use plastic products with a significant environmental impact.

The above policy recommendations were formulated by a coalition of environmental organisations, consisting of Recycling Netwerk Benelux, Plastic Soup Foundation, North Sea Foundation, Natuur & Milieu, GoClean, Plastic Cigarette Butt Collective, the Plastic Soup Surfer, and the Zwerfinator. A comprehensive memo with a more detailed analysis of the draft ministerial regulation will be submitted via the internet consultation in early December.

The PDFs of the extensive views we submitted for the internet consultation:

Mission Reuse, From single-use to reuse, View on Ministerial Regulation Single-Use Plastic Products, November 2021

Extended Producer Responsibility for Litter, View on Ministerial Regulation Single-Use Plastics, November 2021