The road to deposits in 2025: time to take the temperature

A year ago, on 6 September 2022, Flemish Minister for the Environment Zuhal Demir said on Tafel van Vier that ‘deposit return is inevitable’. All three regions are now unanimously in favour of launching this system by 2025, but there is still necessary work to be done. In this article, we take stock of where the regions stand on the path towards deposit return in 2025. Which evaluations are currently underway? What about classic deposit return versus digital deposit return? What are essential elements for good regulation and what are the remaining pitfalls on the way to an efficient and consumer-friendly deposit return system? Deposit return on the horizon: green light for 2025 Great progress in the three regions Wallonia, Brussels and Flanders all want to introduce deposit return in 2025, but each has followed a different path to get there: In Wallonia, after numerous parliamentary hearings and the rejection of the alternative reward scheme, Walloon Minister Céline Tellier launched a final feasibility study at the end of 2022 to examine how deposit return can be introduced. On Thursday 13 July, the government confirmed its desire to introduce deposit return and its preference for a "manual" deposit return by 2025, similar to the deposit return system Belgium already has for glass bottles. Consumers must therefore be able to take their bottles and cans to the point of sale. The final report of the study, scheduled for the end of 2023, will highly likely confirm this approach. In Wallonia, the coalition partners (MR, PS and Ecolo) and the opposition (PTB, Les Engagés) are unanimously in favour of a conventional deposit return system. The Brussels-Capital Region remained silent on the subject for a long time. After finally announcing its cooperation with the Walloon feasibility study, Minister for the Environment Alain Maron indicated on Friday 14 July that he would support and follow the Walloon approach. In Flanders, Minister Zuhal Demir was the first to announce, exactly one year ago in September 2022, that a deposit return system was “inevitable” for plastic cans and bottles, and that it would be introduced by 2025. This followed the unsatisfactory results of OVAM's litter monitoring. The sector had to reduce litter in Flanders by 20% between 2015 and 2021. The monitoring showed that the many prevention and clean-up campaigns had not borne fruit. The Belgian developments are therefore in line with development at European level. Based on the draft ‘Packaging and Packaging Waste Regulation’ (PPWR), member states must introduce a deposit return system for plastic cans and bottles by 2029, unless they achieve 90% separate collection for these types of packaging by 2026 and 2027. No country achieves that without deposit return. A measure that has the unanimous support of Belgian citizens Photo credit: LovelyDay12 Deposit return proves to be one of the most popular environmental measures. Since 2021, petitions in favour of deposit return have been signed en masse and have led to parliamentary hearings in Brussels (CCB, March 2021), Wallonia (Régine Florent, May 2021) and Flanders (Canal It Up, October 2022). Support for deposit return is also reflected in public surveys. A survey by GFK in 2018 showed that 82% of Belgians wanted a deposit return on plastic bottles and cans. Support also continues to grow. Where a survey by Testaankoop in 2017 showed 66% support for deposit return, this rose to 74% when Testaankoop held a second survey in 2021. The Deposit Return Alliance (Statiegeldalliantie) cannot be ignored either. Since its foundation in 2017 with just 21 members, the alliance has grown steadily. In 2018, the Alliance already had 500 members and now it has more than 1300 members, including 62% of Belgian cities and municipalities. Things to watch out for on the way to deposit return Although significant progress has been made, a number of areas of concern can also be identified in the implementation of deposit return. First of all, Flanders has not yet taken a final position on the type of deposit return system. At the same time, the business community is lobbying against the introduction of a classic deposit return system. The elections on 9 June 2024 must also not be lost sight of. Flanders' final position expected by the end of 2023 ‘Deposit return system is inevitable’ according to Zuhal Demir (Tafel van Vier, 6 September 2022), but while the other two regions have opted for the ‘classic’ deposit return system, Flanders has yet to decide which type of deposit return system it wants to introduce. Under pressure from the sector, which has been pushing for the introduction of a ‘digital deposit return’ since September 2022, Minister Zuhal Demir has given Fost Plus, Comeos and Fevia until the end of October 2023 to prove the viability of digital deposit return. Flemish deposit return pilots The pilots, organised by Fost Plus and the O

A year ago, on 6 September 2022, Flemish Minister for the Environment Zuhal Demir said on Tafel van Vier that ‘deposit return is inevitable’. All three regions are now unanimously in favour of launching this system by 2025, but there is still necessary work to be done. In this article, we take stock of where the regions stand on the path towards deposit return in 2025. Which evaluations are currently underway? What about classic deposit return versus digital deposit return? What are essential elements for good regulation and what are the remaining pitfalls on the way to an efficient and consumer-friendly deposit return system?

Deposit return on the horizon: green light for 2025

Great progress in the three regions

Wallonia, Brussels and Flanders all want to introduce deposit return in 2025, but each has followed a different path to get there:

In Wallonia, Walloon Minister Céline Tellier, after numerous parliamentary hearings and the rejection of the reward scheme alternative, launched a final feasibility study at the end of 2022 to examine how deposit return can be introduced. On Thursday 13 July, the government confirmed its desire to introduce deposit return and its preference for a “manual” deposit return by 2025, similar to the deposit return system Belgium already has for glass bottles. Consumers must therefore be able to take their bottles and cans to the point of sale. The final report of the study, scheduled for the end of 2023, will highly likely confirm this approach. In Wallonia, the coalition partners (MR, PS and Ecolo) and the opposition (PTB, Les Engagés) are unanimously in favour of a conventional deposit return system.

The Brussels-Capital Region remained silent on the subject for a long time. After finally announcing its cooperation with the Walloon feasibility study, Minister for the Environment Alain Maron indicated on Friday 14 July that he would support and follow the Walloon approach.

In Flanders, Minister Zuhal Demir was the first to announce, exactly one year ago in September 2022, that a deposit return system was “inevitable” for plastic cans and bottles, and that it would be introduced by 2025. This followed the unsatisfactory results of the litter monitoring by OVAM. The sector had to reduce litter in Flanders by 20% between 2015 and 2021. The monitoring showed that the many prevention and clean-up campaigns had not borne fruit.

The Belgian developments are therefore in line with development at European level. Under the draft ‘Packaging and Packaging Waste Regulation’ (PPWR), member states must introduce a deposit return system for plastic cans and bottles by 2029, unless they achieve 90% separate collection for these types of packaging by 2026 and 2027. No country achieves that without deposit return.

A measure that has the unanimous support of Belgian citizens

Photo credit: LovelyDay12

Deposit return proves to be one of the most popular environmental measures. Since 2021, petitions in favour of deposit return have been signed en masse and have led to parliamentary hearings in Brussels (CCB, March 2021), Wallonia (Régine Florent, May 2021) and Flanders (Canal It Up, October 2022). Support for deposit return is also reflected in public surveys. A survey by GFK in 2018 showed that 82% of Belgians wanted a deposit return on plastic bottles and cans.

Support also continues to grow. Where a survey by Testaankoop in 2017 showed 66% support for deposit return, this rose to 74% when Testaankoop held a second survey in 2021. The Deposit Return Alliance (Statiegeldalliantie) cannot be ignored either. Since its foundation in 2017 with just 21 members, the alliance has grown steadily. In 2018, the Alliance already had 500 members and now it has more than 1300 members, including 62% of Belgian cities and municipalities.

Things to watch out for on the way to deposit return

Although significant progress has been made, a number of areas of concern can also be identified in the implementation of deposit return. First of all, Flanders has not yet taken a final position on the type of deposit return system. At the same time, the business community is lobbying against the introduction of a classic deposit return system. The elections on 9 June 2024 must also not be lost sight of.

Flanders' final position expected by end of 2023

‘Deposit return system is inevitable’ according to Zuhal Demir (Tafel van Vier, 6 September 2022), but while the other two regions have opted for the ‘classic’ deposit return system, Flanders has yet to decide which type of deposit return system it wants to introduce. Under pressure from the sector, which has been pushing for the introduction of a ‘digital deposit return’ since September 2022, Minister Zuhal Demir has given Fost Plus, Comeos and Fevia until the end of October 2023 to prove the viability of digital deposit return. Flemish deposit return pilots The pilots, organised by Fost Plus and OVAM, must demonstrate the technical feasibility, effectiveness and accessibility of this alternative system. It must also be demonstrated that alternative systems do not entail disproportionate risks of fraud or loss of privacy. It must also become clear that the system can be fully operational by 2025. If the pilots do not provide that proof, the classic deposit return system will be introduced. The first pilots in a closed environment took place in June to test a number of technical aspects. The last two pilots in semi-closed and open environments, which start in September and must be completed by the end of October, will be the most decisive, as the technical feasibility, accessibility and efficiency of the system have not yet been tested. At the moment, the industry is still far from proving the concept for an effective introduction in 2025. The September pilots actually raised many questions. The feasibility of the system is also still unproven. Timing is getting tighter for the industry and the risk of failure is therefore increasing.

At the political level, the opposition parties Groen and Vooruit are in favour of the classic deposit return system. Within the coalition itself, CD&V is in favour of deposit return and is very sceptical about the industry's digital proposal. The N-VA, the party of the Minister for the Environment, is also in favour of deposit return, but has no position on the preferred system. Open-VLD supports the digital deposit return system.

Most Flemish people, environmental and agricultural organisations and 70% of Flemish cities and municipalities, on the other hand, are in favour of a classic deposit return. The position of cities and municipalities is essential, as they now have to clean up litter from bottles and cans and also play an important role in the digital deposit return scenario. They would be responsible for placing tens of thousands of extra “blue public bins” on their territory and might have to distribute “home scanners” to their citizens (PwC, 2022).

The role of the industry

Photo: Saskia Risseeuw

The Belgian producer and supermarket federations (Fevia, Comeos) have been strongly opposed to deposit return for years, as has Fost Plus, which organises the collection of packaging on behalf of these federations. Only in September 2022, when the Flemish Minister announced that the decision in Flanders was imminent, did these sectors express their support for deposit return.

Fost Plus, as a waste collection organisation on behalf of producers and supermarkets, likes to stick to the blue bag for the collection of plastic bottles and cans and would prefer not to see these valuable materials collected in another way. In addition, the lobby organisation of the supermarkets, Comeos, is particularly opposed to deposit return. One of its members, Colruyt, would prefer not to be responsible for taking back plastic bottles and cans and paying out deposit refunds to their customers due to extra costs and adjustments. In other countries such as the Netherlands and the United Kingdom, the supermarket lobby also plays an important role in holding back the introduction of deposit return.

The federations concerned now propose to introduce a form of ‘digital deposit return’ whereby collection still takes place via the blue bag and via bins in public spaces for packaging consumed on the go. In contrast to the classic ‘Return-to-retail’ deposit return used in almost all European countries, this system remains an idea whose success is far from proven. It raises many questions among politicians, consumer associations and environmental NGOs.

However, the federation of can manufacturers in the Benelux (Beverage Can Benelux) is opposed to digital deposit return. In its position statement, the federation indicates that the unique coding required for digital deposit return is not yet technically possible and it also states that high-quality material recycling can best be guaranteed via classic deposit return.

Because of the major uncertainties surrounding digital deposit return and the importance of introducing a system that is operational and works well in 2025, we have asked consultancy firm Eunomia, specialised in circular economy and waste systems, to evaluate the proposal for digital deposit return. The final report is expected in September-October.

Interregional cooperation needed for a uniform deposit return

Two complementary approaches: Fost Plus accreditation and the ICA packaging

In order to introduce deposit return at national level, an agreement must be found between the three regions. Indeed, Belgian packaging policy largely takes place at the interregional level. There are two types of agreements that are important now:

Fost Plus accreditation

Every five years, a producer responsibility organisation for packaging (in principle Fost Plus for household packaging in Belgium) is accredited as a party to fulfil legal obligations around the collection and sustainability of packaging on behalf of producers. Deposit return naturally plays a role in this.

The renewal of Fost Plus's accreditation at the end of 2023 for a five-year period is an opportunity to anchor the political will to introduce an operational deposit return in 2025. This renewal is granted by the decision-making body of the Interregional Packaging Commission (IVC), composed of members appointed by the three regions (Chapter V, art 23, §3 of the ICA).

Fost Plus had to submit a proposal in June-July (according to the rules of the ICA) on the content of the future accreditation regarding its various future targets in the field of prevention, reuse and recycling, for example with regard to deposit return on plastic cans and bottles. This will allow the IVC to take a decision in December 2023 (ICA Packaging, art. 10, §3).

At present, no information is being shared on the details of the discussions. This is problematic, given the importance of this approval for all Belgian players affected by it: recyclers, intermunicipal waste associations, but also cities and municipalities and citizens. This lack of transparency is all the more problematic given the doubts about the transparency and monopoly position of Fost Plus (Apache, 2021).

Since the accreditation runs for five years, it must align not only with national policy, but also with European ambitions for a circular economy by 2030.

Therefore, there is a need for more transparency and involvement of relevant stakeholders in the renewal of this accreditation.

Photo credit: Frimufilm

Interregional Cooperation Agreement on packaging

The Interregional Cooperation Agreement (ICA) on packaging is the legal basis for packaging policy between the regions. It was drafted in 2008 and last amended in 2020. The IVC monitors compliance with the cooperation agreement, including approval, monitoring and financing of PRO packaging systems (such as Fost Plus).

The ICA also sets specific targets for prevention, collection and recycling in Belgium. It must be adapted for the legal anchoring of deposit return. But the amendment will take more time than the approval process. Relying solely on the ICA Packaging to introduce deposit return runs the risk of delaying the decision, making it harder to reach the target of an operational deposit return in 2025.

Moreover, these two paths complement each other: while the Fost Plus accreditation guides producers for the next five years in terms of prevention, reuse and recycling, the ICA focuses more on the commitments made by the three regions in terms of packaging and packaging waste management. Together, these documents can form the basis of a solid deposit return system in which public and private players plan the direction of their packaging policy.