TOWARDS A BETTER POLICY FOR PACKAGING …...actual collection and recycling figures to devise a...
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TOWARDS A BETTER
POLICY FOR PACKAGING
WASTE IN FLANDERS -
RECOVER (2018)
Contents
Abstract ................................................................................................................................................... 1
Chapter 1: The why, how and who of this report .................................................................................. 3
1 Recover ................................................................................................................................................. 3
2 The members ........................................................................................................................................ 3
3 The researchers .................................................................................................................................... 4
Interafval ............................................................................................................................................. 4
The University of Antwerp .................................................................................................................. 4
Catholic University of Leuven .............................................................................................................. 4
University of Hasselt ............................................................................................................................ 4
KplusV .................................................................................................................................................. 4
Day One ............................................................................................................................................... 5
Arcadis ................................................................................................................................................. 5
VITO ..................................................................................................................................................... 5
City of Antwerp.................................................................................................................................... 5
ACR+ .................................................................................................................................................... 5
Chapter 2: The Flemish waste policy ....................................................................................................... 6
1 The European Packaging Directive ....................................................................................................... 6
2 The Belgian Interregional Cooperation Agreement of 2008 ................................................................ 6
3 Producer responsibility ......................................................................................................................... 8
4 Collection and treatment of packaging waste ..................................................................................... 1
5 Financial compensations for local authorities ...................................................................................... 2
Collection ....................................................................................................................................... 2
Additional financial support .......................................................................................................... 2
Chapter 3: Strengths of the current policy .............................................................................................. 6
1 Legislation contains preventative measures ........................................................................................ 6
2 High level of separate collection .......................................................................................................... 6
3 Strong link with municipal waste management ................................................................................... 7
4 Obligatory legal not-for-profit status for accredited bodies ................................................................ 7
5 Independent enforcement by the IVC .................................................................................................. 8
6 Mooimakers: a joint partnership in the fight against litter .................................................................. 8
Chapter 4: Possible points for improvement of the current policy ........................................................ 9
1 Recycled volume of packaging waste is overestimated ....................................................................... 9
Current reporting .......................................................................................................................... 9
Recycling figures exceeding 100% ............................................................................................... 10
Producers that are not affiliated with Fost Plus .......................................................................... 10
Purchases made abroad .............................................................................................................. 11
Impurities and recycling losses .................................................................................................... 11
Metal packaging from bottom ash .............................................................................................. 12
Corrected collection and recycling figures .................................................................................. 15
Lack of ambitious goals ............................................................................................................... 15
2 Evolve from collection and recycling towards packaging within the philosophy of a circular economy
............................................................................................................................................................... 15
More prevention of packaging waste .......................................................................................... 15
Material loss ................................................................................................................................ 19
Lack of eco-design ....................................................................................................................... 23
Emergence of bioplastics ............................................................................................................. 25
3 Producers are still not responsible for everything they put on the market ....................................... 29
Packaging in the residual waste .................................................................................................. 29
Packaging in litter and fly-tipping ................................................................................................ 30
Costs of local authorities, related to management of packaging waste, are not fully reimbursed
by producers ...................................................................................................................................... 35
4 A difficult sorting instruction for the public ....................................................................................... 37
Quantitative survey shows that people see a “P” and think “plastic” ........................................ 37
Bags containing too much other waste are refused during collection ....................................... 37
Residual waste in the PMD bag ................................................................................................... 38
More and different efforts required for communication ............................................................ 38
Chapter 5: The management of packaging waste in different European countries ............................. 40
1 The Netherlands ................................................................................................................................. 40
Collection of plastic packaging through Plastic Heroes ............................................................... 40
A limited but efficient deposit return system ............................................................................. 40
Emphasis on collection of more plastics ..................................................................................... 41
Freeriders .................................................................................................................................... 41
More emphasis on quantity ........................................................................................................ 41
Actual recycling falls short ........................................................................................................... 42
Eco-design: room for improvement ............................................................................................ 42
Green dot on packaging .............................................................................................................. 43
Industry support for the fight against litter ................................................................................ 43
2 Germany ............................................................................................................................................. 43
Competition between producer responsibility organizations is an issue ................................... 43
Satisfaction with the deposit return system ............................................................................... 44
Ecomodulation ............................................................................................................................ 44
Consumer happy about deposit return system ........................................................................... 44
New packaging legislation from 2019 onwards .......................................................................... 44
3 France ................................................................................................................................................. 45
Unique tariff classification for the green dot contribution ......................................................... 45
4 Denmark ............................................................................................................................................. 47
Tax rules ...................................................................................................................................... 47
Sorting by material ...................................................................................................................... 47
The deposit return system is a huge success .............................................................................. 47
Limited recycling of plastic packaging ......................................................................................... 48
Waste management strategy ...................................................................................................... 48
5 Sweden ............................................................................................................................................... 48
The success of the deposit return system ................................................................................... 48
6 Norway ............................................................................................................................................... 49
High collection results thanks to the deposit return system ...................................................... 49
Uncertainty about the compensation of local authorities .......................................................... 51
Local authorities decide about local collection systems ............................................................. 51
7 Estonia ................................................................................................................................................ 51
Satisfied with the deposit return system .................................................................................... 51
8 Lithuania ............................................................................................................................................. 51
Deposit return system scored well in addition to the existing collection system ...................... 51
9 Canada ................................................................................................................................................ 52
Deposit return system helps reduce amount of litter ................................................................. 52
Chapter 6: Ten recommendations for a better packaging waste policy in Belgium ............................. 53
1 More ambition and higher objectives ................................................................................................ 53
2 More separate collection of packaging .............................................................................................. 54
3 More emphasis on high-quality recycling .......................................................................................... 55
4 Increased research on the impact of packaging ................................................................................. 56
5 Invest more in eco-design .................................................................................................................. 57
6 Full responsibility of producers .......................................................................................................... 57
7 Better map the materials flow ........................................................................................................... 57
Reporting Obligation ................................................................................................................... 57
More monitoring and research ................................................................................................... 58
Transparency ............................................................................................................................... 58
8 Invest more in prevention .................................................................................................................. 59
9 Increase user-friendliness .................................................................................................................. 59
10 Policy should be in the hands of policymakers ................................................................................ 60
Appendix A: Calculation table effective collection and recycling figures ............................................. 61
Appendix B: Prevention within the Interregional Cooperation Agreement and the Packaging Directive
............................................................................................................................................................... 61
Appendix C Results Day One study ........................................................................................................ 64
Appendix D Results count of different fractions in litter, commissioned by Limburg.net .................... 65
Addendum to the report “Towards a better policy for packaging waste in Flanders, Recover (2018)”
............................................................................................................................................................... 67
Figures
Figure 1 Management of household packaging waste in Belgium ......................................................... 8
Figure 2 Producer contribution as a function of the recycling percentages of various European
countries .................................................................................................................................................. 7
Figure 3 Overview of the process for the recovery of aluminium from municipal solid waste
incineration (MSWI) bottom ash and the final recycling of aluminium (footnote 56) ......................... 13
Figure 4: Materials flow of metal packaging in 2015, Flemish Region (Recover, 2018) ....................... 14
Figure 5: Production of packaging waste (in kg/per capita) ................................................................. 16
Figure 6: Tonnes of packaging placed on the market in Belgium 2005-2016 ....................................... 17
Figure 7: Material loss of packaging in Flanders ................................................................................... 20
Figure 8: Applications of recycled PET flakes in Antwerp in 2017 ........................................................ 23
Figure 9: Global production capacity biobased plastics (footnote 94) ................................................. 26
Figure 10: Reported PLA threshold concentrations in the PET stream and their impact (footnote 96)28
Figure 11: Composition of marine litter ................................................................................................ 33
Figure 12: Additional cost when the average of all submitted quotes is compared with the average of
the lowest quotes (%) (Recover, 2018) ................................................................................................. 36
Figure 13: Composition of the PMD bag in the Flemish Region. ........................................................... 38
Figure 14: I sort my packaging waste as much as I can because...(footnote 127) ................................ 39
Figure 15: Net PET content of all the bottles and containers, compared with the total weight of the
sorted PET products for the various collection systems ....................................................................... 41
Figure 16 Sorting and processing of separately collected plastics in the Netherlands (footnote 136) 42
Figure 17 Basic icons in the Weggooiwijzer sorting guide (footnote 140) ............................................ 43
Figure 18: Market share of single-use (light green) and reusable (dark green) packaging and take-back
rates (grey) ............................................................................................................................................ 48
Figure 19: Presentation about the Norwegian environmental tax on beverage packaging, expressed in
Norwegian Krone .................................................................................................................................. 50
Figure 20: Recycling results of the Norwegian deposit return system ................................................ 50
Figure 21: Support for possible alternative measures .......................................................................... 59
1
Abstract
Both Flanders and Belgium have had the highest recycling rate in Europe for several years. And yet, local
authorities have been struggling with the current collection of packaging waste for several years. There is still
too much packaging in litter on the streets and despite all the communication efforts, consumers, after twenty
years, still have difficulties sorting their packaging waste correctly.
The local authorities want to take the lead in the quest for ways to improve the current collection system for
packaging waste in Flanders. That is why eleven Flemish intermunicipal waste organizations and the City of
Antwerp decided to join forces in the Recover partnership. They funded research to devise solutions for the
problems arising from the current policy. Recover commissioned eight studies, analysed the current waste
collection system and formulated ten recommendations for a better policy: 1. More ambition and higher objectives
2. More separate collection of packaging
3. More emphasis on high-quality recycling
4. Increased research on the impact of packaging
5. Invest more in eco-design
6. Full responsibility of producers
7. Better mapping of the materials flow
8. Invest more in prevention
9. Increase user-friendliness
10. Policy should be in the hands of policymakers
You can find out more about the current policy, its strengths and weaknesses and Recover’s policy
recommendations in this report, which is titled ‘Towards a better policy for packaging waste in Flanders’.
2
Both Flanders and Belgium have earned a reputation as having the highest recycling rate in Europe for
packaging waste for several years now. According to the annual report of Fost Plus, the Producer Responsibility
Organization (PRO) for packaging waste, 89.1% of all packaging was recycled in 2017. Despite these positive
figures, too much packaging still finds its way into the residual waste or is littered on the streets. Moreover, the
obligation of separate collection does not apply to all packaging, as a result of which raw materials are lost in
the process. The Flemish local authorities want to take the lead in the quest for improving the current
collection system for packaging waste in Flanders. That is why eleven Flemish intermunicipal waste
organizations and the City of Antwerp decided to join forces in the Recover partnership, investing in solutions
to the problems arising from the current policy. Recover analysed the existing system with eight different sub-
studies and went in search of new policy instruments. The partnership compiled the most important results in
this report and makes specific policy proposals in the last chapter. This report calls for: • The correct and clear reporting of the collection and recycling figures for packaging waste. The
currently reported figures do not necessarily accurately reflect reality or are distorted because
materials that are not packaging are included. The government must therefore base itself on the
actual collection and recycling figures to devise a better policy.
• Development of a producer responsibility system in which full responsibility for all the packaging
placed on the market, including all phases of the packaging’s lifecycle, is assigned to the producer.
• Prevention of litter. Packaging accounts for much of litter and all new policy instruments must help
prevent this.
• The system must be based on a complete internalisation of the costs associated with packaging
waste, including packaging found in residual waste and litter.
• Increase incentives for a circular economy. Producer responsibility must effectively give rise to better
product design and upcycling.
• A better service to citizens and a sorting message that is easy to understand and communicate.
• A system that will allow Belgium to take a leadership position in Europe.
Structure of the report
This report consists of six chapters. Chapter 1 introduces Recover, its members and the eight aforementioned
studies. Chapter 2 examines the current European and Belgian packaging waste legislation and the limits of the
current producer responsibility system. Chapter 3 maps the strengths of the current policy. Chapter 4 lists
suggestions for improvement of the current policy in four themes: collection and recycling, circular economy,
producer responsibility and the communication. Chapter 5 compares current Belgian policy for packaging waste
with that of a number of other countries and highlights good practices. The end report concludes with ten
specific policy recommendations.
3
Chapter 1: The why, how and who of this report 1 Recover
For several years, there have been problems with the current collection system for packaging waste in Belgium.
This prompted eleven Flemish intermunicipal waste organizations described below and the City of Antwerp to
look for ways to improve the policy for packaging waste. They joined forces in the Recover partnership and
provided funding for a number of studies. Recover aims to develop an efficient and increased collection of
packaging waste, as well as improve the citizens’ understanding of the collection system and provide a better
service. In addition, the partnership aims to reduce the fraction of packaging in litter and for increased financial
responsibility from the producers.
2 The members
Recover has 12 members:
• IBOGEM
IBOGEM is the intermunicipal company for sustainable waste management for the region of Beveren, Kruibeke
and Zwijndrecht.
• IDM
The Intercommunale Durme-Moervaart (IDM) intermunicipal company groups the municipalities of Lochristi,
Lokeren, Moerbeke, Wachtebeke, Zele and Zelzate.
• IGEAN
IGEAN serves thirty municipalities in the district of Antwerp.
• IMOG
IMOG is the intermunicipal company for public health in South-West Flanders, operating in Anzegem, Avelgem,
Deerlijk, Harelbeke, Kortrijk, Kuurne, Kruishoutem, Spiere-Helkijn, Waregem, Wielsbeke and Zwevegem.
• IVAGO
IVAGO is the intermunicipal association for waste management in Ghent and the surrounding region.
• IVAREM
The intermunicipal association for sustainable waste management in the region of Mechelen (IVAREM) is a
partnership of eleven municipalities: Berlaar, Bonheiden, Bornem, Duffel, Lier, Mechelen, Puurs, Putte, Sint-
Amands, Sint-Katelijne-Waver and Willebroek.
• IVLA
IVLA is an intermunicipal association for waste management operating in Brakel, Horebeke, Lierde, Maarkedal,
Oudenaarde, Ronse, Wortegem-Petegem, Zingem and Zwalm.
• IVOO
IVOO, the intermunicipal association for Ostend and the surrounding region, is the intermunicipal waste
company for Bredene, Gistel, Ichtegem, Middelkerke, Oostende and Oudenburg.
• IVVO
IVVO, the intermunicipal partnership for waste removal and processing for the region of Veurne, operates in
twelve municipalities: Nieuwpoort, Koksijde, De Panne, Veurne, Diksmuide, Vleteren, Lo-Reninge, Alveringem,
Ieper, Poperinge, Heuvelland and Mesen.
• Limburg.Net
The Limburg.Net intermunicipal waste company is responsible for waste prevention and collection in the 45
municipalities of the province of Limburg and the city of Diest.
• MIWA
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MIWA is the intermunicipal waste company for the Midden-Waasland region, more specifically the
municipalities of Sint-Gillis-Waas, Sint-Niklaas, Stekene, Temse and Waasmunster.
• City of Antwerp
The City of Antwerp has its own collection and street cleaning service. The City Cleaning Department maintains
the city’s public spaces. In practice this means it is responsible for household waste collection, subsoil
collection containers, street sweeping services and recycling centres. The city collaborate with ISVAG (for
incineration), IBOGEM (treatment of garden waste) and IGEAN (for biological treatment of kitchen waste),
which take care of the waste treatment. The city’s recycling of packaging waste is organised by Fost Plus.
3 The researchers
Interafval Recover’s research was commissioned by the aforementioned participating intermunicipal waste organizations
and the City of Antwerp. They chose to detach the appointed project manager to the Waste Policy Team of the
Association of Flemish Cities and Municipalities (VVSG, a not-for-profit association). The team’s tasks includes
the coordination of Interafval, the partnership of the Association of Flemish Cities and Municipalities (VVSG
vzw), all the Flemish intermunicipal waste organizations and other local authorities that are responsible for
local waste policy. This allowed for access to information within this network.
The following research institutions conducted research upon Recover’s request:
The University of Antwerp As part of her Master programme, Roxanne Abels studied the position of the Flemish policy on packaging waste
in relation to the German, French, Norwegian, Danish and Dutch systems. Her goal was to identify international
good practices, which could be used as lessons for the Flemish policy. She combined a literature review with
interviews.
Reference: Abels, R. (2018). Hoe positioneert het huidig Vlaams beleid inzake verpakkingsafval zich binnen de
internationale context? Onuitgegeven eindwerk Master in de Milieuwetenschap. Antwerpen: Universiteit
Antwerpen
Catholic University of Leuven Bachelor students of the Catholic University of Leuven conducted a study on the Flemish material flow of metal
packaging. In order to calculate the share of packaging after incineration, they conducted a sorting experiment
on the bottom ash of one of Indaver’s incinerators.
Reference: De Coster E., Vandenbergh K., De Broyer S., Lambrix N., 2018. Sluiting van de
materiaalverpakkingscyclus. Onuitgegeven eindwerk Bachelor of Science in de industriële wetenschappen:
Industriële ingenieurswetenschappen Chemie. Leuven: KU Leuven, campus Groep T.
University of Hasselt A group of Bachelor students of the University of Hasselt studied the social cost and benefits of packaging
waste. Their goal was to map producer responsibility, and how external costs are (not) internalised.
Reference: Holsteyns J., Van Eesbeek A., Vanschoubroek M., 2018. Zwerfvuil oplossen: naar een optimaal beleid
voor het beheer van verpakkingsafval. Onuitgegeven eindwerk Bachelor Toegepaste Economische
Wetenschappen. Hasselt: Universiteit Hasselt, Faculteit Bedrijfseconomische Wetenschappen
KplusV KplusV assessed the social cost of litter and studied the impact of packaging waste on litter.
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Reference: KplusV, 2018. Maatschappelijke kosten verpakkingen in zwerfvuil in Vlaanderen. Brussel: Recover.
Day One Day One studied citizens’ experiences with the current waste packaging collection system and which ideas and
suggestions they have for improving the system’s organization. To this end, Day One conducted quantitative
and qualitative surveys among 1,000 respondents.
Reference: Day One, 2018. Evaluatie van huidig systeem en inspiratie voor nieuw scenario gescheiden
inzameling verpakkingsafval. Brussel: Recover [PowerPoint].
Arcadis Arcadis drew up a critical analysis of Directive 2004/12/EC and the 2008 Interregional Cooperation Agreement,
to see how the Packaging Directive and the Cooperation Agreement can be renewed, in keeping with the
principles of a circular economy.
Reference: Arcadis, 2018. Milieueffecten van het Samenwerkingsakkoord Verpakkingsafval. Brussel: Recover.
VITO VITO conducted a review of two existing studies that had been commissioned before by the Flemish Public
Waste Agency (a study on the impacts of a deposit system for packaging and a study on the costs and volume
of litter) checking whether they are based on sufficient data and whether all this information could be
combined in one global document that takes all conclusions into account, including possible interactions. VITO
indicated in its analysis which data were lacking to conduct well-documented research.
Reference: VITO, 2018. Review van studies over de waardeketen van huishoudelijke verpakkingen in
Vlaanderen. Brussel: Recover
City of Antwerp The city of Antwerp studied the options for recycling PET in 2017 and 2018. They analysed the current system
for processing PET and the issues associated with recycling in a policy document.
Reference: Sylwia Szwedo-Furmanska, 2018. Studie PET en r-PET. Antwerpen: Stad Antwerpen
ACR+ ACR+ is an international network of cities and regions, that aim to stimulate the sustainable consumption of
raw materials and sustainable waste management. At the end of 2017, ACR+ launched an in-depth study into
the existing deposit return system in ten European countries. The end report is expected to be published by the
end of 2018. Recover exchanged knowledge with the researchers and was able to use some of the provisional
results for its own research.
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Chapter 2: The Flemish waste policy
This chapter maps the current legislation in terms of producer responsibility. It summarises the main elements
of the Packaging Directive and the Belgian Interregional Cooperation Agreement and gives a better idea on how
the current packaging collection system is organised. It draws from the publication ‘Lokaal afvalbeleid, wegwijs
in de reglementering’, which gives an overview of Flemish waste policy and regulations and was published by
the Association of Flemish Cities and Municipalities.
1 The European Packaging Directive
EU Directive 94/62/EC, which came into effect at the end of 1994, aimed to harmonise national legislation for
packaging and packaging waste among the EU Member States. To this end, the Directive obliged Member
States to take measures to ensure that at least 55% of all the packaging placed on the market would be
recycled whereas at least 60% would be recovered or incinerated with energy recovery by no later than 31
December 2008. The minimum recycling percentage for every type of packaging material was 15%. On 11
February 2004, Directive 94/62/EC was replaced with EU Directive 2004/12/EC, which clarified the definition of
packaging by adding interpretation criteria. As Table 1 indicates, the targets for recycling and recovery were
also raised. The EU Member States must recover at least 60% of all packaging waste and must achieve specific
recycling targets for each of the following materials: 60% for glass, paper and cardboard, 50% for metals, 22.5%
for plastics and 15% for wood. Moreover, the Directive requires all packaging to be monitored, reported and
recycled in every EU Member State where the party responsible for the packaging has business operations.
2 The Belgian Interregional Cooperation Agreement of 2008
In Belgium, environmental policy is a competence of the regions. Belgium acts as a federal state, where the
three regions (Flanders, Wallonia and Brussels Capital Region) have an important political autonomy, including
almost full competence on environmental and waste policy. However, legislation allows the regions to agree on
‘shared legislation’. These are very specific topics where the three autonomous regions decide on shared
legislation because of arguments like economic interests or other. Common regulations for the three regions
gave rise to a uniform system for all of Belgium. When the three regional parliaments agree on such shared
legislation, they confirm this by approving “interregional agreements”. This has not happened very often, but is
amongst others the case for the packaging waste legislation. Flanders, Wallonia and Brussels Capital Region
approved a shared implementation of the packaging waste directive within one legal framework.
In 2008, the most recent packaging and packaging waste directive was transposed into Belgian law via the
Interregional Cooperation Agreement on the prevention and management of packaging waste1. The agreement
between the Flemish, Walloon and Brussels-Capital regions sets out the rights and obligations of the legal
persons and the physical persons, which are active in packaging, and took effect on 1 January 2009. The
Interregional Packaging Commission (Interregionale Verpakkingscommissie, IVC)2 monitors this. The
Cooperation Agreement focuses on three obligations3: the general prevention plan, the take-back obligation &
recycling targets and the reporting obligation.
The general prevention plan
1 Replaces the Cooperation Agreement of 30 May 1996 on the prevention and management of packaging waste. 2 The Interregional Packaging Commission is a government body specifically established to monitor Belgian (regional) legislation for packaging waste. It is a joint institution of the Flemish, Walloon and Brussels-Capital regions. 3 IVC. (sd). www.ivcie.be. Taken from http://www.ivcie.be/admin/upload/page/file/380.pdf
7
Companies that place at least 300 tonnes of single-use packaging on the market annually, or which package or
have products packaged in Belgium, must submit a general prevention plan every three years.
The take-back obligation
The take-back obligation requires companies to organize the take-back system as well as to recycle at least 80%
of the household packaging they place on the market. They must at least achieve the following recycling
percentages for the entire Belgian territory for the various packaging materials:
- 60% in weight for glass;
- 60% in weight for paper/cardboard;
- 60% in weight for drinks cartons;
- 50% in weight for metals;
- 30% in weight for plastics, only material that is counted as plastics is recycled;
- 15% in weight for wood.
Table 1 features an overview of recovery and recycling targets.
The reporting obligation
In order to monitor whether companies comply with their legal obligations, they are required to produce
annual reports about the packaging waste they have taken back and the recovery and recycling percentages
they achieved for packaging they place on the market. The parties responsible for packaging must submit these
data to the IVC. By law, Belgian packaging producers must individually comply with their legal recycling
obligations or transfer these to a body that is accredited by the IVC. Article 9 of the Cooperation Agreement
stipulates that the IVC only gives an accreditation to legal persons, which comply with the following conditions:
• founded as a not-for-profit association;
• take on the responsibility for the take-back obligation for its members as its exclusive statutory
objective;
• have sufficient resources to meet the take-back obligation;
• the administrators or persons which legally represent the association must have full civil and political
rights, and must not have been convicted for an infringement of the environmental legislation of the
Regions or any EU Member State.4
To put the take-back obligation for packaging waste into practice, the producers have founded two bodies,
which have been accredited by the IVC. VAL-I-PAC (founded and accredited for the first time in 1997) is
responsible for waste of packages for industrial use5. Fost Plus (voluntarily established by the private sector in
1994 and officially accredited for the first time in 1997) is responsible for waste from packaging for household
purposes. Figure 1 illustrates the management of household packaging waste.
Table 1 Recovery and recycling targets for the various material flows in weight percentages
Recovery
target
Recycling target
Directive total glass metal paper/
cardboard
plastic wood
94/62/EG 50% 25% 15% 15% 15% 15% /
2004/12/EG 60% 55% 60% 50% 60% 22,50% 15%
4 OVAM. (2016). Studie naar de rol van beheersorganismen in de afvalmarkt. Mechelen: OVAM 5 Taken from IVCIE: http://www.ivcie.be
8
Cooperation Agreement 1 6 90% 80% 60% 50% 60% 30% 15%
Cooperation Agreement 27 85% 80% 60% 50% 60% 30% 15%
Figure 1 Management of household packaging waste in Belgium
3 Producer responsibility
In the Nineties, the Swedish professor Thomas Lindqvist described the concept of ‘producer responsibility’ as a
‘strategy that holds the producer responsible for a product’s entire lifecycle with special attention for the take-
back, recycling and the final processing”. The concept was introduced by the OECD and is founded on two
important principles8.
1. The financial and physical responsibility for waste management is passed on from the public, often the
(local) authorities, to the producers.
2. The producers are encouraged to redesign their products, focussing on eco-design and design for
recycling.
The concept of producer responsibility was transposed in a number of European Directives, and evolved
through the years towards what is now commonly described as ‘extended producer responsibility’ or EPR.
Article 21, §1 of the Flemish Materials Decree enshrines the principle of extended producer responsibility in
Flanders. It states:
“To stimulate the prevention, re-use, recycling and other useful applications of waste materials, the
Government of Flanders can take measures to ensure that every natural or legal person, that develops,
manufactures, treats, processes, sells or imports packaging for professional use (the product’s producer) bears
extended producer responsibility.
The measures, which are set out in the first paragraph, can consist of imposing rules and regulations on these
natural and physical persons, as stated in the first paragraph and relate to:
1° holding these parties fully or partly responsible for the organization of the collection of the waste products
arising from the products they placed on the market;
6 Household packaging waste 7 Industrial packaging waste 8 https://www.ovam.be/producentenverantwoordelijkheid-samen-besturen
9
2° obliging them to accept these waste products;
3° holding these parties fully or partly responsible for the ensuing management of these waste products;
4° assigning financial responsibility for the collection and processing of these waste products in accordance with
Article 10 (the ‘polluter pays’ principle);
5° sharing publicly available information about environmentally-sound product use and the extent to which and
how the product can be re-used and recycled.
The measures, set out in the first paragraph, can also include measures that encourage them to design products
in such a way that the environmental effects and the waste output are reduced, both during the production
phase and during the subsequent use of the products, to ensure that the products that have become waste are
recovered and disposed of as set out in Article 4. Such measures can, among others, encourage them to
develop, manufacture and place on the market products that are suited for multiple uses, which are technically
durable and which, as soon as they have become waste, are suited for adequate and safe recycling, for recovery
and for environmentally-sound disposal.”
The (extended) producer responsibility for packaging waste is put into practice in Belgium through the take-
back obligation. It obliges producers to reach a number of targets in terms of recovery and recycling. Producers
of packaging can fulfil these obligations themselves, or can join a shared system like Fost Plus to comply with
the take-back obligation for household packaging waste. The green dot logo on the packaging indicates that the
company is a member of Fost Plus and financially contributes to the seperate collection, sorting and recycling
of its packaging.
Every five years, Fost Plus must renew its accreditation by the Interregional Packaging Commission. The
accreditation sets out the framework for the cooperation between Fost Plus and the municipalities and
intermunicipal organizations. It defines in which collection schemes Fost Plus must compensate the collectors
and sorters directly (instead of the municipality) whereby the real cost must be covered in full. In addition, the
accreditation imposes additional indemnities to local authorities, e.g. for communication or additional efforts.
The membership contribution of Fost Plus, financed by companies that put packaging on the market and rely
on Fost plus to reach the environmental targets, is calculated based on the quantity and types of packaging
they put on the market. Table 2 lists the Fost Plus green dot tariffs for 2016, 2017 and 2018.
Table 2 Green dot tariffs for the various packaging materials (euro/tonne of packaging put on the market)
Material 2016 2017 2018
Glass 23.9 21.4 27.3
Paper /cardboard 18.5 16.9 25.3
Steel 84.8 124.4 151.4
Aluminium 35.3 32.6 44.7
PET/HDPE 147.1 210.7 327.5
Drinks cartons 249.8 245.5 316.4
Other packaging that can be valorised
287.3 282.3 376.6
Other packaging that cannot be valorised
316.1 310.6 414.2
1
4 Collection and treatment of packaging waste
In Belgium, most municipalities are associated to an intermunicipal corporation for implementing their
household waste policy. There are 32 intermunicipal organizations in Belgium - 25 in Flanders and 7 in Wallonia
– to which municipalities have transferred the operational responsibility for the management of household
waste. The Brussels region organizes household waste management through a regional agency (Net Brussel).
Fost Plus cooperates with these intermunicipal organizations and a small number of municipalities that did not
associate to an intermunicipal organization. Fost Plus and its public partners jointly determine the operational
modalities of collection. In this context, the intermunicipal organizations and cities are responsible for the
smooth operation of separate collection in the field, including the organization of collection routes, distribution
of collection calendars, monitoring and control, emptying bottle banks, enforcement of the sorting
instructions,…. This means: if waste is presented containing too many contaminants, the waste is refused for
collection and the household responsible is contacted and asked to remediate. Fost Plus and the intermunicipal
organizations also develop local communication campaigns to promote the correct sorting of waste.
Fost Plus has chosen to implement a collection scheme that is as uniform as possible, for all of Belgium, in
order to achieve a high efficiency for the sorting and recycling of packaging waste. Glass bottles and flasks are
collected through bottle banks. Paper and cardboard packaging can be deposited at civic amenity sites and is
also collected door to door once a month or every four weeks, together with old newspapers and magazines.
Plastic bottles and flasks, metal packaging and drinks cartons (PMD) are usually collected in transparent, light-
blue bags, door to door twice a month, but can also be brought to municipal civic amenity sites.
Some intermunicipal organizations and cities have a different collection system, which may differ in the
collection frequency for PMD, paper and cardboard. Sometimes, glass is collected door to door. This is
currently the case for approximately 20% of the Flemish population. Some municipalities collect additional
plastic packaging. In 2010, IVAREM9 for example set up a separate collection for mixed plastics (bags, film,
butter containers, yoghurt and flower pots…)in a pink bag. Until 2015, this was only collected in civic amenity
sites. In 2015, the town council of Mechelen decided to invest 100,000 euros for a collection of this pink bag
door to door, free of charge, every eight weeks. Since then, a number of other municipalities have followed
suit. IMOG10 preferred a set of recipients for different additional streams of packaging waste on the civic
amenity sites, where plastic packaging, which does not belong in the PMD bag, and other plastics, are
separately collected. Many municipalities are also implementing to waste collection in subsoil containers. In
Flanders, the collection of waste in subsoil containers first started for the collection of glass. In the past years,
subsoil collection has become increasingly common for all fractions collected door to door, especially in
densely populated areas or near high-rise buildings.
After collection, the packaging waste is sorted for recycling. In Flanders packaging waste sorting plants are
rarely owned by the intermunicipal organizations11. Those sign contracts with private sorting companies for this
purpose. The sorting plants sort paper and cardboard in different fractions and glass packaging by colour.
These are separated from impurities. PMD is sorted into various fractions: aluminium, steel, HDPE, PET, drinks
cartons and a residual non-recyclable fraction. After the materials are sorted, they are then transported to
recycling companies and used to substitute primary resources in the manufacturing of new packaging or other
materials. Plastic bottles and flasks are shredded into a granulate which is used in other plastic products. After
glass has been melted, it is given a new shape and use. Metals, separated in ferrous (steel) and non-ferrous
9 Intermunicipal association for sustainable waste management in the region of Mechelen 10 Intermunicipal company for public health in South-West Flanders 11 Except for IMOG
2
(aluminium), are recycled in respective industries. The three material layers of bonded drinks cartons
(cardboard, plastic and aluminium) are separated and then recycled and/or incinerated with energy recovery.
More details on the specific sorting and recycling steps of packaging material can be found in the Recover study
by Arcadis12.
5 Financial compensations for local authorities
Collection Fost Plus finances the separate collection and sorting of packaging waste. Different possibilities are set out in
the accreditation of Fost Plus.
• The full cost principle: Fost Plus directly pays the invoices of the waste collectors and the sorting
centres after approval by the intermunicipal organizations. This only applies to a number of collection
scenarios that are set out in the accreditation of Fost Plus. Also, it requires the intermunicipal
organization to tender out the collection and sorting within the rules of public procurement.
• Reference cost: Fost Plus pays the intermunicipal organization a lump sum for the collected packaging
waste. This lump sum is calculated partly as a variable share (40% of the reference cost is linked to the
collected amount, euro/tonne) and a fixed share (60% linked to the number of inhabitants served).
The lump sum is based on the average cost of the collection as set out in the basic scenarios which are
paid at the real and full cost. This is often the case for municipalities that collect packaging through
collection schemes that are not approved as a base scenario (and often are more expensive).
• Negotiated fees: Mostly the case where intermunicipal organizations do not tender the collection to
the market, but perform this activity with their own staff and trucks. Fost Plus and the intermunicipal
organization then negotiate on a fee, based on the costs on the intermunicipal level.
Additional financial support13 In addition to the financing of collection, sorting and recycling, Fost Plus legally has to provide local authorities
additional financial compensations for several activities, outlined below, as stipulated in its accreditation that is
valid for the years 2014-2018.
Bonus (or penalty) for enforcing the quality of the collected PMD
The sorting instruction for PMD seems to be difficult to understand for the public. Many people have no idea
what exactly is meant by ‘plastic bottles and flasks’ or assume that the P of PMD stands for all plastic packaging
waste. As a result, this fraction often also contains e.g. yoghurt pots and butter containers, plastic bags and
other packaging that does not belong in it, as defined by the Fost Plus scenario. People sometimes also add
other waste streams to the PMD, even when this is not allowed. When the PMD stream is mechanically sorted,
this packaging that is not contained in the sorting instructions and other pollutants are directed to residual
waste. If this residue weighs less than 20% of the total PMD fraction, Fost Plus pays the municipalities and
intermunicipal organizations a so-called incentive bonus.14 This is subject to certain conditions, such as
collecting at least 8 kg of PMD per capita per year and applying specific scenarios15. It is important to note that
some packaging materials are perfectly in line with the sorting instructions for the public, but are also directed
into the residue because they can not be sorted mechanically or recycled. Examples of this are black plastic
flasks for certain laundry detergents, or milk bottles in white PET.
12 Arcadis, 2018. Milieueffecten van het Samenwerkingsakkoord Verpakkingsafval. Brussel: Recover. Hoofdstuk 4: Effectieve recyclage p.79-86 13 Delatter C., Decalf L., Coopman P. (2015). Lokaal afvalbeleid, wegwijs in de reglementering. Brussel: VVSG 14 Art. 17 Accreditation of FOST Plus (2013). 15 Art. 17 Accreditation of FOST Plus (2013).
3
Fost Plus’s accreditation stipulates that the target of maximum 20% contamination can be adapted if this
residue contains more than 2% materials, that are perfectly in line with the sorting instructions, given to the
public.16
The incentive bonus for a low residue is calculated using the following formulas:
- if the PMD residue percentage is less than 10: y = (20 + z - x) * 2.5%;
- if the PMD residue percentage is greater than or equal to 10: y = (20 - x)² * 0.25% + z *2.5%.
whereby x is the PMD residue percentage, y the payout in euros per inhabitant per year, and
z the adjustment factor when the residue fraction is greater than 2%.
However, in cases where municipalities do not take the necessary initiatives to limit contaminants, a penalty is
also applicable. If the residue is higher than 20%, all incurred extra costs for treatment of this surplus residue
(the quantity over 20%) have to be financed by the municipality that collected those waste streams.
Energy recovery through incineration of not separately collected packaging waste
If Fost Plus fails to achieve the recovery targets based on the separately collected quantities, they have the
right to supplement these quantities with additional volumes by paying a lump sum for the collection and
incineration with energy recovery of packaging that is in residual waste from households. The percentage and
presence of packaging in the residual waste is determined by waste analysis.17 The lump sum fees are
60 euros/tonne for collection and 109 euros/tonne for incineration18 and are allocated to the regions based on
their respective populations.19
Cleaning of bottle bank sites or additional cost associated with the door to door collection of glass packaging
waste
Fost Plus pays a fee for the cleaning of litter on bottle bank sites. This is stipulated in the contracts for the
collection of glass from these bottle banks. However, the fee is insufficient to reach an acceptable level of
cleanliness of these sites, and municipalities often have to step up their efforts and additionally clean up litter
and illegally dumped waste at those sites. Municipalities that have a door to door glass collection (and no
bottle banks) do not have this problem. However, they run a more expensive collection system that is not fully
compensated by Fost Plus either. In both cases, municipalities have additional costs for which they receive an
additional, not cost covering compensation.
Every year, Fost Plus pays an additional lump sum fee of 0.11 euros per inhabitant. It is used for:
• Partly compensating the additional costs of monthly door to door collection of glass;
• The densification or improvement of the bottle bank network;
• The additional cleaning of the bottle bank sites, including the removal of litter;
• The premature replacement of bottle banks by better quality bottle banks;
• The acquisition and installation of underground bottle banks;
• Better integration of the bottle banks in the landscape;
• The monitoring and control of the bottle bank sites.
It is up to the (inter)municipalities to decide how this additional fee will exactly be used in consultation with
Fost Plus. Every year, they inform the IVC about the use of these funds in every intermunicipal organization20.
Additional and increased investments in underground bottle banks
Fost Plus is legally bound to develop an action plan in order to increase the number of underground bottle
banks by at least 600 in cooperation with the (inter)municipalities. The cost of the acquisition and installation
16 Art. 17 Accreditation of FOST Plus (2013). 17 Art. 12.§ 1.2 & 3 Accreditation FOST Plus (2013). 18 Art. 12.§ 2 Accreditation FOST Plus (2013). 19 Art. 12.§ 3 Accreditation FOST Plus (2013). 20 Art. 13, § 2 Accreditation FOST Plus (2013).
4
of these additional subsoil bottle banks is to be shared 50/50 between Fost Plus and the (inter)municipalities.
The latter can use the supplementary fee of 0.11 euros per inhabitant as described above for financing its
share.
If the intermunicipal organizations or municipalities choose to do more than was originally set out in the action
plan, they bear the full cost for such investments.21
Compensation for administrative follow-up and use of civic amenity sites
Fost Plus pays the intermunicipal organizations for the operational follow-up, i.e., for dealing with the enquiries
of citizens about the collection of packaging, data collection or the administrative follow-up of the contract
with Fost Plus. The cost for the project follow-up consists of ‘a lump sum fee of 10% of the cost of the selective
door to door collection and collection through bottle banks, excluding the sorting cost’22. Moreover the
municipalities are compensated for the collection of packaging waste in their civic amenity sites. This
compensation amounts to ‘20% of the cost of the transport from the civic amenity site to the sorting plants,
excluding the sorting cost’.23
‘If the (inter)municipality estimates that its costs are higher (...), then it can opt for the pay-out of a higher
percentage based on analytical analysis of its accounting for all of the costs’.24
However, (any) “profit” on the sale of the recipients for the collection of PMD (the plastic blue bags used for
collection) is deducted from the project follow-up cost. This profit is calculated as follows: the price per bag
sold minus 0.15 euros. However, the deduction of this profit from the project follow-up cost can never give rise
to a negative value, which the intermunicipal company would have to pay to Fost Plus in that case.25
Communication
Every year, Fost Plus pays the intermunicipal organizations a lump sum fee of 0.28 euros per inhabitant for
local communication initiatives. The intermunicipal organization and Fost Plus jointly establish a
communication action plan. If the action plan includes specific communication campaigns, the intermunicipal
organization can deploy its own employees for this and ensure they are paid in line with the applicable pay
scales, while always respecting the total budget of the lump sum intervention.26
Metal packaging waste, recovered from bottom ash of waste incinerators
The operators of waste incineration facilities recover the ferrous and non-ferrous fractions found in the ashes
after incineration. These metals also contain residues of metal packaging. Fost Plus pays a lump sum fee of 60
euros/tonne27 for the collection and transport of this packaging waste. According to their accreditation, Fost
Plus can never pay for more weight than the quantities of metal packaging that its members placed on the
market.28
Inflation indexation of lump sum fees
The accreditation also provides for an annual inflation indexation of the additional compensation for the
collection of glass and for communication.29
21 Art. 13, § 1 Accreditation FOST Plus (2013). 22 Art. 14 § 1 Accreditation FOST Plus (2013). 23 Art. 14 § 1 Accreditation FOST Plus (2013). 24 Art. 14 § 2 Accreditation FOST Plus (2013). 25 Art. 15 Accreditation of FOST Plus (2013). 26 Art. 16 Accreditation of FOST Plus (2013). 27 Art. 18 Accreditation of FOST Plus (2013). 28 Art. 4 Accreditation of FOST Plus (2013). 29 Art. 22 Accreditation of FOST Plus (2013).
5
Collection of packaging waste of non-household users
In addition to collection organised by the municipalities and intermunicipal companies with Fost Plus, the latter
must also promote the collection of PMD from companies and from out of home consumption. PMD from out
of home consumption includes “the collection in schools, sports centres, youth movements, at festivals, events,
in public spaces and other places that are open to the public including train and metro stations as well as
airports”30. Fost Plus pays 200 euros/tonne for this collection, excluding residue. Since 2015, this amount has
decreased annually by 20 euros. The payment per tonne may not exceed the actual cost however. Fost Plus
may request invoices from non-household users before it pays. Fost Plus pays 188 euros for the sorting of every
tonne of sorted materials for recovery.31
Financial contribution for litter policy
Every year, Fost Plus must pay 0,5 euros per inhabitant (subject to indexation) to the regional authorities. The
regions can use these funds, as they see it, for the prevention of packaging waste, for reducing the amount of
packaging in litter, research for improving the recyclability of packaging, better results and more qualitative
selective collection and finally for the financing of the non-selective collection and processing of packaging
waste.32 On 18 January 2016, the Flemish Region and a number of representative business organizations signed
an agreement on a shared litter strategy. The industry has consented to increasing its financial contribution to
litter policy to 9,6 million euros annually. The local authorities were not involved in the negotiations for this
deal.
30 Art. 43 Accreditation of FOST Plus (2013). 31 Art. 43 Accreditation of FOST Plus (2013). 32 Art. 13, § 1, 12° Cooperation agreement regarding the prevention and management of Packaging Waste.
6
Chapter 3: Strengths of the current policy
In this chapter, the strengths of the current policy are mapped, based on document research. A selection of the
available literature and government documents was made, distilling the main points, which contributed to the
success of the current policy. A first success factor is the mix of policy measures for packaging waste. For this
we refer to the current legislation. Flanders owes its leadership position for separate collection of packaging
waste in part to the intermunicipal cooperations and the link of packaging waste management with measures
taken for better household waste management in general. The positive approach of a collective organization
for producer responsibility and the establishment of an independent enforcement body were equally crucial for
the current policy’s success. Then it is explained how Mooimakers, a partnership assisting local authorities in
their fight against litter, operates.
1 Legislation contains preventative measures
Various measures help to prevent the production of packaging waste in Belgium. According to the 2008
Interregional Cooperation Agreement, parties responsible for packaging must submit a general prevention plan
to the Interregional Packaging Commission every three years. The plan sets out the measures to be taken and
the quantified targets for:
• The increase in the amount of recyclable packaging in relation to the amount of non-recyclable
packaging;
• The increase in the amount of reusable packaging in relation to the amount of single-use packaging;
• The improvement of the physical properties and characteristics of packaging to ensure they can
withstand various movements or rotations, under normal conditions of use or can be recycled;
• The improvement of the physical characteristics and the chemical composition of the packaging with a
view to reducing the harmful nature of the materials it contains, and the reduction of their
environmental impact when managing packaging waste;
• The reduction of the amount of single-use packaging.
The plans are not linked to legally binding targets. However, their sheer existence helps to create more
awareness within companies that put packaging on the market.
2 High level of separate collection
Belgium is the European leader for the separate collection of packaging waste. Compared with other European
countries, Belgium is able to report high recycling figures in recent years. Moreover these results are achieved
with comparably low green dot contributions (Figure 2). On average, Belgians pay 7.9 euros a year for the
separate collection of packaging waste, which is less than in many other European countries. Figure 2 also
indicates the amount of packaging which the affiliated producers placed on the market in the various
countries33. The differences are largely due to the differences in the systems of producer responsibility. France
and Germany, for example, only have one system for packaging waste, while Belgium has separate systems for
household and industrial packaging waste respectively, applying the European targets on both streams
separately.
33 European Commission – DG Environment (2014). Development of Guidance on Extended Producer Responsibility (EPR)
7
Figure 2 Producer contribution as a function of the recycling percentages of various European countries
3 Strong link with municipal waste management
The role of the local authorities is crucial for the success of waste management (and packaging waste
especially) in Belgium and Flanders. The approach of the Flemish intermunicipal organizations is cited as an
example of a good practice in the Global Waste Management Outlook of the United Nations Environment
Programme34. The fact that the intermunicipal organization or municipality is responsible for collecting
packaging waste offers several advantages according to them. An understanding of the local circumstances and
the involvement of the municipalities, among others, facilitates an integrated approach35. Every intermunicipal
organization decides which solution is the most adequate depending on the local circumstances. Moreover,
waste collection is seen as a shared goal. Unlike commercial companies, intermunicipal organizations are seen
as long-term thinkers and public service providers. This explains why the industry sees them as reliable waste
collection partners. Ultimately the success of the packaging waste management system also depends on the
public’s participation. Municipalities are close to the citizen, which is why they are key players in a coordinated
and successful communication strategy. For many years, the local governments have been able to rely on the
good sorting behaviour of the Flemish public. The 2017 monitor of the municipalities and cities36 demonstrates
that the Flemish public is very satisfied with the organized service and the local household waste disposal
facilities.
4 Obligatory legal not-for-profit status for accredited bodies
The accredited producer responsibility organizations like Fost plus and Valipac must, by law, choose for a not-
for-profit legal status. This fundamentally changes their role. There is no interest for investors to associate to
such an organization just for the profit of it. Environmental fees on products can only be used to organize the
collection service and finance the recycling.
34 Wilson, D. C., Rodic, L., Modak, P., Soos, R., Carpintero, A., Velis, C., Iyer, M. & Simonett, O. (2015). Global waste management outlook. UNEP. 35 VVSG, Ambities voor reductie restafval verdubbeld. 9 June 2016 at http://www.vvsg.be/nieuws/Paginas/Nieuw-plan-voor-huishoudelijk-afval-verdubbelt-ambities-reductie-restafval-.aspx 36 The monitor of municipalities and cities is published by the Agency for Local and Provincial Government and describes the evolutions in 13 Flemish cities.
8
5 Independent enforcement by the IVC
The Interregional Packaging Commission (Interregionale Verpakkingscommissie, IVC) is the common institution
for all three Belgian regions, which oversees compliance with the Interregional Cooperation Agreement. It has
various missions. It recognises producer responsibility bodies and controls their functioning. If necessary, the
IVC can suspend or revoke their accreditation. It evaluates the prevention plans and approves them. The IVC
also oversees the way in which the certified bodies comply with the legal obligations for the recycling and
recovery of packaging waste and ensure that the submitted data are correct. It also verifies compliance with
the reporting obligation and the provisions of the Interregional Cooperation Agreement. In view of the
different interests of the organizations involved, it is crucial that this commission remains independent.
6 Mooimakers: a joint partnership in the fight against litter
Mooimakers is the Flemish partnership of the Flemish Public Waste Agency ( Openbare Vlaamse
Afvalstoffenmaatschappij, OVAM), Fost Plus and the Association of Flemish Cities and Municipalities
(Vereniging van Vlaamse Steden en Gemeenten vzw, VVSG). Mooimakers provides support to the local
authorities in the fight against litter by organising campaigns, knowledge sharing, tailored guidance, grants and
research. In 2016, the representative organizations of the distribution and food industry invested 9,6 million
euros in this partnership. Some of their activities are listed below.
• Coaching projects for municipalities, intermunicipal organizations and Flemish institutions to reinforce
the local litter and fly-tipping policy, with intensive and individual coaching.
• Financial support and assistance to local governments for their litter and fly-tipping project(s).
• Project ‘Enforcement Week’ (Week van de handhaving): large-scale communication campaign and
support to the local governments with a scenario, information sessions and training to police litterers
and fly-tippers.
• Support for one-off campaigns during which volunteers or organizations collect litter. The support can
be provided in various ways, i.e. through communication (e.g. the Flemish spring cleaning campaign),
material (cleaning material) or financial support.
• A lump sum fee of 500 euros for municipalities for four measurements with the cleanliness
barometer, a dedicated tool for mapping public cleanliness37.
• Pilot projects to study e.g. the use of surveillance cameras to catch litterbugs; ashtray tiles; the litter
strategy along trunk roads.
• Research into the quantity and cost of litter and fly-tipping.
• ‘Operation clean’ (Operatie proper), a reward-based system for schools, groups and associations,
which help fight litter in a structural manner.
• Comprehensive company-wide projects with which Mooimakers provides support to every company
in the Flemish Region to help increase public cleanliness and put their commitments into practice.
37 IVAGO developed the cleanliness barometer. OVAM decided to include the instruments in its policy after a pilot project.
9
Chapter 4: Possible points for improvement of the current policy
Chapter 4 examines the problems local authorities encounter when collecting packaging waste. The current
policy is re-evaluated based on the results of the various sub-studies that were commissioned by Recover and
compared with relevant scientific literature. In addition to this, in November 2017 Recover sent a survey to the
stakeholders to enquire about their views on the collection of packaging waste. The main conclusions have
been grouped in four themes.
The first theme relates to the collection and recycling of packaging waste. It is claimed hereby that current
reporting on recycling is incorrect. The calculations contain errors leading to an overestimation of recycling
results. Evaluation of policy requires reliable figures. Recover partnered with the Catholic University of Leuven
to determine realistic collection figures for metal packaging in particular. The reported figures are adjusted
based on these results and on scientific literature to determine more accurate collection and recycling
percentages.
In the second theme, it is examined whether Belgium can evolve towards a circular economy with the current
policy. It is concluded that many raw materials are lost due to the lack of prevention, inadequate collection and
low-quality recycling. Furthermore, proposed solutions, such as bioplastics, which are often regarded as
innovative, can endanger recycling.
How far does producer responsibility currently extend and are the local governments receiving sufficient
support? This is the third theme. The local governments find it obvious that producers should be fully
responsible for all of their packaging, even though this is not currently the case from a legal standpoint. Based
on official documents, it can be determined where packaging evades separate collection. It is further observed
that the share of packaging in litter is relatively high and the social cost thereof is examined in a sub-study.
The fourth theme is on the sorting instructions for the public. Some of the separate collection schemes of
packaging waste still achieve less than satisfactory results. Plastic packaging waste in particular often ends up in
the wrong bin or is littered. The aforementioned survey examines the main problems associated with the
current sorting instruction and aims to assess what motivates households to sort their packaging waste.
1 Recycled volume of packaging waste is overestimated
Belgium uses the data reported by Fost Plus as its recycling results for household packaging waste, although
these are calculated based on the quantities collected and sorted and not on what actually is recycled. The
calculation uses the weight of the separately collected (or sorted) packaging waste as a numerator and the
amount of packaging materials that Fost Plus members placed on the market as a denominator. As a result, the
reporting contains various errors. Recover intends to give a correct idea of the actual packaging waste currently
collected and recycled based on literature and an experimental study.
Current reporting The recycling targets are calculated with a simple formula: the numerator is the amount of collected and sorted
material, while the denominator is the amount of material that was placed on the market. The result is used in
reports to the EU about whether Belgium achieves its targets in keeping with the Packaging and Packaging
Waste Directive and to check whether Fost Plus and Valipac fulfil their obligations in terms of producer
responsibility.
According to Fost Plus, Belgium recycled 682,516 tonnes of household packaging waste in 2015, which amounts
to a recycling percentage of 86.3%38.39 This result is the total of all the collection results across all packaging,
38 Fost Plus, 2017 Annual Report 39 In 2017, Belgians recycled 698,314 tonnes of household packaging waste, which corresponds with a recycling percentage of 89.1 %
10
i.e., metal, glass, paper and cardboard and plastic. Glass and paper/cardboard account for the largest share by
weight (50% and 28% each) and have a high recycling percentage. As a result, these fractions have an
important impact on the overall result (which is also calculated on the basis of the weight). Moreover, more
glass (the heaviest fraction) is collected than what the members of Fost Plus put on the market, which
increases the result even more (see Chapter 1.3 and 1.4). It is interesting to take a look at the results for the
different waste streams separately:
Glass
Every year, Fost Plus exceeds the recycling targets for glass. This can be partly explained by imports from other
countries. In 201540, Fost Plus reported a recycling result of 343,589 tonnes of glass packaging, which
corresponds with a recycling percentage of 111.8% compared to what their members put on the market.
Paper and cardboard
In 2015, 163,807 tonnes of paper and cardboard from packaging and 16,688 tonnes from drinks cartons were
recycled according to Fost Plus. Resulting in a recycling rate of 94.1%.
Metals
The annual report of Fost Plus states that a total of 77,057 tonnes of metal packaging was recycled in 2015,
resulting in a recycling rate of 102.5%. These figures include metal packaging from scrap metal recovered from
the bottom ash of incinerators for household waste41.
Plastic bottles and flasks
Currently, from the plastics fraction, only plastic bottles and flasks are collected through PMD bags. These
bottles and flasks are mainly produced from PET or HDPE. In 2015, 81,344 tonnes of bottles and containers
were recycled. Fost Plus reported a recycling rate of 38.4% for plastic packaging.
Recycling figures exceeding 100% Recycling figures of more than 100% are technically impossible. The IVC does not accept amounts that are
greater than the amounts reported to the accredited body by its members and thus always corrects the Fost
Plus figures to a maximum of 100%. This adjustment is inadequate, as data are available for a more accurate
adjustment. OVAM’s 42 household waste analysis shows that household waste contains 1.92% glass packaging.
According to regional statistics, a total of 110.34 kg of household waste per capita was collected in 2015. This
includes 2.12 kg of glass packaging per inhabitant. For a population of 6,437,680, this amounts to 13,638
tonnes of non-separately-collected glass or 4.2% of the glass that was placed on the market in 2015. Meaning
this glass is not recycled, thereby implying that the recycling figure of 100% is incorrect. For glass in particular,
it is worth noting that non-packaging glass and refillable glass bottles also may end up in the bottle banks.
These glass streams are included in the recycling figures for single-use glass packaging.
Producers that are not affiliated with Fost Plus Freeriders are companies that neither collect nor recycle the packaging they place on the market, nor do they
report it to the accredited body. Their packaging is collected through the separate waste streams and is
consequently added to the recycling figures. Freeriders are mainly small companies. Estimates indicate that
there are numerous freeriders across Europe. A study from 200543 referred to 10 to 50% in various European
producer responsibility44 systems. According to the study, this is largely due to a lack of control procedures for
40 Fost Plus, 2015 Annual Report 41 32,932 tonnes 42 OVAM (2015). Sorteeranalyse-onderzoek huisvuil 2013-2014. Mechelen: OVAM 43 EEA (2005). Effectiveness of Packaging Waste Management Systems in Selected Countries: a European Environment Agency Pilot Study. Copenhagen: EEA 44 Extended Producer Responsibility
11
checking the reported sales volumes. Other companies do not fall under the reporting obligations due to small
volumes of packaging placed on the market.45
In addition to the packaging reported by its members, Fost Plus makes an assessment of the market for each
type of material. In 2015, approximately 8% of the packaging on the Belgian market was placed on it by
producers that were not registered with Fost Plus. Currently policy-makers do not regard enforcement of
registration as a priority. Table 3 lists the share of the freeriders in 2015 by material.
Table 3: estimate of the share of companies that are not affiliated with Fost Plus in 201546
Material Market (Estimate) 2015
(tonnes)
Fost Plus
members 2015
(tonnes)
Freeriders (%)
Paper and cardboard 216,441 191,711 11.4
-Paper and cardboard 197,551 173,186 12.3
-Drinks cartons 18,890 18,524 1.9
Glass 326,052 307,230 5.8
Plastic 230,021 211,807 7.9
-Bottles and containers 88,761 85,897 3.2
Metals 78,790 75,172 4.6
Other 5,129 4,610 10.1
total 856,433 790,530 7.7
Purchases made abroad In addition to this, Belgian consumers purchase 5 to 10% of all packaging in neighbouring countries. The
opposite also occurs (people purchasing goods in Belgium) but to a lesser extent. According to Fevia, the
federation of the Belgian food industry, border purchases increased by almost 8% in 201647. All this packaging
is however collected under the Fost Plus system and added to the denominator in the calculation of the
recycled fraction. Implying that for the correct calculation of separate collection, the denominator should also
be corrected for cross-border purchases when estimating the packaging that is placed on the market48.
Impurities and recycling losses The tonnages of packaging placed on the market, as reported by Fost Plus members, are based on dry
packaging materials. The reported weight of separately collected packaging waste however also contains
residues, moisture and liquids. This additional waste is also registered as separately collected packaging waste.
This residue is extracted during the recycling process.
In the Netherlands, the average material yield49 for PET bottles is between 73 and 77% (WUR)50. In addition to
this, further material losses occur during the actual recycling process. Various studies have demonstrated the
often significant differences between collected and recycled material. A study by Eunomia (2018) concluded
that the recycling figure for plastic packaging in the UK is between 23 and 29% in reality, rather than the
45 If the party responsible for the packaging places less than 300 kg of packaging waste on the market annually, i.e., household and industrial packaging waste combined, they are not required to adhere to the take-back obligation. 46 Fost Plus (2017). 2016 Annual Report 47 https://www.fevia.be/nl/standpunten/fevia-standpunt-rond-belastingen-en-heffingen 48 Recover used an underestimate of 5% for foreign purchases to calculate the effective collection and recycling results. 49 Yield in terms of recovered mass: kg of dry and clean output/kg wet and dirty input. 50 Van Velzen, T., Bos-Brouwers, H., Groot, J., Bing, X., Jansen, M., & Luijsterburg, B. (2013). Scenarios study on post-consumer plastic packaging waste recycling. Wageningen UR Food & Biobased Research. Table 12, p.45.
12
reported figure of 39%. EXPRA51 analysed the average losses during the sorting and recycling process using data
provided by its members, including Belgium52. This showed that the recycling losses are most important for
plastics, namely 29%. A study53 by Plastic Recyclers Europe (PRE) lists recycling losses of 27% for PET, which is
consistent with the figures reported by EXPRA (Table 4). There is less information available in literature about
the sorting and recycling losses for the remaining packaging materials. Recover based itself on the figures in the
EXPRA report for the adjustment of recycling losses.
Table 4: Sorting and recycling losses for various materials, based on existing studies
Sorting loss Recycling loss
EXPRA (2014) WUR (2013) PRE (2014) EXPRA (2014)
Paper and
cardboard
4%
10%
Glass 8%
5%
Plastic 25% 23-27% 27% 29%
Metals 5%
14%
Metal packaging from bottom ash Approximately half of the metal packaging that is placed on the market is collected separately in PMD bags54. A
large share of metal packaging ends up in the residual waste, is disposed of as litter or finds its way into the
bins on the streets, after which it is disposed of. Metals however can be recovered for further recycling from
the bottom ash after incineration. According to Article 4 of the accreditation of Fost Plus, part of this recovered
scrap metal may be counted as recycled metal packaging. The maximum threshold for this waste fraction is
calculated as follows:
𝑡𝑜𝑛𝑛𝑒𝑏𝑜𝑡𝑡𝑜𝑚 𝑎𝑠ℎ=(𝑡𝑜𝑛𝑛𝑒𝑚𝑒𝑡𝑎𝑙 𝑝𝑎𝑐𝑘𝑎𝑔𝑖𝑛𝑔 𝑝𝑙𝑎𝑐𝑒𝑑 𝐵𝑒𝑙𝑔𝑖𝑎𝑛 𝑚𝑎𝑟𝑘𝑒𝑡 − 𝑡𝑜𝑛𝑚𝑒𝑡𝑎𝑙 𝑝𝑎𝑐𝑘𝑎𝑔𝑖𝑛𝑔 𝑐𝑜𝑙𝑙𝑒𝑐𝑡𝑒𝑑(𝑃𝑀𝐷 + 𝑎𝑟𝑡8)) ∗ 0,95
For the Flemish Region in 2015 for instance, Fost Plus was allowed to count 18,933 tonnes of metal from scrap
metal recovered from incinerators as recycled packaging waste. In reality, packaging waste only accounts for
part of this tonnage. Moreover, this seems to ignore that there are material losses for metal during an
incineration process. Part of the material is incinerated and oxidised, causing it to be lost for further recycling.
This particularly applies to aluminium packaging. An Italian study showed that 10 to 15% of denser aluminium
materials (tins) oxidise. This figure increases to approximately 60% for thinner materials (film)55. Claassens56
studied the CO2 emissions of aluminium recycling from bottom ash for his master’s thesis. He concluded that
only 32% of the aluminium that passes through an incinerator is effectively recycled. His study further reveals
that a large part of the recovered aluminium is not extracted from the bottom ash in incinerators. The material
51 Extended Producer Responsibility Alliance, an umbrella organisation of organisations that coordinate the collection and processing of packaging waste and recycling. 52 EXPRA (2014). The effects of the proposed EU packaging waste policy on waste management practice: a feasibility study 53 Hestin, M., Faninger, T., & Milios, L. (2015). Increased EU plastics recycling targets: Environmental, economic and social impact assessment. Table 6, page 16. 54 In 2015, 45,297 tonnes of metal packaging were placed on the Flemish market, 25,639 tonnes of metal packaging were collected. 55 Biganzoli, G. N. (2012). Volatilisation and oxidation of aluminium scraps fed into incineration furnaces. Waste management(32). 56 Claassens, H.J.P. (2015). CO2 emissions in the recovery and recycling of aluminium from MSWI bottom ash.
13
losses during incineration are relatively low for steel packaging (2-13%). Figure 3 illustrates the process of
aluminium recovery from bottom ash including the final recycling of aluminium into products.
Figure 3 Overview of the process for the recovery of aluminium from municipal solid waste incineration (MSWI) bottom ash and the final recycling of aluminium (footnote 56)
For a more accurate calculation of the corrected recycling percentage of metal packaging, De Coster et al.
(2018)57, upon request of Recover, conducted a sorting experiment using the bottom ash of an incinerator. To
determine the total ferrous and non-ferrous streams of packaging in bottom ash, the recycling percentages
were recalculated to take into account the limited recognisability of metal packaging (best case scenario) and
possible aluminium losses. The study indicated that there was a total of 34,074 tonnes of metals in the ash,
which in the best case scenario contained 3,727 tonnes of packaging. Thus only 7.6% of the metals in the
bottom ash are actually packaging materials. Consequently, the corrected recycling percentage of metal
packaging would be 64.83% at most. When the researchers adjusted the figure for aluminium losses during the
incineration process, they arrived at a total of 4,092 tonnes and a recycling percentage of 65.64%. Figure 4
indicates the materials flow of metal packaging in the Flemish Region.
Table 1: Corrected recycling results for metal, taking into account packaging recovered from bottom ashes from waste incinerators
Experimental Best case scenario Best case + Aluminium
losses
Ferrous 74.38% 78.17% 78.17%
Non-ferrous 43.84% - 44.74%
Total metal packaging 62.29% 64.83% 65.64%
57 De Coster E., Vandenbergh K., De Broyer S., Lambrix N., 2018. Sluiting van de materiaalverpakkingscyclus. Onuitgegeven eindwerk Bachelor of Science in de industriële wetenschappen: Industriële ingenieurswetenschappen Chemie. Leuven: KU Leuven, campus Groep T.
14
Figure 4: Materials flow of metal packaging in 2015, Flemish Region (Recover, 2018)
15
Corrected collection and recycling figures The adjustment of the reported figures numerator and the denominator in the calculation of the recycled
quantities, using the above data, yields very different recycling rates for the Flemish Region than what is
officially reported today58:
Table 2: Corrected recycling rates for packaging waste in Flanders for 2015
Material
Packaging put on the
Flemish market 2015
estimate includes cross
border purchases (5%)
(tonnes)
Collected
in Flanders
(tonnes)
Collection
rate
Recycling
losses
Recycling
rate
Paper and cardboard 130654 103767 79.4% 10% 71.5%
Paper and cardboard 119252 94173 79.0% 10% 71.1%
Drinks cartons 11403 9594 84.1% 10% 75.7%
Glass 196821 197531 100% 5% 95.3%
Plastic 138852 46765 33.7% 29% 23.9%
Bottles and flasks 53581 37904 70.7% 29% 50.2%
Metals 47562 29366 61.7% 14% 53.1%
Other 3096 18 0.6% 0.6%
Lack of ambitious goals The Interregional Cooperation Agreement suggests a minimum recycling target for each packaging material.
Recover concludes that the suggested targets are already being achieved if not exceeded. Arguing that imposed
recycling targets which are easily reached or below the already achieved rates, sends the wrong message to
parties responsible for packaging.
2 Evolve from collection and recycling towards packaging within the philosophy of a circular economy
More prevention of packaging waste59 Waste prevention is the most important element to achieve a circular economy. Prevention relates to the
reduction of the amount of waste (quantitative prevention) and the reduction of the harmfulness of waste
products for the environment (qualitative prevention). The European Packaging and Packaging Waste Directive
and the Interregional Cooperation Agreement contain elements that refer to quantitative as well as qualitative
prevention measures. The reduction of pollutants in packaging material is a federal competence in Belgium, as
part of product standardisation. Based on Appendix B of this paper complying the various prevention measures
included in the Interregional Cooperation Agreement and the Packaging Directive (including the revision on 18
April 2018), Recover draws the following conclusions:
58 For the calculation see Appendix A 59 Arcadis, 2018. Milieueffecten van het Samenwerkingsakkoord Verpakkingsafval. Brussel: Recover.
16
The total amount of packaging put on the market has not decreased
The Belgian production of packaging waste per capita is approximately the same as the European average,
which did not post a significant reduction either (Figure 5)60. The amount of packaging that is placed on the
market is even increasing (Figure 6). The Day One survey61 revealed that 64% of all respondents find that a lot
of packaging is unnecessary. The current prevention measures do not seem to decrease the production of
packaging waste. Recover does not exclude that current measures have the potential to stop or slow down
growth in combination with other factors. The Packaging and Packaging Waste Directive and the legislation on
product standardisation require packaging to be limited to the absolute minimum, while complying with
regulations in terms of safety, hygiene and consumer acceptance. The packaging weight, however, has dropped
substantially in the past years. In the past fifteen years, producers used 25% less raw materials to produce the
same number of bottles, but the amount of bottles has increased substantially over time. When comparing the
amount of packaging with the amount of packaged products in plastic packaging under two litres, then the
reduction becomes obvious. The amount of bottle packaging, however, has increased faster over time than the
amount of drinks that are consumed. This can be explained by consumer demand for smaller bottles.
Figure 5: Production of packaging waste (in kg/per capita) 62
60 The figures relate to Belgium and the EU-28 and are collected in the Eurostat database. The quality of Eurostat figures is not always consistent, which requires some vigilance when interpreting them. 61 Day One, 2018. Evaluatie van huidig systeem en inspiratie voor nieuw scenario gescheiden inzameling verpakkingsafval. [PowerPoint]. Brussel: Recover 62 Eurostat
17
Figure 6: Tonnes of packaging placed on the market in Belgium 2005-2016
Single-use packaging
In the past fifteen years, reusable glass packaging has dropped by more than 200,000 tonnes or 20%. In weight
terms, producers market the same amount of reusable household packaging and single-use packaging. Glass
makes up a large part of this. According to Comeos63 and Fevia, trade must respond to consumer demand,
which is why producers choose single-use packaging, following the preference of the consumers. According to
Fevia, reusable packaging is not an option for many food products64.
Recycled content in packaging is currently limited
Producers are not incentivized enough to use recycled material in the production of packaging. The Coca-Cola
Company may be used as an example to illustrate this. In 1993, the drinks manufacturer launched its first,
partly-recycled bottles. They were produced from 25% recycled PET. Coca-Cola had already launched similar
bottles in the USA (1991), the United Kingdom (1992) and Australia (1993)65. The share of the brand’s current
PET bottles remained at 25% recycled material66 instead of increasing. The glass bottles and metal cans only
contain 36% recycled material although it is technically possible to have cans as well as PET bottles with higher
recycled materials content.
Recover asked various stakeholders why they do not consider using more recycled material. Comeos and Fevia
indicated that there are various barriers:
• Price - the low cost of virgin plastic means recycled plastic is economically not an interesting option.
• Quality – Recycled material can contain impurities. Producers prefer a colourless end product for
some plastic products (e.g. PET bottles). Unlike recycled material, the quality of virgin plastics is
63 The federation of commerce and services 64 From a survey by Recover, sent in November 2017 65 “Coca-Cola pakt uit met gerecycleerde PET-flessen in Brussel”, De Tijd, October 16, 1993 66 https://nl.cocacolabelgium.be/packages/grondstoffen-hergebruiken
18
constant. They do not contain any impurities. Producers often mix recyclates with virgin material to
maintain the desired level of quality.
• REACH legislation – Uncertainty about the possible presence of SVHC67 components in certain waste
streams.
• Availability of the material – The amount of good quality recycled material is limited due to the
possible presence of pollutants. The quality and quantity can only be guaranteed for a limited number
of recyclates, such as rPET for example.
Packaging waste or food waste: a dilemma
According to the food industry, packaging is needed to guarantee food safety and avoid food waste. It claims
the benefits of the prevention of packaging must be weighed against food loss. However, this seems like a
questionable argument when the entire product chain is taken into account. A lot of product loss already
occurs in production and distribution. Furthermore, a important losses happen in-store, precisely because the
packaging facilitates another approach to stock management. In developed countries such as Belgium, the
main contributor for food waste is the fact that food often simply is not sold68. Retailers prefer filled shelves
over a stock based on turnover. This means that products are always presented in excessive amounts to the
consumer, giving rise to food surpluses69. It is argued that less available products result in a loss of turnover,
because retailers simply do not sell enough or lose consumers who switch to shops with a wider range of
products. This sales mentality is facilitated by the sales price. If a product is sold at twice the purchase price, it
is more profitable to have surpluses (of which some goes to waste) than to miss out on product sales70. The
availability of one and the same product from several brands leads to an even higher surplus of unsold
products.
Thus it is argued that packaging may often rather be a marketing and communication instrument, designed to
generate more sales, and not to prevent food waste. Shops also highlight the convenience of products. Selling
pre-cut vegetables and fruit that require additional and arguably redundant plastic packaging is not in any way
related to the fight against food waste.
Redundant food packaging
According to the calculations of the research department of the Flemish Green Party “Groen”, Belgians use 1.1
billion plastic bags every year71. Supermarkets can reduce this waste mountain by gradually phasing out the use
of plastic bags for fruit and vegetables. According to Comeos, a number of retailers are currently testing
reusable bags for fruit and vegetables. In November 2017, Carrefour launched a pilot project with reusable
outer packaging. Customers could bring reusable bags and containers to the shops to package the products
they purchased from the butcher’s, the fish and the deli counters. In addition to this, the supermarket also
offered reusable textile bags for fruit and vegetables72. An example of redundant outer packaging is that of
products that are sold in bulk, in order to make consumers buy larger quantities. Comeos aims to increase the
share of reusable secondary and tertiary packaging among its members. It strives to achieve a ratio of
reusable/single-use packaging of 87.5/12.573.
67 Substance of Very High Concern. 68 Monier, V., Mudgal, S., Escalon, V., O’Connor, C., Gibon, T., Anderson, G.,... & Morton, G. (2010). Preparatory study on food waste across EU 27. European Commission (DG ENV) Directorate C-Industry, 210. 69 OVAM. (2012). Voedselverlies in ketenperspectief. Mechelen: OVAM. 70 Stuart, T. (2009). Waste. Uncovering the Global Food Scandal. London: Penguin Books. 71 https://www.groen.be/groen_vraagt_vlaams_verbod_op_plastic_zakjes_fw72n6xvx4urxwzikrgm7g 72 http://www.gondola.be/nl/news/food-retail/carrefour-test-twee-alternatieven-voor-plastic-zakken 73 From a Recover survey, conducted in November 2017.
19
Material loss
Cumulative material in use after various rotation cycles
To measure a product’s contribution to the circular economy, its consecutive recycling cycles must be
examined as well. The increasing material losses of the various types of packaging materials can be mapped
based on the effective collection and recycling figures. Figure 7 gives an overview of the various material
evolutions of packaging. These charts show the amount of original material, which is still available for recycling
after various recycling cycles. In the case of plastic bottles and flasks, only 6.4% of the original material is still
available in the fourth recycling cycle. Packaging has a very short life span, meaning they go through a large
number of lifecycles in a short time frame. Single-use packaging has a particularly limited lifespan. Once they
arrive in the consumer’s hands, they are soon disposed of as waste. As a result, the materials are lost much
faster, meaning not much material is left after a short time. If the turnaround time of a metal can for drinks is
just two months74, then only 4.8% of the initial material will be left at the end of the year, i.e., after six
rotations.
74 Hypothesis in OVAM. (2015). Impactanalyse invoering statiegeld op eenmalige drankverpakkingen. Mechelen: OVAM.
20
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Paper and cardboard
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Glass
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Plastic bottles and flasks
in use total collection loss total recycling loss
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Metal packaging
Figure 7: Material loss of packaging in Flanders
21
Material loss due to low-grade recycling applications
In Flanders, most packaging waste is largely recycled into low-grade applications (mainly non-packaging)
meaning new raw materials are constantly required to produce new packaging. Moreover, newly designed
packaging is increasingly difficult to recycle or cannot be recycled at all. This is in opposition to the principle of
the circular economy, in which raw materials remain in the economy as long as possible. The (extended)
producer responsibility mainly focuses on quantitative recycling targets. The end uses are not or barely
assessed. To determine the quality of the current recycling process, Recover commissioned Arcadis to conduct
a market survey of the current recycling technology and applications75. Various limitations are discussed in the
following.
Paper and cardboard
Generally speaking, the higher the quality and the purity of the waste stream, the better the fibre quality. The
fibres however, are damaged during the recycling process, meaning they become increasingly shorter during
the consecutive recycling cycles. Depending on the type of fibre used and the end use, they can be recycled five
to seven times. When the quality of the fibres has significantly decreased after various recycling cycles, new
fibres must be added. Thus, the global material cycle of paper packaging is not a closed loop, as new fibres
must continuously be introduced. Some producers argue that the cycle may be regarded as being closed, if the
organic raw materials are renewable. The paper industry thus often contributes to reforestation. But the loss of
biodiversity due to the planting of particular plants for industrial use and the environmental effects of the
production process and transport must also be taken into account. In any event, maximized recycling of paper
and cardboard continues to be very important in order to reduce the impact of this material on the
environment.
Plastic
The production of plastic packaging relies on petroleum. The recycling of plastic packaging can thus reduce the
amount of petroleum used. Moreover, recycling requires less energy than the production of new plastic
packaging. Recycling thus helps to reduce greenhouse gas emissions, such as CO2. The recycling applications of
plastics heavily depend on the quality of the material. The rule of thumb is that the purer the material and its
flow, the higher the chances of high-quality recycling. Currently an insufficient amount of plastic packaging is
recycled to a high-quality standard. There are various reasons for this:
• There are too many different types of plastics on the market. Mixed materials flows often do not mix
well or are not compatible. Consequently they are often incinerated or used for low-grade
applications, resulting in a loss of raw materials.
• The waste streams of some plastics are often too dirty for high-quality recycling, especially for use in
the food industry.
Metal packaging
If no collection and process losses occur, steel and aluminium can in principle be recycled an infinite number of
times, without loss of quality. They both have a high market value.
Drinks cartons
Drinks cartons are made from cardboard, PE and a thin layer of aluminium. These three components are
separated and are individually recycled and/or recovered. The paper fibres are used for other paper
applications than drinks cartons. As a result only new wood fibres are used for the production of drinks cartons.
75 Arcadis, 2018. Milieueffecten van het Samenwerkingsakkoord Verpakkingsafval. Brussel: Recover.
22
This is therefore a case of downcycling. A second limitation is the layer of aluminium. The material cannot be
fully recovered because the layer is so thin76.
Glass
A pure stream of collected glass can be processed into products with the same application, without any loss of
quality.
General conclusions
Arcadis concluded that the current recycling process is of low quality for the most frequently used packaging
(Table 5).
Table 5: Evaluation of the recycling process for various packaging materials
Material Processing Evaluation
Paper and
cardboard
Recover fibres and use them for
other paper products
Downcycling after a number of cycles
PMD, plastic
bottles and flasks
Sorting, granulating, processing
into various applications
Often downcycling, except for bottle to bottle
recycling
PMD, metal
packaging
Scrap processing Recycling
PMD, drinks
cartons
Separate cardboard fraction,
incinerate aluminium and plastic
residue, cardboard recycling
Downcycling
Plastic film Sort, granulate, process into film Recycling and downcycling
Mixed plastic Granulate, process into more low-
grade applications
Downcycling
Biodegradable
plastic
Compost or incinerate Downcycling or energy recovery
Glass Purify, crush, melt Recycling
Corks Grind and use Downcycling
Wood packaging Chipboard industry Recycling
EPS Extrude and grind Downcycling
Within Flanders, only the City of Antwerp has exact figures on recycling applications77. In 2017, only 5.18% of all
PET bottles were processed as bottle to bottle (Figure 8). The rest was processed as low-grade applications:
textile fibres, insulation materials or food packaging (trays,...).
76 The aluminium layer is so thin that it combusts rather than melts in incinerators. 77 The figures of the City of Antwerp were reported in the city council
23
Figure 8: Applications of recycled PET flakes in Antwerp in 2017
Material loss due to high-quality applications of another product type
Recycled packaging materials are often used in applications that are different from the original product.
Recycled HDPE containers are often recycled as storage containers, waste bins, pipes or cables. It has been
argued that the recycling of packaging into other high-quality applications also closes loops. Moreover, in many
cases, the material also spends more time in the loop (short lifespan packaging vs. long lifespan of other
products). We consequently often accumulate our recycled materials in capital goods such as cars or
computers. But in the meantime we also require raw materials for new packaging and consequently lose
material. As long as we continue to accumulate these raw materials in other products with a different lifespan,
we are unable to ensure a closed loop.
Lack of eco-design The ecologically responsible design of products or eco-design is an important aspect of the circular economy.
According to sorting companies, packaging is becoming more complex and contains different materials,
complicating the sorting and recycling process78. Various studies demonstrate that much unrecyclable
packaging is still placed on the market. A study by Wageningen University & Research79 showed that only 28%
of the packaging on the Dutch market is recyclable. An additional 6% can in theory be recycled into applications
such as consumer articles. But other packaging is considered disruptive for more circular applications80. PET
trays can currently still not be recycled. They are collected separately, but a recycling market must still be
developed for them.
In early April 2018, Go4Circle, the federation of the Belgian waste management industry, announced that 16%
of the waste that ends up in the PMD bag cannot be recycled, based on a study commissioned by the federal
government81. According to Go4Circle, designers do not consider recyclability, but give priority to marketing
and user-friendliness instead. Some packaging contains parts which even high-technological sorting machines
do not recognise. In a circular economy, the emphasis is on sortability and recyclability of course. Various
product design issues complicate sorting and recycling.
78 From a Recover survey, sent in November 2017. 79 Brouwer, M. T., & van Velzen, E. T. (2017). Recyclebaarheid van verpakkingen op de Nederlandse markt (No. 1782). Wageningen Food & Biobased Research. 80 Such as coloured PET bottles and PP film. 81 Go4Circle, Studie Technische, technologische en economische belemmeringen voor de terugwinning van onderdelen en de recyclage van producten in België, Taakomschrijving DG5/PP/NDS/17012, Ontwerp-eindverslag over de belangrijkste afvalstroom: PMD.
24
Trend towards lighter packaging
Some producers make their packaging increasingly thinner to save on raw materials, energy and costs, often
forgetting the recycling phase in the process. The light weight increases the relative moisture content in the
bale. In addition, thinner flakes are lost more easily during the recycling process. Since 2011, the average yield
of PET recycling has dropped from 73% to 68%82.
Use of different material layers in plastic packaging83
Plastics present more problems than other packaging materials during the recycling process due to the large
array of plastics and their compositions. Metal and glass packaging, for example, can mainly be transformed
into the same products. Drinks cartons, made form cardboard (75%), plastic (21%) and aluminium (4%) can be
recycled at the end of their lifecycle as well.
Plastic packaging however, can contain different types of plastics, which, when combined, are not easily
recycled. These plastics must therefore first be separated. In some packaging however, it is impossible to
separate the different types of polymers from each other. The combination of the layers and the nature of the
materials complicate the sorting process and ultimately decrease the quality of the recycled material. A good
example is potato crisps packaging, i.e., plastic packaging with a layer of aluminium. There currently is no
sorting process for this. In 2016, the Netherlands even contemplated to completely ban this type of packaging,
because they complicate efficient sorting for the public. The food industry often uses food trays that are made
from different layers of plastics, such as polyethylene terephthalate (PET) and polyethylene (PE). They are
bonded with each other and are therefore recycled together. When you try to mechanically mix PET and PE in
the melting phase to produce a new recyclate, the outcome is a non-mixable blend. Consequently, every year
700,000 tonnes of PET trays are not recycled but incinerated84.
Opaque and coloured PET
In recent years, a trend has emerged towards opaque PET. The usual packaging for milk drinks, HDPE bottles
and Tetra Brik cartons, are increasingly replaced with white, opaque PET. The advantage of opaque PET is that
it is lighter and cheaper than HDPE and water and energy is saved during its production85. And yet these
products are questionable in a circular economy. The colour or characteristics of the opacifiers can disrupt the
recycling process of transparent PET packaging for example. According to the SRP86 the share of opaque PET in
the PET stream may not exceed 10% as a higher percentage would break down the materials that are used to
make PET opaque, i.e., the fibres. The pigments of opaque PET also influence the colour of recycled PET87 by
turning it grey. The packaging therefore often ends up in the residue. Hence, the French minister for the
environment argued in favour of banning this packaging in 201788.
In the case of coloured PET the rule of thumb is, the more homogeneous the colour of the waste stream, the
greater the quantities and the easier it is to recycle as processing companies can always rely on a sufficient
product supply. It is almost impossible to produce transparent plastic from coloured recycled products.
82 Sylwia Szwedo-Furmanska, 2018. Studie PET en r-PET. Antwerpen: Stad Antwerpen. 83 Technische, technologische en economische belemmeringen voor de terugwinning van onderdelen en de recyclage van producten in België - Ontwerp-eindverslag over de belangrijkste afvalstroom: PMD. 84 Van Damme, N. (2016a). Algemene presentatie: Recyctray. Gent: Universiteit Gent 85 Technische, technologische en economische belemmeringen voor de terugwinning van onderdelen en de recyclage van producten in België - Ontwerp-eindverslag over de belangrijkste afvalstroom: PMD. 86 Syndicat des Régénérateurs Plastiques. 87 Factsheet - Opaque PET bottles and recycling https://www.usi.nl/uploads/media/5a044e65e6009/factsheetkivd.pdf 88 http://www.journaldelenvironnement.net/article/pet-opaque-le-coup-de-gueule-de-segolene-royal,79047
25
Coloured PET bottles can therefore not be used for bottle to bottle recycling. They are currently recycled as e.g.
black packaging trays89.
Black packaging
Producers often use black packaging, especially in the case of plastic and glass, to protect a product against
light. They add black carbon to the packaging. It is estimated that black carbon90 is used in 1.5 to 2 weight
percent of all packaging. This causes problems for the waste industry, as the infrared cameras of the traditional
optical sorting installations cannot detect the colour. When sorting PMD, black plastic packaging often ends up
in the residue.
Sleeve
Sleeves are often used to make products more appealing and to better protect them. They can increase the
recyclability of plastic packaging, because e.g. no glue or colour pigments need to be added to PET or HDPE
bottles. But sleeves create problems during the sorting process as well. The combination of bottles and
containers with sleeves in particular is a problem as the sleeve often fully covers the bottle. As a result, the
optical sorting machine does not recognise the material the bottle is made of. The sleeve can also affect the
quality of the recycled material. A PVC sleeve around a PET bottle, for example, can cause the plastic to turn
dark brown during recycling. 10% of PVC is sufficient to make the recycled product unusable. In addition, it is
difficult to visually and mechanically separate PVC from PET. The materials have a comparable density: during
the flotation phase, both plastics sink, making it impossible to separate them during this phase. Fortunately,
the use of PVC in packaging has dropped substantially, although the number of sleeves is steadily growing91.
Emergence of bioplastics92 A growing number of companies suggest bioplastics as a sustainable alternative to plastic packaging. They
constitute just a small share of the global plastic packaging market, but expectations are that the share of
bioplastics will experience strong growth (Figure 9). In 2017, the total production of bioplastics amounted to
2.05 million tonnes. The Nova Institute estimates that this will increase to 2.44 million tonnes by 202293.
89 Brouwer, M. T., & van Velzen, E. T. (2017). Recyclebaarheid van verpakkingen op de Nederlandse markt (No. 1782). Wageningen Food & Biobased Research. 90 OVAM (2018). Discussiepaper OVAM: Knelpuntenanalyse van de kunststofketen (2017). Mechelen: OVAM 91 Preventpack, dossier “De recyclage van plastic flessen en flacons”. 92 https://www.ovam.be/sites/default/files/atoms/files/Discussiepaper.pdf 93 Nova-Institute. European Bioplastics. 2016. Available online: http://www.european-bioplastics.org/market/
26
Figure 9: Global production capacity biobased plastics (footnote 94)
Confusing for consumers
Bioplastics still cause confusion among consumers. Often the terms biobased, compostable and biodegradable
are seen as interchangeable, even though they each mean something different. Biobased plastics are made
from renewable biomass but essentially are the same molecules as those produced from fossil sources. Other
polymers like polylactic acid (PLA), are compostable or biodegradable. However, compostable plastics only
degrade in an industrial composting plant because they must be processed at sufficiently high temperatures.
The term biodegradable refers to the degradation in a natural environment. Most “bioplastics” are not
biodegradable. They can only be recycled in the same way as ordinary plastics. Bio-PE for example is produced
from sugar cane but has the same chemical characteristics as PE from petroleum and hence cannot be
composted.
The world’s supply of renewable resources is not inexhaustible
According to some, plastic packaging made from renewable sources (biobased) are more sustainable than
plastics made from fossil fuels. The CO2 emissions that are released during the incineration or composting of
bioplastics is compensated by the CO2 absorption while the plant grows. This varies strongly however and
depends on the type of biomass that is used and where the crop is grown. The production of plastic from
biomass can be less efficient than that from fossil raw materials. Some bioplastics require more raw materials
per kg of plastic produced, compared to others. A study by the Worcester Polytechnic Institute (WPI)94 yielded
some interesting results about the food supply of PLA ( a thermoplastic polymer made from lactic acid). To
produce PLA, 147% of biomass is needed in relation to the amount of plastic produced. In plastics from fossil
raw materials, the weight ratio is approximately one to one. If American plastics manufacturers switched to
94 Momani, B. (2009). Assessment of the Impacts of Bioplastics: energy Usage. Fossil Fuel Usage, Pollution, Health Effects, Effects on The Food Supply, and Economic Effects Compared to Petroleum Based Plastics, Worchester Polytechnic Institute, United States.
27
PLA, this would require approximately 24.3% of the global rice or maize supplies, or 49.5% of the global
sugarcane supply. These rough estimates give an indication of the order of magnitude of the acreage required
in case of a large-scale switch to biobased plastics.
In addition to this, external effects associated with the production of these raw materials must also be
examined. Palm oil for example is the most efficient crop in terms of land use and CO2 emissions, but this also
results in deforestation. Often the production of bioplastics causes a lack of biodiversity, potential
deforestation, land use changes, soil adaptation due to erosion, the planting of genetically selected or modified
high yield crops, water consumption, the use of fertiliser and pesticides, etc. Moreover, the supply of
renewable resources is not endless. Thus bioplastics are made from agricultural by-products. But the ‘waste’
from agriculture or the food industry can also be used to maintain or improve the soil structure and the fertility
of the soil. As Flanders only has a limited supply of biomass, due to its limited crops, this forces people to make
choices: which share is used to improve the soil, which for bioplastics?
Biodegradable plastics disrupt the recycling process
According to several waste processors, biobased plastics do not impact the recycling process. The
biodegradable ones, however, can potentially disrupt the recycling process. According to Go4Circle, these
plastics decrease the quality of recyclates. An example are recycled films, which are mixed with virgin plastics,
for film-based products. If the recyclate is also made from biodegradable film, there could potentially be a
quality issue with the end products, causing them to tear more easily. Another example are the biodegradable
flower pots. Eco-oh! mentions that many herbs are being sold in biodegradable flower pots95. If these are
mixed with plastics intended for recycling, the quality of the recyclate is diminished as a result. The recycling
companies claim that biodegradable plastics should only be used in applications where mixing them with
plastics intended to be recycled is impossible. Luc Alaerts et al. (2018)96 examined the impact of PLA on the PET
recycling process. They estimated that the PLA contamination in household waste currently amounts to
approximately 0.09-0.6% for PET bottles and 3-7% for other packaging. Given the growing bioplastics market,
the contamination rate may increase to 0.1 and even 0.8% by 2021 for PET bottles and 4-8% for other
packaging. Figure 10 gives an overview of the various concentrations of PLA contamination in PET and its
impact on the recycling process.
The PLA’s physical material characteristics97 are different from those of PET, meaning a contamination rate
above 0.1% can cause the recyclate to become opaque and yellow. Above 2%, additional problems might arise
during the drying of the flakes, as the PLA’s lower melting point causes the PLA fragments to become sticky and
accumulate, damaging the drying plant. Consequently, biodegradable plastics must be separated as much as
possible. Manual sorting of PLA is impossible, as there is no visual difference between PET and PLA plastics. NIR
spectroscopy achieves a sorting efficiency of 90%. Installing an additional sorting installation to reduce
contamination levels is expensive and may give rise to a larger stream of rejected PET bottles. One possible
solution could be the installation of sorting instructions or digital markers on all the packaging. In any event,
the recycling cost will increase as a result. For PLA all evidence points to the fact that its presence, even in small
quantities, is detrimental to the quality of rPET, especially in bottle to bottle applications. That is why it is highly
95 In a Recover survey from November 2017. 96 Alaerts, L., Augustinus, M., & Van Acker, K. (2018). Impact of Bio-Based Plastics on Current Recycling of Plastics. Sustainability, 10(5), 1487. 97 PLA and PET are physically different, because of their glass transition temperature, melting temperature.
28
recommended that the contamination level be maintained under 0.1%.
Figure 10: Reported PLA threshold concentrations in the PET stream and their impact (footnote 96)
Source of microplastics
Compostable plastics only break down in an industrial composting plant, because it requires high
temperatures. The degradation process in a composting plant is questionable. A bioplastic must undergo a
number of test procedures before it is given a label. The question remains to which extent these tests succeed
in representing all the environmental effects. The laboratory setting of these tests are different from the
circumstances in an industrial composting installation. As a result, there is no guarantee that these plastics will
indeed break down fully. The digestibility of the fragmented bioplastics is not tested for example. These
microplastics end up in fields and pastures, and may cause damage when consumed by animals. Bioplastics also
often contain additives to improve certain material characteristics. To this end, toxicity tests are conducted on
the compost produced from bioplastic products. But the degradation products of the bioplastics and the
additives can accumulate in nature or reach the groundwater. Such concentrations are potentially dangerous.
The biodegradable plastics that end up directly in the environment, such as biodegradable agricultural film,
which is ploughed over after use, raise even more concerns98.
No solution for litter
Bioplastics do not seem an adequate solution for litter and the so-called ‘plastic soup’. This is largely due to the
fact that currently only a quarter of all bioplastics is biologically compostable. These compostable plastics often
require an industrial environment with high temperatures to be able to compost. Biodegradable plastics do not
break down completely when the environmental conditions are not optimal, thus still contributing to the litter
issue.
98 Interview with Karine Van Doorsselaer.
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3 Producers are still not responsible for everything they put on the market
Packaging in the residual waste A lot of recyclable packaging still ends up in household bin bags. In 2013, the Flemish public waste agency
OVAM99 analysed the various different fractions in household waste of a representative sample of 2,000
households. The study showed that packaging waste accounts for 27% of residual household waste on average,
23.43% of which is recyclable (Table 6). The residual waste bag contains packaging that is not separately
collected: 4.98% of which could be collected in the PMD bag, 4.5% in the paper and cardboard and 1.92% in the
glass stream.
The sorting analyses show that the household waste fraction still contains too much recyclable packaging
waste.
Table 6: Composition of household waste 2013-2014 in the Flemish Region
Material Weight%
Packaging 26.96% Paper and cardboard - recyclable 4.55%
Paper and cardboard - non-recyclable 3.53%
Glass 1.92%
Metals 0.95%
Plastic bottles and flasks 2.71%
Plastic film 4.12%
Residual plastics 3.49%
Inert materials 1.91%
Wood 1.21%
Drinks cartons 1.32%
Mixed and residual packaging 1.25%
Non-packaging 73.04%
Producers currently are not being held responsible for the collection and processing of packaging that finds its
way into household residual waste. In 2015, a total of 915,646 tonnes of household residual waste100 was
collected in Flanders, i.e. 141.35 kg per capita. The household waste in Flanders that is collected door to door
(including 2.09 kg/capita sorting residue of PMD waste) amounted to 112.43 kg/capita. In 2015, the cost for
processing household residual waste101 was estimated to be 0.14 euros/kg. The collection cost for household
waste can vary substantially, between municipalities, according to Interafval. Currently it stands at 85-95 euros
per tonnes on average. Today, producers pay a fee for the separate collection and recycling of waste. If
municipalities and intermunicipal companies were to hold producers accountable for the packaging that ends
up in the household residual waste, municipalities would be able to save 6.69 euros per capita102 on collection
and processing cost alone.
99 OVAM. (2015). Sorteeranalyse-onderzoek huisvuil 2013-2014. Mechelen: OVAM. 100 This comprises household waste from door to door collections (including the sorting residue of PMD waste), bulky waste that is collected door to door and at the recycling centre and waste from public spaces. 101 OVAM (2008). Uitvoeringsplan Milieuverantwoord Beheer van Huishoudelijke Afvalstoffen. Mechelen: OVAM. 102 Calculation method: average weight of the household residual waste (110.34kg/capita)*share of packaging (26.96%)*(collection cost (€0.085/kg)+incineration cost (€0.14/kg).
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Packaging in litter and fly-tipping
Social cost of litter in Flanders
Recent research by the Flemish public waste agency OVAM103 helped map the total cost of the Flemish litter
clean-up policy. The study establishes the most realistic estimate of the amount of litter that was collected in
the public spaces of Flanders within one year. It estimates that the total cost in 2015 was 164 million euros104,
or 25.7 euros per capita. The local authorities bear 95% of the cost for the clean-up and processing of litter and
fly-tipping.
OVAM’s study exclusively relates to the current policy cost and does not give a comprehensive idea of the total
litter cost. The cost would be much higher for perfectly clean streets. A study by KplusV, commissioned by
Recover105, indicates that litter has a very wide impact. From the known plastic pollution of our oceans or
physical injuries to animals, to an impact on the increase in crime and a reduction in overall well-being. Litter is
also associated with indirect costs. It causes public irritation and also has a detrimental effect on the
environment and nature. The loss of materials of packaging waste in litter must also be taken into account. The
recyclable fraction of litter ultimately also ends up in the incinerator, rather than being recycled.
Materials of packaging that are lost due to littering
The share of packaging in litter is quite high. A waste analysis of litter was conducted at the request of
Limburg.net106. This showed that the total weight share of packaging in litter was 57% and the share in volume
69.9%. The packaging from public waste bins should be added to these numbers107, which can be counted as
‘avoided litter’. Public waste bins are often used by inhabitants to dump household waste. This represents 45%
of the volume of waste collected in public bins. Therefore, 55% of the contents can be counted as avoided
litter108. The total quantity of packaging materials in cleaned up and avoided litter amounts to 13.9 kilotonnes
every year for Flanders alone. In terms of volume, this represents a material loss of 204,585m³. KplusV
calculated that the cost of this lost material, and of lost social income, is approximately 7.3 million euros a year
for Flanders109.
Livestock deaths
A recent study110 calculates the damage that farmers suffer due to litter, causing injuries and deaths of
livestock, the associated reduction of milk production and the cost of veterinary treatments. Every year in
Flanders, 5,152-6,227 of a national total of 1.3 million cows fall ill due to litter. The annual average cost for
Flanders is in ranges from 4.5 to 6.8 million euros annually.111
Cost of litter in ports
The Flemish integrated action plan for marine litter112 proposes various targets and measures to avoid or limit
marine litter by 2050. It also makes a financial assessment for the period 2018-2025, arriving at a figure in the
range of 2.47 to 3.97 million euros, or an average cost of 353,000 to 567,000 euros a year. The new measures
103 OVAM (2018). Onderzoek naar de hoeveelheden en de beleidskosten van zwerfvuil in Vlaanderen. Mechelen: OVAM. 104 Including the cost associated with emptying public garbage bins. 105 KplusV (2018). Maatschappelijke kosten verpakkingen in zwerfvuil in Vlaanderen. Brussel: Recover. 106 Der Linden (2018). Rapport Samenstelling zwerfvuil Limburg.net. Hasselt:Limburg.net 107 Strictly speaking, waste streams that end up in public waste bins are not considered litter. These are a preventative measure to prevent litter and are part of the social cost of litter. 108 Tweejaarlijks onderzoek zwerfvuil Methodologisch rapport, KplusV (2017). 109 Based on primary raw materials prices and 30% remnant dirt and liquids. 110 Van der Bles (2018). Als blikken konden doden – een schatting van de economische gevolgen van zwerfafval voor de veehouderij in Nederland en Vlaanderen. 111 https://recyclingnetwerk.org/2018/02/27/zwerfvuil-maakt-koeien-ziek-vlaanderen/ 112 OVAM (2017). Vlaams Integraal Actieplan Marien Zwerfvuil. Mechelen: OVAM.
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linked to household packaging waste can be funded in part from the budget from the ‘Werkplan Halve Euro’
(Half Euro Working plan). A structural amount of 181,000 euros a year has been earmarked for marine litter in
this plan.
Use of volunteers
Volunteers work for free, but this does not mean that the cost of their work should not be taken into account.
From an economic perspective, the fact that volunteers commit to cleaning up litter can be regarded as the
next trade-off: less litter, and the additional positive personal effects (varying from a more pleasing, clean
environment to feeling good about oneself) are more important than the value that these volunteers assign to
their free time. The value that volunteers assign to their free time can be used as an indicator for the cost of
their efforts. In the Netherlands, a fictional hourly wage of 10 euros was allocated to volunteers to calculate
the cost of cleaning up litter, as part of a game. The monthly total was approximately 2.5 million euros. For
Flanders, the estimate is in the range of at least 10 million euros a year.
Violations and crime
A report of Zero Waste Scotland113 established a link between environmental factors and the number of
violations and criminal offences. When there is more litter in an area, it is considered a breach of standards,
potentially giving rise to an increase in crime. The costs of violations and crime can be subdivided into three
categories.
o Anticipatory costs, e.g., by taking out additional insurance.
o Consequential costs, e.g., the cost of replacing stolen goods or repairing damage.
o Response costs, e.g., the cost of additional police and legal costs. The indicative cost can be
calculated based on indicators.
Public health
Litter can cause various health problems.
o It can also cause injuries as a result of accidents.
o Mental health issues and mental illness due to a reduction of well-being.
o More illness due to stress and irritation.
Unwanted species
Litter, especially food waste, can attract vermin. Animals that are associated with litter include rats and birds,
such as pigeons and gulls. Controlling vermin is costly. Vermin also often causes damage, e.g. rodents that
gnaw and cause damage. The additional cost for cleaning up bird excrement is also an additional cost to be
factored in.
House prices
The environmental factors largely determine a neighbourhood’s appeal, which is partly reflected in house
prices. Litter (and the potential, associated, negative impact on other environmental factors) can reduce a
neighbourhood’s appeal, which in turn negatively affects house prices.
Tourism
Cities with a big litter problem can lose appeal, their reputation may be damaged, which can result in a drop in
tourism. This will cause a drop in income for cafes, restaurants and hotels. This problem occurs on a smaller
scale as well. Certain places of a the city may attract fewer tourists because the environmental factors are not
very favourable.
113 Zero Waste Scotland (2013). Exploring the indirect costs of litter in Scotland.
32
Reputational damage of companies
Environmental factors are not just relevant for tourist appeal. The inhabitants of a town may also be less
inclined to visit certain shops/shopping areas due to negative environmental factors.
Physical injuries to animals
In nature, litter can also cause physical injuries to animals. Examples include suffocation and entrapment, injury
and starvation. Suffocation and entrapment are often linked with plastic litter. Plastics can cause constipation
and injuries to the stomach-gut, causing death. Exposure to plastic particles and chemicals in plastic can give
rise to various behavioural effects (reduced activity and mobility), morphological effects (disruption of fat
storage, enzyme secretion in the gut, neurotoxicity) and reproductive effects (delayed ovulation, inhibition of
growth and delayed maturity). Animals most often injure themselves on cans and glass waste, but also on
plastics. Starvation often occurs because animals regard (indigestible) litter as food, causing their stomach to
become clogged114.
Irritation and nuisance
Litter can be a source of irritation and nuisance for the public, because it is regarded as socially unacceptable
but also because citizens worry about the (potential) environmental impact. Research has shown that more
nuisance is caused by coarse litter. Large packaging, such as beverage packaging, are expected to cause a
relatively big role in the nuisance people experience115.
Safety
Previously we already mentioned that litter can cause an increase in other offensive behaviour. This in turn can
contribute to creating a sense that the neighbourhood is not as safe as thought.
Social cohesion
A neighbourhood with a relatively large number of litter issues can inspire a lack of cohesion. People may feel
alienated and socially isolated.
Well-being
Litter and the negative environmental factors that are associated with it cannot just cause a sense of insecurity,
irritation and loneliness. They can also affect well-being as a whole. An example is the reduced sense of well-
being and contentment due to litter in a forest.
Damage while clipping green shoulders
The pollution of green shoulders with litter causes damage to mowers and complicates the transformation of
grass clippings into biogas and compost116. Litter also pollutes grass clippings, decreasing the value of this
product. The exact cost of this has not been calculated.
Plastic pollution in the oceans
Nobody knows exactly how much waste (including plastic) is already in our oceans, but roughly speaking, it is
estimated that approximately 8 million tonnes of plastic ends up in our oceans every year. The fear is that 150
million tonnes of waste (including plastic) will clog up our oceans by 2025 and that the weight of plastic in the
oceans will exceed that of fish by 2050. The Flemish public waste agency OVAM commissioned a study on
114 de Waard, S., de Jong, W. and Tijs, M. (2015) Zwerfafval (commissioned by RWS Leefomgeving) 115 OVAM. (2015). Impactanalyse invoering statiegeld op eenmalige drankverpakkingen. Mechelen: OVAM. 116 Inverde (2012). Eindrapport graskracht: vergisting van maaisels in Vlaanderen.
33
marine litter and microplastics in Flanders117. The share of packaging in marine litter ranges from 20-30%.
Plastic bags, food and beverage packaging are among the most frequently found items on beaches (Figure 11).
Figure 11: Composition of marine litter118
The study on marine litter and microplastics in Flanders enumerates several negative effects of plastic
packaging on our oceans.
117 Devriese, L.; Janssen, C. (2017). Overzicht van het onderzoekslandschap en de wetenschappelijke informatie inzake marien zwerfvuil en microplastics in Vlaanderen. VLIZ Beleidsinformerende Nota's, 2017_001. Vlaams Instituut voor de Zee (VLIZ): Oostende. ISBN 978-94-92043-34-4. 26 pp 118 Andrady A. L. (2015). Persistence of plastic litter in the oceans. In M. Bergmann, M.Klages & L. Gutow (eds.), Marine Anthropogenic Litter (pp. 57-72). Heidelberg: Springer.
34
• Entrapment
Animals can become entrapped in all kinds of packaging such as plastic ties and sixpack rings. Plastic cuts in the
flesh and limits the animal’s growth and may ultimately give rise to deformation, infections and/or suffocation,
causing the animal to die.
• Intake
Some organisms regard packaging as food and may die as a result. Effects include: external and internal
injuries, stomach ulcers, reduced intake capacity, a sense of saturation causing starvation, blockages of the
digestive system.
• Change and disruption of ecosystems
Plastic packaging can disrupt marine ecosystems with
o the formation of (artificial) hard substrates;
o the spread of invasive species due of floating plastic;
o the clean-up of beaches with machines.
• Poisonous substances
Plastics contain harmful additives such as Bisphenol A, nonylphenol, phtalates, bromated flame retardants,
dibutyltin and heavy metals. Their carcinogenic and/or endocrine disrupting effect may possibly be a risk for
freshwater organisms and humans. Plastic litter may possibly be a source of emission of additives to the
freshwater environment. Experiments have shown that the intake of microplastics can cause harmful quantities
of chemicals in the body of organisms. Humans could also be exposed to microplastics and related chemicals,
e.g. by consuming fish products. In addition, microplastics are like sponges, attracting poisonous substances in
sea water. The long-term consequences are difficult to assess, because the half-life of plastics is estimated to
be hundreds to even thousands of years119. In the sea, plastic is broken down into smaller particles due to the
presence of salt, UV light (photo oxidation) and the waves. Plastic maintains its original structure, but it
becomes less sturdy and falls apart into small fragments. These small particles, called micro- and nanoplastics,
are absorbed by organisms and can thus be detrimental to animals and the environment. The nature and range
of the impact varies depending on the type of pollution and the characteristics of the biota that are exposed to
them.
It is estimated that over 600 types of sea creatures are currently suffering due to entrapment and the ingestion
of marine litter. By 2050, almost all sea birds are expected to have plastic in their stomachs.
Habitat disruption
The introduction of litter can also disrupt the habitat of a species. Disruptions can occur due to physical injuries
(see above) or due to substances in the litter that impact biotic or abiotic habitat factors. The introduction of
litter in an aquatic habitat, for example, may change the chemical composition of the water, causing harm to
the organisms living in the water, as the environment has become toxic for them. Percolate water which has
been polluted with weather-beaten plastic can for example be toxic for water fleas. Litter can also introduce
invasive species, which has a disruptive effect on the habitat and possibly on whole ecosystems, although the
effects have not been clearly mapped. A more telling example is the growth of rat populations due to the
increase of litter containing food.
Greenhouse gas emissions
A study by Royer et al. (2018)120 showed that greenhouse gases 121 are emitted when plastic breaks down.
Polyethylene is the most active emitter. The study shows that the release of these greenhouse gases is
119 Possibly even longer around the poles and in deeper waters. 120 Royer, S. J., Ferrón, S., Wilson, S. T., & Karl, D. M. (2018). Production of methane and ethylene from plastic in the environment. PloS one, 13(8), e0200574. 121 Mainly CH4 (methane) as a greenhouse gas and C2H4.
35
continuous during the long breakdown phase of plastics. The methane emissions of plastics are twice as high in
air as in water.
Conclusion social cost
KplusV was able to outline the clean-up cost, the cost of lost materials, the cost of volunteers and the cost of
damage to cows in Flanders with the most accuracy. Packaging continues to have a prominent presence in
litter: all the packaging combined accounts for 70% of the volume of litter122. Mapping the hidden cost is a
more complicated exercise. An approximation of the hidden social cost for Flanders can be calculated by
converting the cost figures for Scotland and England to a cost per capita. However, the studies from Scotland
and England contain uncertainties and inaccuracies. Thus, the order of magnitude will be discussed in the
following instead in order to shed light on the social cost of litter.
KplusV concludes that the total social cost of packaging materials in litter in Flanders amounts to a billion
euros every year. However, the calculation of hidden cost is incomplete, as the lack of data made it impossible
to factor in certain effects. Examples include the effects of litter on rivers and oceans as well as the
microplastics issue. Recover aims to provide a starting point to examine all the hidden costs associated with
litter in Flanders for inclusion in policy decisions.
Costs of local authorities, related to management of packaging waste, are not fully reimbursed by producers
Reference cost
According to the legislation, Fost Plus must compensate the local authorities in keeping with the principle of
real and complete cost, meaning it must pay the invoices of the collectors and sorting centres directly. If the
municipality or the intermunicipal company decides to manage the collection of packaging waste itself,
according to a basic scenario, i.e., with own employees and garbage trucks, then Fost Plus and the municipality
or the intermunicipal company must jointly determine the charges to be paid for this. Fost Plus uses the so-
called reference cost as a starting point in negotiations. The Interregional Packaging Commission determines
the reference cost, by taking the average of the contracts that were awarded by the intermunicipal companies
that outsource their collection.
The question remains whether the reference cost fully covers the actual (real) collection cost. The contracts are
almost always awarded to the tenderers with the lowest price, and consequently do not give an accurate
picture of the effective collection cost. An average of all the received quotes - omitting abnormally high and
low prices - would give a better idea of the real cost of this service.
The average reference cost should be 17.8% higher
Recover compared the current calculation of the reference cost with the average of the contracts that were
submitted, to get a better idea of the actual cost of the collection. It concluded that on average the reference
cost should be 17.8% higher. The cost for paper and cardboard is underestimated the most, i.e. by 27%:
122 Der Linden (2018). Rapport Samenstelling zwerfvuil Limburg.net. Hasselt:Limburg.net
36
Figure 12: Additional cost when the average of all submitted quotes is compared with the average of the lowest quotes (%) (Recover, 2018)
According to this approach, municipalities and intermunicipal companies which manage all the collection of
packaging waste themselves, are currently underfunded for their collection by approximately 1.50 euros per
inhabitant. For a city like Antwerp, this amounts to €750,000 a year.
Collection systems that are not recognised
The reference cost is also applied to the collection of packaging waste through subsoil containers, door to door
collection of glass packaging, or collection of additional plastics (most of which is packaging) in the so called
‘pink bag’, which some municipalities use. All these collection systems have their merits, and have proved their
efficiency. However, they are only compensated according to the reference cost of one of the cheaper basic
scenarios. The recognised basic scenarios, which must be fully compensated and which have existed now for
more than 20 years, no longer fulfil the public’s needs.
Hidden costs
In addition to this, the local authorities still incur costs during the separate collection, which are not covered by
the compensation that Fost Plus pays. In order to get an image of this, Recover asked a group of students of the
University of Hasselt to send a questionnaire123 to the various intermunicipal companies of which fifteen
participated in the survey. The students found following conclusions:
• 77% of all the respondents incurred additional costs that are not covered by the fees that Fost Plus
pays.
• Examples of activities that are not covered by Fost plus are additional administration, special
collections such as catch-up or evening waste collections, litter collection, the emptying of the
underground paper and PMD containers, the affixing of PMD stickers, the clean-up of litter near bottle
banks and the use of personnel for communication.
123 Holsteyns J., Van Eesbeek A., Vanschoubroek M., 2018. Zwerfvuil oplossen: naar een optimaal beleid voor het beheer van verpakkingsafval. Onuitgegeven eindwerk Bachelor Toegepaste Economische Wetenschappen. Hasselt: Universiteit Hasselt, Faculteit Bedrijfseconomische Wetenschappen
14,44% 14,12%
26,99%
15,65%
17,80%
0,00%
5,00%
10,00%
15,00%
20,00%
25,00%
30,00%
glass pmd paper &cardboard
duo p&c andpmd
average
% additional cost
37
Conclusion
The fee that is paid to the local authorities is still not in keeping with the legal principle of the ‘total and real
cost’. Recover argues in favour of a correct compensation for the collection of packaging waste, as laid down in
legislation now for more than 20 years.
4 A difficult sorting instruction for the public
The PMD sorting instruction ‘Plastic bottles and flasks, Metal packaging and Drinks cartons’ has not changed
since 1994. Fost Plus has already made a substantial effort, along with the municipalities and the
intermunicipal waste companies, to explain the sorting instructions to the public. In spite of these efforts, the
public still does not understand the sorting instructions for the PMD bag.
Quantitative survey shows that people see a “P” and think “plastic” Recover commissioned the company Day One to conduct a study on how citizens currently experience the
sorting and collection of packaging waste. The survey showed that most people make sorting errors when
dealing with plastic packaging. The respondents found the sorting for plastic and small hazardous waste to be
most complicated. The paper and cardboard collection was considered the easiest stream (Appendix C).
Another organization, IPSOS, carried out a study, commissioned by the VVSG, on the ease of communication of
the PMD sorting message. This revealed that the main cause for the wrong sorting of PMD is that the public
simply does not sufficiently understand the basic rules. Day One concluded that only one in every four
respondents is well informed about the sorting rules. And because they don’t understand the rules, the public
perceives PMD sorting as being difficult. Daily PMD sorting is thus based on habits and routines. The public
makes almost no mistakes when it comes to items they must sort daily, such as plastic water bottles, the tins of
canned goods and drinks cans. They tend to make errors when faced with packaging they don’t use on a daily
basis. It turns out to be very difficult to break these habits with communication. The City of Antwerp conducted
a similar study124 into the communicability of the GFT (vegetable, fruit and garden waste) and PMD fraction.
This showed that PMD was the category where people had the most doubts, as it was not sufficiently clear to
them what exactly is allowed in the PMD-collection. At the same time, people are very much aware that they
cannot put any waste plastic in the bag, causing more uncertainty. PMD is often generalised by the public as
the ‘bag for plastic’. The main conclusion is a recommendation to keep the sorting instructions as simple as
possible and also communicating about how the sorted waste is processed and used.
Bags containing too much other waste are refused during collection During door to door collection, garbage men often find waste products in the PMD bag that do not belong
there. To prevent sorting errors in the future, the collector puts a red sticker shaped like a hand on the bag and
does not collect it. The sticker is stuck near the wrongly sorted object. The persons who put out the bag can
thus see what does not belong in the bag and why the bag was not collected. They must then remove the
wrong fractions from the bag and put it out again for the next waste collection. However, in an urban context,
many people leave their refused bags out on the street. This causes nuisance and frustration, forcing the
municipalities to collect these refused bags anyway. They are then processed in the residual waste fraction,
which means that also recyclable materials are. Many cities and municipalities are forced to apply their sorting
rules less stringently because too many bags would be left behind.
124 Stad Antwerpen (2014), Afvalbeheer. [PowerPoint] – uitgevoerd door Ipsos.
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Residual waste in the PMD bag The residue percentages of PMD bags show that the public is still making a lot of sorting mistakes. On average,
PMD waste contains 44% plastic bottles and flasks, 28% metal packaging, 11% drinks cartons, 2% PMD bags and
15% residue. The residue thus accounts for a sixth of the contents, comprising all kinds of waste products that
do not belong in the PMD bag. A sorting test by one Flemish intermunicipal organization demonstrated that
more than 90% of the PMD residue consists of plastic packaging, which Fost plus does not accept in the PMD
bag125. Figure 13 shows the various fractions in the PMD bag for Flemish households.
Figure 13: Composition of the PMD bag in the Flemish Region126.
More and different efforts required for communication A study by Recover127 shows that the communication can be improved. Respondents are under the impression
that they know the sorting rules well enough but two out of three respondents overestimate their knowledge
when challenged. This misplaced confidence means that people are not getting Fost Plus’ message about
sorting and recycling. Pointing this out to consumers/families is an additional challenge. Almost half of all the
respondents think that companies should invest (even) more in communication about sorting and recycling,
illustrating that it is not just a content-based or formal problem. It is important to look at ways to better
motivate the public. Figure 14 illustrates the results of the survey regarding the motivation to sort waste. It
shows that the public prefers emotional arguments over rational ones. Contributing to saving our planet was
the most important reason.
125 https://www.ingelmunster.be/fileadmin/MEDIA/docs/milieu/Milieubarometer/13_sorteerresidu_PMD_-_website.pdf 126 OVAM (2017). Huishoudelijk afval en gelijkaardig bedrijfsafval 2016. Mechelen: OVAM. 127 Day One, 2018. Evaluatie van huidig systeem en inspiratie voor nieuw scenario gescheiden inzameling verpakkingsafval. Brussel: Recover [PowerPoint].
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Figure 14: I sort my packaging waste as much as I can because...(footnote 127)
Respondents indicate that the main obstacles include the accessibility of the collection points, the low
frequency of the collection and the lack of space in-house. Possibly respondents have trouble distinguishing
between the collection of packaging waste and other waste streams. Four out of ten respondents have no idea
what happens to waste after it is collected. Generally speaking, most respondents do not regard waste sorting
as a burden. Four out of ten even indicate that they could sort more. An interesting conclusion is that the most
important information channel still is paper media (e.g. municipal brochure on waste management or a
collection calendar).
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Chapter 5: The management of packaging waste in different European countries
This chapter discusses the most interesting practices of international policy for packaging waste. By examining
the Flemish waste policy from an international perspective, we try to understand where Flanders can improve.
International comparisons can also be used to help formulate and support policy goals and ambitions. Reaching
certain collection and recycling percentages indicates that policy targets are realistic and feasible. Flanders can
also learn a lot from the countries that have a good track record in terms of litter policy. We identified these
international practices, based on a Master dissertation of the University of Antwerp, conducted by Roxanne
Abels. She combined document research with interviews with different stakeholders. The Flemish policy for
packaging waste was compared to the German, French, Norwegian, Danish and Dutch system. Recently, ACR+
conducted an in-depth study into deposit return systems in ten European countries. These are Germany,
Denmark, Estonia, Finland, Croatia, Iceland, Lithuania, the Netherlands, Norway and Sweden. Recover had the
opportunity to review the provisional results of this survey. We wish to stress that Recover received this
information at an early stage of the research and that Recover is basing itself on provisional documents. Since
then ACR+ has continued to develop its research, supplementing it and (in most cases) having the data
validated by local experts. Recover took the most important policy elements in the Master’s thesis from the
University of Antwerp, were inspired by the provisional ACR+ research and supplemented the chapter with
own document research.
1 The Netherlands128
Collection of plastic packaging through Plastic Heroes In the Netherlands, in addition to a collection similar to the Belgian PMD bag, the packaging industry launched
a new initiative, called “Plastic Heroes”. This is a collection system for plastic packaging that does not fall under
the deposit return system, such as small PET bottles, butter containers, other containers and plastic bread
bags. Since 2009, the project has substantially increased the amount of collected plastic packaging waste. In
2014, 162 kilotonnes of plastic were collected from households and through subsequent separation. In 2009,
this was just 25.2 kilotonnes. The separate collection of the plastic packaging that all the households in the
Netherlands dispose of in a year yields CO2 savings that are comparable to the CO2 emission of the electricity
consumption of 100,000 households129. The figures of the Afvalfonds Verpakkingen (Packaging Waste Fund)
show that in 2016, 51% of all plastic packaging was recycled. Approximately 80%130 of the share that is
collected under the Plastic Heroes system is recycled as a monostream. The remaining plastic packaging is
mainly recycled as mixed plastic. The Netherlands have the best recycling rate for plastic packaging of all the
countries studied.
A limited but efficient deposit return system Since 2006, the Netherlands have enforced a deposit return system for single-use PET beverage packaging for
volumes of 1 litre or more131, mainly to reduce the amount of litter. The deposit is 0.25 euros per bottle.
Stichting Retourverpakking Nederland (SRN) is tasked with the coordination and registration of the deposit
128 Information mainly taken from Abels, R. (2018). Hoe positioneert het huidig Vlaams beleid inzake verpakkingsafval zich binnen de internationale context? Onuitgegeven eindwerk Master in de Milieuwetenschap. Antwerpen: Universiteit Antwerpen. 129 CE Delft (2016). Wat redt een Plastic Hero? Delft: CE Delft 130 Mainly PET bottles. 131 Decision regarding the management of packaging, paper and cardboard, Overheid.nl, 8 September 2011.
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return system. It cooperates with all Dutch supermarket chains, except Aldi and Lidl. These supermarkets
operate their own closed deposit return system, which does not accept deposit bottles of the SRN scheme. SRN
requests a contribution from producers for every bottle with a deposit which they place on the market. It uses
this income to run the deposit return system. Official figures show that this is an efficient system. Almost 95%
of all deposit return system bottles are returned. The remaining 5% are collected via Plastic Heroes or end up in
the residual waste fraction. The deposit return system results in collection of a high quality PET stream with
very little impurities. The bottles contain much less dirt and liquids compared to what is collected through
other collection systems (Figure 15). An interview with HVC132 revealed that the introduction of a deposit
return system for large bottles was a positive move in the fight against litter. The share of large PET bottles in
litter is just 0.3%. The system will be extended to include plastic bottles and tins, if the producers do not
succeed in reducing the amount of plastic bottles in litter by 70- 90% by 2021. By then, 90% of these bottles
must also be reused.
Figure 15: Net PET content of all the bottles and containers, compared with the total weight of the sorted PET products for the various collection systems133
Emphasis on collection of more plastics Plastic Heroes focuses on packaging. Other plastic products such as toys and garden chairs are collected at
recycling centres. In the spring of 2015, a study was conducted to measure the share of plastic non-packaging
in sorted plastics at the request of the Begeleidingscommissie Verpakkingen (Packaging Commission)134. The
conclusion was that the share amounted to 9.8% on average, based on 75 observations. The Plastic Heroes
system could thus also work for the collection of all plastics.
Freeriders The Netherlands actively aims to identify freeriders. They are currently estimated to make up 2% of the
producers.
More emphasis on quantity According to the HVC, the Dutch waste policy creates good stimuli for the separate collection of packaging,
meaning a lot of raw materials end up at the recycling companies. All too often however, the emphasis is on
132 The HVC is a Dutch organisation. It is tasked with the sustainable waste management of its shareholders (46 municipalities and 6 water boards in Noord-Holland, Zuid-Holland, Flevoland and Friesland). 133 Van Velzen T., Brouwer M.T. en Molenveld K. (2016). Technical quality of rPET that can be obtained from Dutch PET bottles that have been collected, sorted and mechanically recycled in different manners. 134 Aandeel kunststof niet-verpakking in gesorteerde kunststofproducten, Nedvang – KNV working group, 2016.
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the quantity rather than the quality of the collected material, which is an obstacle for high-quality recycling.
According to Recycling Netwerk, the Plastic Heroes system has several shortcomings. A small share of the
plastic waste is recycled as high-quality recyclate. However, most of the output of the sorting facilities cannot
be sold and is used as recovered material or stored in warehouses. Taking into account dirt and liquids, only 5-
10% of all plastic packaging waste from households is used to replace virgin plastics135.
Actual recycling falls short Part of the material is lost, both during the sorting and the recycling phase (Figure 16). The sorting analyses of
Nedvang show that 3.5% liquids, 0.7% non-plastics (cans, aluminium and drinks cartons) and 22.3% residue are
lost during the sorting process136. Residue mainly consists of liquids (5%), the paper of labels and the organic
material of food and drink that remained in the packaging. The recycling companies must also remove any dirt
and liquids. The amount of residue is in the range of 10-28% of the weight of the plastic packaging material,
upon arrival at the processing plant, and depending on the type of plastic. Plastic is also lost during processing.
The loss also depends on the plastic stream and varies between 0-15%137. Based on this information, only 42-
67% are effectively recycled.
Figure 16 Sorting and processing of separately collected plastics in the Netherlands (footnote 136)
Eco-design: room for improvement As mentioned higher, a study138 of the University of Wageningen showed that only 56% of the packaging on
the Dutch market can be recycled. In principle, 6% of the packaging is easy to recycle as user consumer items,
but this is not ideal as this packaging may disrupt the recycling of other packaging for more circular
applications, such as coloured PET bottles and PP film. A total of 28% of all collected packaging is difficult to
recycle. This mainly pertains to PS and PVC packaging, laminates and blister strips.
135 http://recyclingnetwerk.org/wp-content/uploads/2016/10/160930-Recycling-Netwerk-aan-TK-commissie-IM-nav-CPB-notitie.pdf 136 Bergsma, G. C., Bijleveld, M. M., Otten, M. B. J., & Krutwagen, B. T. J. M. (2011). LCA: recycling van kunststof verpakkingsafval uit huishoudens. CE Delft, Delft. Table 45 and 46. 137 Nusselder, S., Odegard, I. Y. R., (2016). Wat redt een Plastic Hero?. CE Delft, Delft. 138 Brouwer, M. T., & van Velzen, E. T. (2017). Recyclebaarheid van verpakkingen op de Nederlandse markt (No. 1782). Wageningen Food & Biobased Research.
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Green dot on packaging In the Netherlands, they do not advise using a green dot symbol on packaging. Research showed that
consumers were under the impression that packaging with a green dot logo is recyclable, which often is not the
case. In practice, the majority of Dutch companies do not use this symbol139. In 2012, the supermarket chain
Albert Heijn, Nedvang and Milieu Centraal developed an easy to use tool, with information about how to sort
waste, called the “Weggooiwijzer”. Icons inform customers how to dispose of specific types of packaging. These
include the most frequent waste streams, i.e., paper, glass, plastics and residual waste. The Knowledge
Institute for Sustainable Packaging (KIDV, Kennisinstituut Duurzaam Verpakken) manages the tool and drew up
a guideline about the use of these icons. Each icon consists of three elements, in one block. The component of
the packaging is listed at the top (e.g., the lid or the jar). The icon and the text under the logo indicate in which
waste stream people should dispose of the packaging component140 (Figure 17).
Figure 17 Basic icons in the Weggooiwijzer sorting guide (footnote 140)
Industry support for the fight against litter A separate agreement between the business community and the Dutch government makes industry contribute
20 million euros every year, for the prevention and clean-up of litter. These funds are paid out by Nedvang,
which is the executive organization of companies that place packaging on the market. It is divided among the
municipalities, which submit plans for this. The division is based on a fixed amount, supplemented with a
payment per inhabitant. Every municipality is free to use these funds as it sees fit to boost its local litter policy.
Municipalities must use WasteTool, a registration system for the various streams of collected packaging waste
from litter, to register how they used these litter funds.
2 Germany
Competition between producer responsibility organizations is an issue Until 2005, Germany had one Producer Responsibility Organization (PRO) which occupied a monopolistic
position: Duales System Deutschland (DSD). Currently there are ten PROs operating on the German market. The
introduction of competition between producer organizations has halved the cost of the collection and recycling
of packaging waste for the producers. But competition also has its drawbacks, as demonstrated by an interview
with EXPRA. The low price often comes at the expense of quality. Freeriding is a big problem in Germany. In
2019, the German government hopes to increase the participation of producers in EPR systems by introducing
new legislation141.
139 https://afvalfondsverpakkingen.nl/a/i/uitleg_Groene_Punt.pdf 140 https://www.nedvang.nl/weggooiwijzer 141 Abels, R. (2018). Hoe positioneert het huidig Vlaams beleid inzake verpakkingsafval zich binnen de internationale context? Onuitgegeven eindwerk Master in de Milieuwetenschap. Antwerpen: Universiteit Antwerpen
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Satisfaction with the deposit return system The deposit return system was primarily introduced to maintain the large share of reusable packaging.
Germany is regarded as the inventor of extended producer responsibility with its 1991 packaging waste
legislation. This legislation states that the amount of reusable packaging on the market may never drop below
72%. If this would be the case, the government would be forced to introduce a deposit return system for all
single-use beverage packaging. In 1997, the market share of reusable packaging dropped under the 72%
threshold for the first time, and numbers only deteriorated in the following years. In 2003, the government
launched a deposit return system. The system generates high collection percentages for PET. According to
Forum PET142, 93.5% of all PET bottles were recycled in 2015, while 97.9% of all returnable bottles were
recycled. The deposit return system is a success: approximately 98.5% of all the refillable bottles are returned
by consumers143. Moreover, the recycling quality is high, paving the way for bottle to bottle recycling. Beverage
packaging also accounts for a very small share of litter.144
Ecomodulation The German deposit return system imposes separate fees for reusable and non-reusable packaging145.
Producers of biobased plastics are also exempted from paying green dot contributions146.
Consumer happy about deposit return system The principle of the returnable packaging with a deposit is very popular in Germany: nine out of ten consumers
like the fact that packaging is reused multiple times. Two thirds indicate that they prefer to buy products such
as soft drinks and yoghurt in returnable packaging. There are also some critical voices however: four out of ten
consumers complain that they often find it difficult to recognise whether they are holding single-use packaging
or packaging that can be used multiple times. According to PwC, the producers and traders must use uniform
icons on their products. Consumers should be able to see at a glance whether they are holding single-use
packaging or returnable packaging with a deposit147.
New packaging legislation from 2019 onwards148 On 1 January 2019, the new German packaging legislation (‘VerpackG’) takes effect and recycling targets for
the various different packaging materials are raised to 90% for plastic by 2022 (currently 36%) and also 90% for
metal, glass and paper and cardboard. The law will also encourage reusable packaging, with the aim of using
70% of that by 2022 and offer incentives to packaging manufacturers who incorporate recyclate in their
packaging designs.
All companies must register with the central packaging registry to be able to access the market. Companies
that produce volumes of more than 80,000 kg glass, 50,000 kg paper and cardboard and 30,000 kg aluminium,
plastics and compounds, which are sold in Germany, must submit a declaration of conformity with the new
packaging legislation. Failure to do this will result in a fine of 50,000 euros. The legislation applies to all
manufacturers, importers, distributors and online shops that place goods on the German market. All companies
that sell goods in Germany must prepare to take part in a system to arrange the recovery of the packaging after
142 A German association of PET recycling companies. 143 Watkins, E., Gionfra, S., Schweitzer, J. P., Pantzar, M., Janssens, C., & ten Brink, P. (2017). EPR in the EU Plastics Strategy and the Circular Economy: A focus on plastic packaging. Institute for European Environmental Policy (IEEP). 144 Abels, R. (2018). Hoe positioneert het huidig Vlaams beleid inzake verpakkingsafval zich binnen de internationale context? Onuitgegeven eindwerk Master in de Milieuwetenschap. Antwerpen: Universiteit Antwerpen 145 https://www.umweltbundesamt.de/en/topics/waste-resources/product-stewardship-waste-management/packaging 146 Van Hoof V. en Geerken T. (2012). Bioplastics: Definities, normen, toepassingsmogelijkheden, milieu-impact. Mol: VITO. 147 http://www.agf.nl/artikel/169800/Duitse-consumenten-hechten-waarde-aan-duurzame-verpakkingen 148 https://www.gruener-punkt.de/en/services/packaging/german-packaging-act.html
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use, in order to be able to continue trading in Germany. The legislation aims to achieve higher recycling quota,
and is another step towards a sustainable circular economy.
3 France149
Unique tariff classification for the green dot contribution In 2018, the tariffs for the green dot contribution were adapted. A new ecomodulation was developed and a
new unit introduced, the UVC (=Consumer Sale Unit). In France, producers and importers pay a contribution
that depends on the number of packaging units, the weight and the material of the household packaging they
place on the market. The contribution takes into account the recyclability of their packaging and the number of
packaging units per UVC.
Producers can choose from three tariffs.
• The declaration by UVC unit: declaration of the various UVC placed on the market, broken down by
weight and material.
• The sectoral declaration: producers in the French market can choose to submit a sectoral declaration if
they place less than 500,000 UVCs on the market every year;
• A lump sum of 80 euros, without declaration, for producers that place less than 10,000 UVCs on the
French market.
The tariff is calculated as follows:
Total contribution = (1 + 2) X 3
whereas: 1 = contribution by weight by material
2 = contribution per UVC (increased if the UVC consists of several packaging units)
3 = bonus/malus (ecomodulation)
The contribution by weight by material and by UVC
When producers choose to submit a declaration per UVC, they must distinguish between seven types of
materials (Table 7). Less recyclable materials (such as drinks cartons and plastic packaging) are subject to the
highest tariff. To avoid ‘overpacking’, the tariff also takes account of the amount of packaging per consumer
unit.
Table 7: Green dot tariffs by material
Material Tariff (eurocent/kg)
Steel 4.43
Aluminium 10.38
Paper/Cardboard150 16.30
Drinks cartons 24.74
Plastic 31.23
Glass 1.42
Other materials 31.23
149 Information mainly obtained from Arcadis, 2018. Milieueffecten van het Samenwerkingsakkoord Verpakkingsafval. Brussel: Recover 150 The tariff for paper and cardboard packaging, of which 50% of the total weight of the packaging consists of recycled material, is reduced by 10%, after submission of a certificate issued by the packaging supplier.
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Bonus-malus (ecomodulation):
The bonus-malus system is very progressive. The bonuses go to materials that are easier to recycle and for
packaging with the right sorting instructions. The tariff also drops when the producer tries to raise awareness.
Possible bonuses include:
• Package bonuses (cannot be combined);
• Bonus of 8% on the total contribution if certain sorting instructions such as ‘recyclable’, ‘disposable’
are featured on the packaging;
• Bonus of 5% on the total contribution if the packaging features the ‘Triman’ logo, without instructions
on how to sort it;
• Bonus of 5% on the total contribution for raising awareness, by adding a QR code to the packaging,
which refers to the sorting instructions;
• Bonus for awareness campaigns, not on packaging;
• Bonus of 4% on the total contribution for campaigns on TV/Radio, in the media.
The package bonus can be combined with the bonus for awareness campaigns.
Possible maluses include:
Surcharge for disruptive packaging. A surcharge of 50% of the total contribution will be charged for the
following packaging, due to the degradation in quality of the recycled product: glass packaging with a
porcelain or ceramic cap; Packaging for liquid foods, of which cardboard is the primary component,
but which consists of less than 50% fibres; a packaging of ‘bonded’ paper and cardboard; bottles that
are primarily made from PET, but which contain aluminium, PVC or silicone;
• Surcharge for PET packaging with mineral opacifiers: increase of 100% weight when PET packaging
contains more than 4% opacifiers;
• Surcharge of 10% weight when cardboard is printed with ink made by adding mineral oils;
• Surcharge of 100% of the total contribution for packaging, which is sorted and collected, but which is
not recycled (e.g., other plastic bottles than PET, HDPE or PP, other types of glass than sodium-
calcium). This surcharge does not apply to plastic packaging other than plastic bottles.
Packaging to which a malus is applied is not eligible for bonuses.
Sectoral contributions are an option for some packaging and for producers that place less than 500,000 UVCs
on the French market. These contributions are calculated based on a fixed tariff, that is multiplied with the
number of UVCs. The bonuses and maluses are not applied in this case however, meaning producers are less
inclined to use environmentally-responsible solutions or raise awareness about recycling.
A lump sum is applied for producers of smaller quantities of packaging. This ensures that they also contribute.
The bonus/malus system is not applied in this case either.
One category for plastic packaging
Another change is the combination of plastic packaging in one category. Until 2018, plastic packaging was
subdivided into three categories:
• Clear PET bottles and PET jars;
• Other plastic bottles and jars;
• Other plastic packaging.
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In 2018, these categories were combined again, to simplify the tariff structure and because, according to
CITEO, substantial investments are currently being made to double the amount of recycled plastic packaging
units, regardless of the plastic’s composition.
4 Denmark
Tax rules In addition to the deposit return system for beverage packaging, Denmark has a packaging tax, instead of
extended producer responsibility. The local authorities fund and coordinate packaging waste management. The
packaging industry pays an environmental tax on the products it puts on the Danish market. The tax depends
on the weight and the material of the packaging. A volume tax is also applied to beverage packaging and a
weight tax on paper or plastic bags, disposable cutlery and films. As a result, producers are encouraged to use
less packaging. The local authorities determine the amount of the tax themselves. Defining this tax is often
used as an electoral promise. The amount must be sufficiently high to finance everything but cannot result in a
profit. The Danish Tax and Customs Administration checks and coordinates this tax system. The government
checks whether the local authorities approximately achieve the same efficiency figures for waste processing.
The tax applies to producers, distributors, the refillers of beverage packaging and importers.
Sorting by material The Danes sort packaging by the material. Packaging and other household waste which is made of the same
material are collected in the same bin or bag. The Danish Waste Association (DWA) and Local Government
Denmark (LGDK) feel very positive about this method for sorting packaging at the source. Products that are
made of the same material each have an indicated waste stream, making processing a cost-efficient operation,
which can be implemented on a large scale. The DWA however does think that more packaging can be
collected for reuse and recycling. Too much packaging is still being incinerated.
The deposit return system is a huge success In 2016, the Danes returned 1.15 billion bottles and cans under the deposit return system, which is the
equivalent of a collection rate of 90%151. The collection rate for reusable packaging was 102% in 2016.
According to Dansk Retursystem, a rate greater than 100% is the consequence of the growing market share of
single-use packaging (Figure 18)152.
151http://mfvm.dk/fileadmin/user_upload/MFVM/Case_catalog__Danish_examples_to_reduce_plastic_pollution_and_making_pl.._.pdf 152 Dansk Retursystem: Annual Report 2016
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Figure 18: Market share of single-use (light green) and reusable (dark green) packaging and take-back rates (grey)153
During the 2014 litter campaign, approximately 20% of the collected cans were returnable cans, subject to a
refund. The remainder consisted of foreign beverage packaging that did not fall under the Danish scheme154. It
is estimated that 400 million cans of beer and soft drinks are purchased every year in Germany and then
transported back to Denmark for personal consumption155. Based on the Dansk Retursystem strategy for 2020,
the company has consistently worked to expand the dialogue with consumers. 92% of all consumers are in
favour of the system156.
Limited recycling of plastic packaging Over four million Danes regularly collect plastic packaging waste157. Until recently, half of all the collected
plastic was sent to China. In January 2018 however, China officially closed its borders to a series of waste
streams, including plastics. According to the DWA, only 15% of the collected plastics are recycled. The closure
of China’s borders has contributed to the low recycling rate. But a lot of the plastic packaging that is placed on
the market consists of multiple layers, which cannot be melted down to produce new plastics. According to the
DWA, stringent requirements must be imposed on packaging manufacturers.
Waste management strategy Recently a new waste management strategy took effect, with new targets for 2018 and 2022. These are
identical to the goals formulated in the EU’s Waste Framework Directive158.
5 Sweden
The success of the deposit return system In Sweden, the discussion about the introduction of a mandatory deposit return system for cans and PET
bottles started in the early Seventies when single-use beverage packaging was first placed on the market and
153 Dansk Retursystem: Annual Report 2016 (in Danish) [http://www.dansk-retursystem.dk/wp content/uploads/2017/05/Aarsrapport-_2016_web.pdf]. 154 Inge Frisker, presentation of Dansk Retursystem. 155 Dominic Hogg, Debbie Fletcher, et al. "Have We Got The Bottle? Implementing a Deposit Refund Scheme in the UK?”, Eunomia, 2010. 156 Dansk Retursystem: Annual Report 2016 [http://mst.dk/media/133289/annual-report-2016-dansk-retursystem.pdf]. 157 Excluding plastic drinks packaging. 158 http://data.consilium.europa.eu/doc/document/PE-11-2018-INIT/en/pdf
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the number of reusable bottles began to drop. Initially the industry was against the mandatory deposit return
system. But gradually the industry became convinced that it had no other choice than to set up a deposit
return system, faced with social pressure and the fact that it failed to achieve the recycling rates set out by the
government (despite the fact that the industry voluntarily stepped up its efforts). In 1984, the Returpack
organization was founded. It was owned by three partners: manufacturers of single-use beverage packaging,
drinks manufacturers (including brewers and producers of fillers) and retailers. In 1984, the system for
aluminium cans was established and ten years later, in 1994, the organization started to collect PET bottles159.
This does not apply to drinks that contain 50% or more of dairy products or vegetable, fruit or berry juice. Since
2015, juice bottles can also be included in the Returpak system if the manufacturer prefers this160. The deposit
return system for metal cans and PET bottles gave rise to a drastic increase in the separate collection of these
products. Since 2000, the recycling percentage for metal cans is in the range of 85-93%. In 2016, it stood at
86.2%, a drop of five percentage points compared with 2015. It was also the first time in five years that the 90%
recycling target was not achieved. The recycling rate for PET bottles was 82.5% in 2015, a drop of one
percentage point compared to 2015. The biggest challenge were the smaller PET bottles which are often
consumed out of home.
Generally, the various national and international stakeholders have accepted the deposit return systems. The
Swedish population already has plenty of experience with sorting, because the return system for glass bottles
was established several decades ago and works well. As a result, the public was very positive about the
introduction of a system for single-use packaging.
6 Norway161
High collection results thanks to the deposit return system Norway levies an environmental tax on beverage packaging. The tax is calculated based on the collection
results. The more beverage packaging is collected, the lower the tax. When the collection rate is 95% or higher,
the producer is fully exempted from the tax (Figure 19).
Due to the high environmental tax on beverage packaging, the drinks producers and supermarket chains
decided to establish a deposit return system for plastic bottles and cans. Infinitum is the organization tasked
with the management and execution of the Norwegian deposit return system. Producers of beverage
packaging can choose whether they want to join a Green Dot organization or Infinitum. Most producers find
the Infinitum model more interesting from an economical point of view, because the company’s high collection
percentages result in a lower environmental tax. Approximately 97% of the cans and 95% of all bottles are
collected (Figure 20). To join Infinitum, the packaging must fulfil several quality criteria, aimed at facilitating
sorting and recycling.
159 Tojo, N. (2011). Deposit Refund Systems in Sweden. IIIEE Reports, 2011(05). 160 https://pantamera.nu/om-oss/verksamhet/historia/ 161 Information mainly taken from Abels, R. (2018). Hoe positioneert het huidig Vlaams beleid inzake verpakkingsafval zich binnen de internationale context? Onuitgegeven eindwerk Master in de Milieuwetenschap.
50
Figure 19: Presentation about the Norwegian environmental tax on beverage packaging, expressed in Norwegian Krone 162
Figure 20: Recycling results of the Norwegian deposit return system 163
162 Figure obtained from Infinitum 163 Figure obtained from Infinitum
51
Uncertainty about the compensation of local authorities The cooperation between the packaging industry and the local authorities is not always seamless on a financial
level. According to the principle of extended producer responsibility, the producer contribution must cover the
complete cost of the system. Norwegian legislation does not determine how high this cost should be. The
legislators decided not to delve deeply into this matter. The financial compensation for collection and recycling
is thus based on an agreement between the two parties and they often disagree about the real cost for
collection and processing.
Moreover, the local authorities are not compensated for the clean-up of packaging in litter. However,
according to the Norwegian Environment Agency and Infinitum, Norway has no major litter problems thanks to
the deposit return system.
Local authorities decide about local collection systems In Norway, the local authorities have a lot of freedom when it comes to organising the system. This is necessary
because of the big differences between the regions in the country. The Norwegian Environment Agency thinks
that stricter requirements should be imposed so that the local authorities optimise management.
7 Estonia
Satisfied with the deposit return system Since May 2005, Estonia has had a deposit return system for single-use and recyclable beverage packaging. At
the same time, the country also established a collection system for all other packaging. The three main reasons
for introducing a deposit return system were (1) to increase the collection rate and the reuse of packaging, (2)
to collect more recyclable material and (3) to reduce the environmental impact of beverage packaging. In 2017,
the Estonians collected 87.4% of all plastic bottles, 73.5% cans and 88.7% glass bottles. There is no data
available about the difference between the amount of litter before and after the introduction of the deposit
return system. Consumers are sufficiently informed and they are sufficiently aware of the system. A survey
showed that 95% of all consumers are aware of the deposit return system and 81% believe in returning
beverage packaging164. The producers are also very satisfied. The income from deposits that were not refunded
was sufficient in recent years to cover the system’s expenditure165.
In a survey by Eesti Pandipakend166, retailers and producers did note that the deposit return system is
necessary to protect the environment. On a scale from 1-5 (with 5 being the best score), the producers gave
the system an average score of 4.2 and the retailers a 4.5.
8 Lithuania
Deposit return system scored well in addition to the existing collection system After analysing the successful deposit return systems of other EU countries, the Lithuanian government
decided to introduce the system in 2016 for single-use cans, plastic bottles and glass packaging. One of the
main drivers was to reduce environmental pollution. In addition to this, the government had concluded that
the collection and processing of recyclable waste streams was not efficient enough167.
164 Good Practices Tallinn Factsheet 1, R4R. 165 Impactanalyse invoering statiegeld op eenmalige drankverpakkingen (2015), OVAM. 166 Management body of the Estonian deposit return system. 167 in 2013, 64% of all collected urban waste was taken to a landfill.
52
In the first year after the introduction, over 75% of all single-use beverage packaging was collected. This rate
increased to 92% during the second year (2017). As a result, the system easily achieved its target of 65%168. The
manager of the system expects the collection rate to increase to 93% in 2018.
9 Canada
Deposit return system helps reduce amount of litter Various producer organizations implement the extended producer responsibility in Canada. They report
directly to the government, by way of the Environment Ministry. There are multiple collection systems for
household packaging and paper in urban areas across the country169. Some provinces apply a deposit return
system for the collection of single-use beverage packaging. Currently six out of the ten Canadian provinces
have their own deposit return system for all beverage packaging, except milk. The annual report of the Center
For Marine Conservation170 showed that the share of beverage packaging in litter on beaches is lower in
provinces with a deposit return system (7%) than in provinces without one. (19%). In provinces with a deposit
return system, the share of beverage packaging in litter dropped by 70-84%, and the total amount of litter
dropped by 34- 47%.
168 The Lithuanian government set a recycling target of 65% for the system. 169 Giroux L. (2014). State of Waste Management in Canada. Kanata: Canadian Council of Ministers of Environment. 170 Sheavly S.B. (1997). 1995 International Coastal Cleanup. Washington: Center For Marine Conservation.
53
Chapter 6: Ten recommendations for a better packaging waste policy in Belgium
Based on the previous chapters, Recover concludes that we need a system that places full responsibility with
the producers. The social consequences of packaging in residual waste and litter are underestimated. If we
want to evolve towards a circular economy, we need more and better policy instruments. To implement an
adequate and fair policy, we must also base ourselves on the right numbers. We have summarised these
conclusions in ten specific policy recommendations.
1 More ambition and higher objectives
Collection and recycling targets
Recover notes that the producers easily achieve the legal recycling targets every year. Imposing recycling
targets that are lower than the results they already achieve sends the wrong message to the parties
responsible for packaging. Moreover, the EU recently approved a new Packaging and Packaging Waste
Directive, with new targets in terms of reuse and recycling. According to this Directive, 50% of all plastic
packaging must be reused or recycled by 2025. By 2030, this rate must increase to 55% (Table 8). In addition,
the various types of materials (e.g. plastics) must be sufficiently distinguished. Recover suggests the following:
• Impose higher collection and recycling targets for every fraction and material (Table 8);
• Collect and recycle 90% of all single-use beverage packaging by 2022.
Table 8: Collection and recycling targets according to Directive 2018/852 and Recover’s recommendations
EU Cooperation agreement (Recover)
By 2025 By 2030 By 2025 By 2030
All packaging
65% 70% 90% 95%
Glass 70% 75% 95% 95%
Paper and cardboard
75% 85% 90% 95%
Drinks cartons
/ / 90% 95%
Ferrous metals
70% 80% 90% 95%
Aluminium 50% 60% 90% 95%
Plastic 50% 55% 90% (HDPE, PET) 95% (HDPE, PET)
Other plastics
/ / 50% 55%
Wood 25% 30% 80% 85%
Targets for public cleanliness
The targets for public cleanliness are insufficiently substantiated as well and should be tightened. The local
governments strive to offer residents and visitors a clean public space. Recover commissioned a study from
KplusV about the desired policy goals171, which the local authorities deem feasible under the current policy
efforts in the short to medium term.
• The targets must allow to decrease the problem in the short and long term.
171 KplusV, 2018. Maatschappelijke kosten verpakkingen in zwerfvuil in Vlaanderen. Brussel: Recover.
54
• The target must also be raised for litter, and adapted to the municipality’s soco-economic situation.
• The target for litter must be a formula for achievably clean streets.
2 More separate collection of packaging
The real collection and recycling figures show that there is a long way to go to improve the collection of
packaging waste. In Flanders, less than two thirds of all metal packaging (61.7%) and only one third of all plastic
packaging (33.7%) is collected for recycling. A large part of the remaining plastic and metal packaging ends up
in the residual waste fraction (household waste and municipal waste) and consequently in waste incinerators.
Valuable raw materials are lost as a result. On top of that, a certain volume remains on the streets or in nature.
Separate collection is important in the framework of the circular economy. Various policy measures are a
means of increasing the collection rate, and consequently the recycling rate. Thus Recover suggests the
following:
• The extension from PMD to the separate collection of all plastic packaging.
• The introduction of a deposit return system for single-use (drinks) packaging that are susceptible to
on-the-go consumption.
Deposit
There is growing support for a deposit return system in Flanders. Research by the consumer organization Test
Aankoop shows that 66% of the respondents are in favour of a deposit return system for plastic bottles and
cans. In November 2017, the Statiegeldalliantie was founded to urge the Government of Flanders to introduce
a deposit return system as soon as possible. In June 2018, 165 Flemish local governments had signed up. But
generally speaking, stakeholders’ opinion is divided. Recover’s international study shows that countries with a
deposit return system achieve striking results in terms of collection and the quality of their recycling process. In
Norway, for example, 96% of all packaging with a deposit is returned and 80% of all PET bottles is recycled into
new bottles. Recover notes that a deposit return system has social advantages and hardly any disadvantages,
based on the studies that were conducted.
Social advantages Social disadvantages
Increased collection and recycling of packaging
which currently ends up in the residual waste
fraction
Cost of the scheme172
High-quality recycling thanks to high purity
Cleaner streets
Application of the ‘polluter pays’ principle
Local authorities can economise on the cleaning of
litter and the emptying of rubbish bins
Better follow-up of the materials flow
Recover makes the following recommendations:
• Simultaneous introduction of a deposit return system in all three regions of Belgium;
• The deposit must be high enough to sufficiently stimulate consumers to return packaging to the take-
back points;
• Adequate compensation for traders in the form of a handling fee;
172 In 2015, the Flemish public waste agency OVAM calculated that a deposit return system would cost up to 77 million euros.
55
• Sufficient deposit opportunities for the public;
• Conduct further research into a deposit return system for other products (non-beverage packaging)173
which are susceptible to become litter.
Simultaneous introduction of extended PMD-collection and deposit return system
Some organizations feel that a deposit return system would undermine the PMD collection system, which “has
already proven that it works”. By examining the situation in other countries, we learn that the two systems can
exist alongside each other174. Recover recommends conducting further research into a future scenario for
Belgium, based on the simultaneous introduction of these two systems. In the framework of this
recommendation, the existing studies, commissioned in the past by OVAM and Fost Plus, can be used as a data
source. VITO conducted a review175 for Recover (1) to determine to which extent these studies contain data
that can be used to combine all the information into a possible scenario for the future and (2) establish an
overview of the missing data. VITO came to the following recommendations:
• The yields for plastic packaging that falls under the deposit return system are higher than in the p+md
study. This can be explained by the fact that these fractions are purer;
• The two studies provide a good starting point for a scenario for the future, but some data are lacking
nonetheless;
• There are no data available on the further processing of sorted fractions;
• Nor is there data about the current collection and sorting of mixed plastics.
3 More emphasis on high-quality recycling
During the studies that were conducted, Recover noticed that the current policy instruments insufficiently
encourage companies to design sustainable packaging, or adapt their packaging strategy. The current
performance in terms of packaging waste management is merely based on the figures that Fost Plus reports.
These do not provide information about the underlying quality of the recycling process. In fact, the conclusion
is that most waste streams are recycled as low-grade recyclate (see Chapter 4 - 2.2). If we want to keep raw
materials in the economy as much as possible, we must take into account the quality of the recycling process in
our current recycling targets. Promoting the use of recycled materials benefits the circular economy. One way
of achieving this by means of a policy instrument, is to impose the use of recycled content on producers.
OVAM176 mapped the potential local market for plastic recyclate. The study showed that there are a large to
very large number of companies that sell products with recycled content plastics for plastic packaging.
Depending on the application, a target value of 30-100% recyclate can be achieved in plastics. Bar-le-Duc, a
Dutch water brand, produces bottles from 100% recycled PET. The company uses the PET bottles that are
collected in the Netherlands through the deposit return system as a raw material177. Bottle-to-bottle is
therefore technically feasible. Recover draws on the Arcadis study for this, and has formulated a number of
suggested changes to the Interregional Cooperation Agreement:
• The introduction of definitions for circular economy and downcycling;
• The addition of targets regarding the quality and nature of recycling to close loops;
• Downcycling should be avoided as much as possible in this framework;
173 E.g., pizza boxes, hamburger boxes, etc. 174 Most countries that have a deposit return system also have a separate collection for other waste streams. 175 VITO, 2018. Review van studies over de waardeketen van huishoudelijke verpakkingen in Vlaanderen. Brussel: Recover. 176 OVAM (2017). Identificeren van product(groep)en met kunststofrecyclaat (recycled content) en product(groep)en met potentieel voor het inzetten van kunststofrecyclaat. 177 http://www.bar-le-duc.nl/
56
• The IVC should develop a method to distinguish between high-quality and low-grade recycling and
conduct controls;
• A ban on single-use packaging that complicate sorting and recycling;
• When using recyclate, the closing of the own loops for every product type must be taken into
account;
• Promote pure streams during the separate collection of packaging waste (e.g. through improved eco-
design and standardisation).
Policy on raw materials and sustainable materials management in the production of packaging material is a
federal competence and can be regulated by imposing a minimum recycled content. The following conditions
can be used to apply the principle of minimum recycled content in the current legislation:
• The introduction of compulsory product standards for the use of recycled materials in packaging,
including the formulation of feasible targets for recycled content in the short and long term per
material;
• The introduction of a bonus-malus system for the use of recycled material. The producer is assigned a
bonus value for the use of any recyclate that exceeds the targets and a malus when the use of
recyclate is under the target;
• Promoting recycled material with subsidies;
• Applying a regulating tax when using primary material when equivalent secondary material is
available;
• Reporting and communication obligation through product certification. The certification
organizations should be accredited by the authorities;
• The packaging may not be harmful for humans and the environment. This means the product is
REACH-compliant.
4 Increased research on the impact of packaging
The effects of some packaging solutions are insufficiently studied. A good example is the hype around
bioplastics, biodegradable plastics or compostable plastics. There is a lot of confusion about these terms and
their significance. This creates a lot of ambiguity for consumers. Literature shows that biodegradable plastics
are not a solution to the issues of plastics or litter. On the contrary, the public is convinced that the packaging
may be disposed of freely. In nature, these plastics fragment into small particles, so-called microplastics, which
can have a detrimental effect on fresh water and marine ecosystems.
In addition, biodegradable plastics cannot be recycled together with ordinary plastics, as they disrupt the
recycling processes. The only way to process compostable plastics is in an industrial composting plant. Another
disadvantage is that biodegradable plastic is not completely broken down during the composting process,
causing (micro)plastics to remain in the environment.
Non-degradable plastic, made from renewable raw materials, however, is suited for recycling. But here too
Recover has its doubts about the added value of this material for the environment. Recover concludes that the
potential environmental effects cannot be fully determined and that the policy pertaining to some plastics
must be updated to reflect this.
• Research and innovation are necessary to develop plastics that are biodegradable in various
environments, in a time frame that the particles do not accumulate in the soil or the oceans;
• Take measures, through eco-design, to reduce the harmfulness of packaging waste;
• Tighten the certification process for bioplastics, by conducting tests that guarantee 100%
degradability;
• Conduct further research into the lifecycle of each type of packaging;
57
• Ban biodegradable plastic for packaging that is prone to be littered.
5 Invest more in eco-design
Producers do not sufficiently take the waste phase of packaging into account. In Flanders they are insufficiently
encouraged to place packaging on the market within a circular economy approach. The green dot tariffs are
insufficiently tailored to eco-design. Countries such as France emphasise the ecomodulation principle more
than Belgium, encouraging companies to use recyclable packaging.
Recover makes the following policy recommendations:
• Phasing out of packaging that disrupts the current sorting and recycling process. In the short term, this
involves the introduction of ecomodulation (following the example of the French system). In the long
term, there should be a ban on non-circular packaging;
• Develop standards for packaging to facilitate cooperation between companies;
• Raising awareness about eco-design, as a task for the parties responsible for packaging and their
organizations.
6 Full responsibility of producers
Currently packaging producers only pay for the separate collection of certain fractions. Their goal is to achieve
the recycling targets at the lowest cost. Some local authorities feel that this fee does not cover the actual cost,
even within this limitation, as evidenced by a survey conducted by a group of students. In addition to this, Fost
Plus has been paying 9.6 million euros every year to help combat litter. This amount is disproportionate to the
responsibility of their members in the cleaned up litter. Recover requests the following:
• Full financial responsibility for the collection and processing of all types of packaging;
• Full financial responsibility for packaging that does not find its way into the separate waste streams,
such as litter, household waste, on-street garbage bins;
• Internalisation of the environmental effects178.
7 Better map the materials flow
Reporting Obligation The Interregional Packaging Commission approves the results in terms of recycling and the recovery of
packaging waste and reports them to the European Commission (Eurostat). This reporting complies with
European rules but does not paint an accurate picture of the actual situation for recycling. The current
calculation overestimates the collection and recycling figures, meaning targets are easily achieved. Recover
suggests tightening the reporting obligation for parties responsible for packaging to have a more accurate idea
of what is effectively recycled. The following changes must be made to the method for calculating the recycling
rates.
Denominator:
• All packaging that is placed on the Belgian market (=correction of freeriders)
• Correction for purchases done abroad (import of non-accounted packaging)
Numerator:
• Adjustment for remnant dirt and liquids
178 Indirect costs of packaging in residual waste (municipal waste, household waste and fly-tipping) and litter that is not cleaned up.
58
• Correction for recycling losses
• Do not count non-packaging (e.g. non packaging metal recovered at waste incinerators)
More monitoring and research The packaging waste that is not collected via the separate collection streams ends up in the residual waste
fraction. A waste analysis, conducted by the Flemish Public Waste Agency OVAM, showed that packaging waste
on average accounts for 27.8% of household waste that is not collected separately. Various information sources
show that beverage packaging account for 20-30% of the weight of litter. Most sources refer to beverage
packaging but we relied on the count of different waste fractions, conducted by Vander Linden (2018) for
Limburg.net to calculate the share of packaging in litter. This waste analysis showed that the total weight share
of packaging in litter was 57% and the share in volume 69.9%. Currently there are no data about the packaging
that is not cleaned up and remains in nature. We notice that there is no continuity in the method and the
periodicity of the various measurements. Monitoring is vital if we wish to check the impact and the progress of
measures to promote prevention and collection. This is the only option for a correct evaluation and adjustment
of the current policy measures. Recover suggests the following;
• Research into the materials flow of packaging per material. Effective annual reporting in the form
of a clear mass balance is necessary;
• Waste analysis for waste streams that do not completely consist of packaging, such as scrap from
incinerators, biennial waste analysis of the household bin bag, biennial analysis of the separately-
collected cardboard and paper fraction.
At the request of Recover, KplusV conducted a study into the social cost of litter. Limited data were made
available for some calculations. Recover suggests conducting a follow-up study into the social cost of litter, with
the following recommendations:
- Biennial study into the policy cost of litter and the cleanliness index for the same group of
municipalities, representative for Flanders. This could establish a link between the cost and a
cleanliness policy;
- Representative biennial fraction count of the materials that make up litter and the contents of
household bin bags, distinguishing between packaging and non-packaging, including weight and
volume measurements;
- Research into the most frequently occurring products that are susceptible to become litter;
- Further research into the amount of litter that is not cleaned up;
- Map policy efficiency with a qualitative study, representative for all Flemish municipalities;
- Further research into the other costs associated with packaging in litter (economic, social,
environmental). We refer to the study KplusV conducted for Recover in this framework. They
formulated a number of recommendations for a follow-up study.
Transparency During the study into the social cost of litter, Recover noted that limited data are available regarding packaging
and litter. The underlying data of the various public documents that were used for this study are managed by
the Flemish Public Waste Agency OVAM or Fost Plus and could not be published. Recover makes the following
recommendation:
• More transparency about data that are relevant for the stakeholders.
59
8 Invest more in prevention
The current policy instruments fail to reduce the amount of generated packaging waste. The amount of
household packaging on the market continues to grow steadily. The current targets for the prevention of
household packaging waste are consequently not achieved. Recover suggests the following:
• Introduction of reuse targets for the short and long term
o 60% of all household packaging must be reusable by 2022,
o 80% of all household packaging must be reusable by 2050;
• Strengthen enforcement of prevention;
• Introduce a bonus-malus system for the product/packaging ratio;
• Ban of single-use plastic bags;
• Stimulate local products179.
9 Increase user-friendliness
Day One conducted a survey, commissioned by Recover, into the ideas and suggestions of citizens for a
different approach to the separate collection of packaging waste. The support for these suggestions is
illustrated in Figure 21.
Figure 21: Support for possible alternative measures
Recover suggests the following in order to increase the user-friendliness of the collection of packaging waste:
• Adapt legislation to stimulate preventive action by parties responsible for packaging;
• Collect glass door to door where required;
• Add a sorting message to all packaging;
• Invest more in enforcement and penalization in the form of fines or an alternative sanction for litterers
and fly-tippers180;
• Standardise new policy measures across all of Flanders (e.g., extension of PMD);
179 Could stimulate reuse and reduce transport of packaging 180 An alternative sanction can consists of community service, requiring the offender to clean up litter for a specific number of hours (max. 120) without pay. Community service can only be imposed by means of an arbitration agreement.
60
• Promote unpacked vegetables and fruit, and by extension other foods such as breakfast cereals.
10 Policy should be in the hands of policymakers
Recover notes that the producers have too much impact on the current packaging waste policy. As a result,
ambitious policy measures are not imposed or producers fail to comply with them. Recover suggests the
following:
• Develop a platform with all the stakeholders, jointly preparing choices in terms of packaging
strategies;
• Conduct further research into a packaging tax instead of extended producer responsibility, whereby
the management of packaging waste is coordinated by the government.
61
Appendix A: Calculation table effective collection and recycling figures
DENOMINATOR NUMERATOR
Belgian market (estimate) 2015
adjustment purchases abroad (x1.05)
Flemish market (estimate) 2015 (x0.5749)
Collected 2015 (Fost Plus)
Collected in Flanders 2015 (Fost Plus figures x 0.5749)
Recover (2018). Materials stream metal packaging
Collection% Flanders
Recycling loss
Recycling rate
Paper and cardboard
216441 227,263 130,654 180,495 103,767
79.4% 10% 71.5%
Paper and cardboard
197551 207,429 119,252 163,807 94,173
79.0% 10% 71.1%
Drinks cartons 18890 19,835 11,403 16,688 9,594
84.1% 10% 75.7%
Glass 326052 342,355 196,821 343,589 197,531
100.4% 5% 95.3%
Plastic 230021 241,522 138,852 81,344 46,765
33.7% 29% 23.9%
Bottles and flasks
88761 93,199 53,581 65,931 37,904
70.7% 29% 50.2%
Metals 78790 82,730 47,562 77,057 44,347 29366 61.7%* 14% 53.1%
Other 5129 5,385 3,096 32 18
0.6%
0.6%
*numerator 29366 tonnes
Appendix B: Prevention within the Interregional Cooperation Agreement and the Packaging Directive
Prevention measure Interregional Cooperation Agreement Packaging Directive
Definition of prevention; dual
emphasis on reduction and on
impact
Art. 2.12 The reduction of the amount
of and the environmental damage
caused by:
a) materials and substances used in
packaging and packaging waste
b) packaging and packaging waste at
the level of the production process and
during the phase in which it is placed
on the market, the distribution, the
use, the recovery and disposal,
especially by developing non-polluting
products and techniques
Art 3.2c
As in the Waste
Framework Directive
Compatible with the
definition in the
Interregional
Cooperation
Agreement
The prevention targets are
semi-quantitative, and aimed at
a reduction of single-use
packaging and the increase of
the share of reusable packaging.
Art 3 §1
1° Prevent and reduce the production
and the harmfulness of packaging
waste.
2°
• share of reusable packaging may not drop
Art 5.1
Member States must
take measures to
encourage the share
of reusable
packaging.
Art 5.5
62
• total weight of single-use packaging must drop.
3° reuse must be promoted
In 2024, the
Commission will
examine the
feasibility of a
quantitative reuse
target
Individual prevention plan for
companies, including self-
imposed quantifiable targets
Art 4 §1
Compulsory for anyone who is
responsible for specific quantities of
single-use packaging.
• Prevention measures
• Prevention measures from the past (Art. 5)
• Quantifiable targets
• Limiting circumstances of a technical, legal or economic nature (Art. 5)
Art. 5, Art. 26 §1.1
Plans are assessed by the IVC
Art. 18 §4.
Every second and third anniversary of
the plan, an evaluation report must be
submitted to the IVC.
Not provided for
under European
legislation - Belgium
is a pioneer.
Sectoral prevention plan, to
replace the individual plan.
Art. 4 §2
A third legal person can take over the
obligation to draw up a prevention
plan for every sector.
Art. 5, Art. 26 §1.1
Plans are evaluated and approved by
the IVC
Art. 18 §4.
Every second and third anniversary of
the plan, an evaluation report must be
submitted to the IVC.
Not provided for
under European
legislation - Belgium
is a pioneer.
Essential requirements for
placing packaging on the
market
Not in the Cooperation Agreement;
federal competence. Is provided for in
the Product Standardisation Act.
Act of 21 December 1998 concerning
product standardisation to promote
sustainable production and consumer
patterns and to protect the
environment, public health and
workers.
Art. 9 and Appendix II
Packaging material
must be minimised
to the requirements
in terms of safety,
hygiene and
consumer
acceptability. I.e., not
to be interpreted as
‘what consumers
would like’, but ‘what
is just barely
63
acceptable for
consumers’.
There are also
several essential
requirements in
terms of qualitative
prevention.
Role of the IVC: promote
prevention by raising
awareness
Art. 4 §3
Actions to promote prevention and
raise awareness must be developed
within the IVC, within the boundaries
of the regional competence.
Art 4.1
(Member States)
must guarantee that
prevention measures
are taken, including
prevention plans,
incentives within EPR
systems, economic
and other measures.
Communication and awareness
to promote prevention
Art. 22
Sellers establish an action plan for
communication to their customers,
including a global message regarding
the prevention of packaging waste.
Art. 13
(Member States)
must take measures
to inform consumers
about a number of
aspects of packaging
waste. While
prevention is not
explicitly mentioned
in this article, reuse
is.
Financing of prevention
campaigns
Art. 13 §1.12
A recognised body for household
packaging waste (Fost Plus) must
contribute to the financing, among
others, of the regional prevention
policy. The region determines how
these funds are used.
Art. 15
(Member States) can
take economic
measures, among
others by applying
the ‘polluter pays’
principle.
Support for prevention Art. 14.4
A recognised body for industrial
packaging waste (Val-I-Pac) must
support smaller industrial consumers
in their prevention efforts with special
campaigns.
Specific Belgian
measure.
64
Appendix C Results Day One study
1. Score for the question: how easy do you think this type of waste is to sort? 1 is the lowest score and 5 the
highest.
(Note: in this figure: “glas” stands for “glass”; “papier/karton” is “paper and cardboard” en “KGA” is the Flemish
abbreviation for “hazardous household waste”)
8,0%
4,8%
18,6%
11,8%
19,1%
18,5%
18,8%
20,8%
27,5%
15,0%
64,6%73,5%
43,2%
54,8%
40,8%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Glas Papier/Karton Plastics PMD KGA
5
4
3
2
1
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Appendix D Results count of different fractions in litter, commissioned by Limburg.net
(Note fractions can be translated as follows:
Folies: plastic films
Glas drank: glass bottles
Metaal drankverp: metal beverage containers
Kunststof niet-verp: plastic non-packaging
Kunststof drankfles: plastic bottle
Papier/K verp: paper/cardboard packaging
Papier/K niet-verp: paper/cardboard non packaging
Organisch zwerfvuil: organic litter waste
Drankinhoud: liquids (drinks)
Steen: stone
Kunstst verp (niet-PMD): plastic packaging other than PMD
Textiel: textiles
Metaal niet-verp: metal non packaging
Rest: residual waste
Glas verp: glass packaging other than bottles
Hout en kurk: wood and cork
Metalen verp: metal packaging other than beverage packaging
Elektronica: electronics
Hygiene: diapers
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Glas niet-verp: glass non-packaging
KGA: household hazardous waste
Kunststof flessen en flacons: plastic flasks, non beverage
Drankkartons: drink cartons
Peuken: cigarette butts
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Addendum to the report “Towards a better policy for packaging waste in Flanders, Recover (2018)”
In the report “Towards a better policy for packaging waste in Flanders”, Chapter 5 gives an overview of the
financial compensations for local authorities that are set out in the accreditation of Fost Plus, valid for the years
2014-2018. On 29 June 2018, Fost Plus submitted a new application to be accredited as an organism for the
management of
household packaging waste for the period 2019-2023. The results of the Recover study where used by
Interafval to advise the Interregional Packaging Waste Commission of Belgium (IVC) on the application for a
new accreditation. On 20 December 2018, Fost Plus was granted a new accreditation for the period from 1
January 2019 to 31 December 2023. We list the main changes of the new accreditation, compared to the
previous one:
• Introduction of extended PMD-collection The new accreditation sets a timing for the introduction of an extended PMD-collection. In the timing is
foreseen that by the end of 2020, all Belgian households should be able to put all plastic packaging in the blue
collection bag. Plastic packaging is no longer limited to plastic bottles and flasks. The new accreditation puts an
end to the bonus-malus arrangement for the residue in the blue collection bag. Fost Plus has to monitor the
composition of the sorting residue of P+MD waste.
The new accreditation clarifies the new sorting message for the citizens. The sorting message is meant to be
simple and as uniform as possible. To evaluate the sorting message, a working group consisting of Fost Plus, IVC
and involved organizations including the federations representing the waste management companies, should
be set up.
• New calculation rules for metal packaging waste Fost Plus has to adapt the new calculation method of the European Commission for the recycling rates181.
Therefore, in the future, Fost plus can no longer take the non-packaging metals recovered at waste incinerators
into account for the calculation of the recycling rates.
• Financing rules for collection by public authorities The basic scenarios have been updated to include the collection of additional plastics, underground collection
and a higher frequency of collection. A working group, consisting of Fost Plus, IVC and involved organizations,
will develop a new calculation method for the reference cost for the collection schemes that are not approved
as a base scenario. When the intermunicipal organization collects with own staff and trucks, Fost Plus has to
pay a negotiated fee. Fost Plus cannot refuse the costs that are proven by the (inter)municipal association.
• Additional financial support The new accreditation provides a compensation for the purchase of individual containers for the collection of
paper and cardboard and installation of underground bottle banks. Also, the new accreditation introduces an
additional fee of €3000 per year for every civic amenity site, whereby Fost Plus intervenes in the operational
costs of the sites.
From 2021 onwards, Fost Plus will have to contribute to the collection of hazardous household waste at civic
amenity sites.
• Rules for green dot tariffs In order to introduce the principle of eco-modulation, the new accreditation provides new rules for green dot
tariffs. From 2021, packaging that interferes with recycling and/or sorting should pay a double rate for Green
181 COMMISSION IMPLEMENTING DECISION (EU) 2019/665 of 17 April 2019 amending Decision 2005/270/EC establishing the formats relating to the database system pursuant to European Parliament and Council Directive 94/62/EC on packaging and packaging waste.
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Dot contribution. In this context, a working group on "materials” will identify the packaging that disrupts the
current sorting and recycling process.
• Targets for out of home collection The new accreditation imposes targets for out of home collection of packaging waste. By 2023, the amount of
separate collected packaging waste from out of home consumption must be doubled. Fost Plus has to collect at
least 26,000 tonnes of PMD from out-of-home consumption with particular attention to on-the-go
consumption.
