Europen, the European Organisation for Packaging and the Environment, has written an open letter to the European Parliament and Council urging them to reconsider recently announced plans to introduce a “rigid” five-step waste management hierarchy.
A letter from the Brussels-based packaging and environmental lobbying group supported by nine other industry organisations argues that introducing such a hierarchy into Europe’s framework legislation on waste would “contradict the current waste management practices of many progressive cities and regions of Europe, rendering then open to legal challenge”. Europen says, furthermore, that so far no scientific evidence has established the case for a “strict hierarchy” between reuse, recycling and other recovery options. “Indeed,” it argues, “numerous well-founded studies show selecting the best option depends critically on the particular circumstances relating to a product chain”.
Stressing the organisation’s view that a hierarchy would be “unworkable in practice and would not bring any additional environmental benefits, Europen md Julian Carroll says: “Scientific studies and basic principles of EU law such as proportionality and equal treatment within the internal market all point towards maintaining the current EU policy and European Commission proposals on the matter. That means placing prevention as the highest priority, final disposal as the least favoured option and keeping a flexible approach to the choice of recovery options.”
Europen says a survey this July by FFact Management Consultants demonstrates that flexible use of the waste management hierarchy is proving the best approach in cities such as Amsterdam, Bordeaux, Strasbourg and Vienna, by “allowing local situations and options to be take into account”. In Amsterdam, for instance, local authorities may decide to abandon separate collection of biowaste after performing a lifecycle analysis which Europen says revealed “only a marginal environmental advantage in composting rather than incinerating with energy recovery”. “In the light of this,” says Caroll, “the Dutch government has acknowledged the need for flexibility.”
Europen also claims any derogation procedure from a rigid hierarchy, which it believes would be essential to preserve the local solutions currently working in many European cities, would “place a huge bureaucratic and cost burden on industry and Member States, with negative consequences for European competitiveness”.
The nine organisations that endorsed Europen’s letter are: the Alliance for Beverage Cartons and the Environment, the European Brands Association, Beverage Can Makers in Europe, the Confederation of the Food & Drink Industries of the EU, the European Federation of Bottled Water, Euro Commerce, the European Federation of Corrugated Board Manufacturers, PlasticsEurope, and the European SoftDrinks Industry.