Environmental compliance… the latest developments

What are the latest developments concerning environmental legislation globally? We’ve picked out some highlights for you for September 2021.

European Commission working on new study on freeriding in online sales

The European Commission has commissioned a new study to support the implementation of the revised Waste Framework Directive with regard to online sales. The consulting firms, Eunomia and Milieu, are conducting the study, which will propose measures to improve compliance with extended producer responsibility (EPR) requirements and combat freeriding.

The Commission’s mandate calls for extensive stakeholder consultations as part of the study. Five initial workshops were held in July to discuss existing barriers to compliance with EPR regulations and possible solutions. The workshops were attended by a few selected stakeholders, including Landbell Group company European Recycling Platform.

The workshops will continue in September. The study will then seek broader stakeholder participation. Completion of the study is planned for March 2022.

EU Battery Regulation: JRC proposes new calculation method for collection targets

As part of the ongoing review of the Battery Regulation, the European Commission’s Joint Research Centre (JRC) has published a new study examining alternative collection targets for waste portable batteries.

The study concludes that, given the increasing durability of portable batteries, the gap between the amount of batteries put on market and the amount of batteries available for collection will increase significantly in the coming years. As a result, the proposed collection targets, which are based on the put on market volumes of the three preceding years, would be disproportionately high. Therefore, it makes sense to consider alternative calculation methods that take into account the amount of batteries actually available for collection – for portable batteries and the newly in scope batteries for light means of transport.

Landbell Group company European Recycling Platform (ERP) agrees that the calculation method urgently needs to be adjusted, otherwise the new collection targets will not be achievable. ERP had already made this point in a detailed position paper on the Commission’s legislative proposal in March.

Based on this paper, ERP has recently developed concrete proposals for amendments and sent them to the relevant members of the European Parliament as well as representatives of the member states.

In this amended paper, ERP proposes among others:

• a revision of the collection targets,
• a change in the definitions of terms such as portable and industrial batteries, and
• amended conditions for producer responsibility organisations’ authorisations.

The final plenary vote on the new Battery Regulation in the European Parliament is scheduled for February 2022.

Industry calls for harmonised packaging labelling

In a joint letter to leading members of the European Commission, representatives of the packaging industry and consumer product manufacturers have called for a harmonised approach towards packaging labelling and information requirements in the European Union.

According to the signatories, the current trend for diverging measures in member states could lead to major disruptions of the single market and could undermine Europe’s sustainability goals. To preserve the free movement of goods in the European Union, they argue that concrete and urgent action is needed.

National labelling and information requirements could force companies to create several versions of their packaging or use stickers to add to or cover certain markings. This would have negative impacts on costs, and the size of the packaging and its recyclability.

The industry representatives call on the Commission to leverage the ongoing revision of the Packaging Directive and the implementation of the Waste Framework Directive. They also ask the Commission to ensure timely and constructive cooperation between member states in resolving any single market incompatibilities raised by their respective national measures.

ZSVR to revise criteria on scheme membership

Germany’s Central Agency Packaging Register (Zentrale Stelle Verpackungsregister or ZSVR) has completed a consultation on the 2021 edition of its scheme membership requirement catalogue. First published in 2018, the catalogue and its product groups have since been regularly updated.

The catalogue allows producers to quickly and easily determine whether their packaging is subject to scheme membership. According to the German Packaging Law (Verpackungsgesetz or VerpackG), producers are responsible for ensuring that their packaging is classified correctly and, if necessary, contracted with a packaging scheme.

The draft version of the catalogue consists of 39 product sheets which can be viewed and downloaded from the ZSVR website’s consultation procedures section, including new and amended products.

Stakeholders had until Wednesday, 8 September 2021 to comment on the draft.

After the consultation period, the catalogue will be revised and voted on again. The final version is expected to be published on the ZSVR website in autumn (replacing the current catalogue).

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