Calculation, verification and reporting of data on the separate collection of SUP beverage bottles

The REMONDIS Group is one of Europe’s largest recycling, service and water companies. We collect, sort and recycle plastic packaging from different sources. That includes mixed recyclables from EPR systems, and drinks packaging from the German deposit refund scheme.

The Bundesverband der Deutschen Entsorgungs-, Wasser- und Rohstoffwirtschaft (BDE) welcomes clarification and guidelines regarding the calculation, verification and reporting of data on the separate collection of waste single-use plastic beverage bottles to ensure efficient implementation of the SUPD. Due to late notice of this consultation we unfotunately have not had time to properly consult our membership.

Natural Mineral Waters Europe (NMWE) welcomes the development of the draft Implementing Decision in order to ensure correct implementation of Article 9 SUPD on setting separate collection targets for beverage bottles.

PET is light, versatile, shatter-free and easily recyclable. Naturally more and more people are getting convinced of its intrinsic value as a packaging solution of choice, especially in a circular economy. PET can even get recycled up to 5-6 times mechanically. Moreover, PET has an extremely low carbon footprint making it a true green packaging champion. We need therefore qualitative primary material.

FNADE: position paper on SUP directive implementing act proposal FNADE, the French Waste Management association would like to take the opportunity to make some comments regarding the European Commission’s proposal on SUP directive guidelines: First, in the draft proposal the word “collection” in article 2, paragraph7 seems misused and seems to correspond more to “recycling”.

Oceana welcomes the separate collection targets laid out in Article 9 of Directive (EU) 2019/904 that apply to beverage bottles with a capacity of up to three litres, including their caps and lids. These targets establish that by 2025, Member States shall take the necessary measures to ensure the separate collection of an amount of waste single-use plastic bottles equal to 77 % of such single-use plastic products…

Together with many other organisations, Recycling Netwerk Benelux supports a detailed response to the Draft Implementing Decision which will be submitted by Reloop. In what follows below we wish to bring to your attention what our concerns are for in particular Belgium where there is an ongoing debate about the best method to collect single use plastic bottles.

The Sociedade Ponto Verde (SPV), as the managing body (EG) of the Integrated Packaging Waste Management System (SIGRE), intends to contribute to the revision of the framework legislation for the waste and packaging sector in particular, which is strategic for the sector over the next decade.

Filed in Portuguese · English published by the European Commission

The European Recyclers’ Industry Confederation (EuRIC) welcomes this draft Implementing Decision regarding the calculation, verification and reporting of data on the separate collection of waste single-use plastic beverage bottles. Unfortunately we received notice of this consultation late and have not had time to properly consult our membership.

My main concerns are as follows: a) notwithstanding the attempt to make this clear in the wording of Paragraph 2(4)(b), the wording of the Draft Implementing Decision might still, possibly, be interpreted as allowing for the inclusion, within the definition of what is separately collected, single use plastic beverage bottles which are sorted from what is typically described as 'residual waste', or 'mixed waste'.

CONAI, the Italian National Packaging Consortium, is a private non-profit entity which gathers more than 700 thousand companies to ensure a sustainable and circular management of waste packaging in the EPR regulatory framework.

COREPLA, the main Italian EPR scheme dealing with recovery and recycling of plastic packaging waste, is a private non-profit entity which undertakes EPR obligations on behalf of more than 2500 companies ensuring a sustainable and circular management of plastic packaging waste.

We call on the European Commission and national authorities to provide more clarification of certain provisions of the draft Decision which, in their current format, would significantly undermine the intent of the Directive.

The Rethink Plastic alliance welcomes the opportunity to provide feedback on the draft implementing act. The alliance would like to highlight that it is critical that the definition of "separate collection" is in line with the Waste Framework Directive and that the implementing act clearly states that waste splitting/post-sorting of bottles after residual waste mixed collection is not separate collection.

Packaging Recovery Organisations, including the 27 members represented by the Extended Producer Responsibility Alliance (EXPRA) as well as CITEO and Altstoff Recycling Austria AG (ARA), would like to comment on the proposed methodology for the determination of the weight of separately collected waste single-use bottles (Article 2 of the draft Implementing Act).

The objective of Article 9 SUPD is the separate collection of plastic bottles in order to ensure that they don’t end up in the open environment. Putting an end to plastic pollution of SUP products is one of the main parts of the Plastic Strategy’s vision.

Greenpeace Austria thanks for the opportunity to comment on the draft implementing decision laying down rules for the application of Article 9 SUPD on setting separate collection targets for beverage bottles. We call on the European Commission to provide more clarification of certain provisions of the draft Decision which, in their current format, would significantly undermine the intent of the Directive.

Objective 1. Reduce the amount of bottles in the environment. 2. To increase the quality of the material obtained in order to increase the availability of food grade PET. I certainly see this as a big step backwards. Questions. 1.There should be a requirement to collect only PET bottles for beverages and not to collect them with other streams.

Filed in Spanish · English published by the European Commission

Infinitum’s feedback to the EU Commission’s proposal towards “Recycling – EU rules on calculating, verifying and reporting data on separate collection of single-use plastic bottles”. Infinitum is the owner and operator of the Norwegian DRS (Deposit Return System) for beverage containers. We handle containers made of plastic (mostly PET bottles but also HDPE) and metal (mostly aluminium cans but also steel).

The objective of Article 9 SUPD is the seperate collection of plastic bottles in order to ensure that they don’t end up littered in the environment. Putting an end to littering of SUP products is one of the main parts of the Plastic Strategy’s vision.

No Plastic In My Sea welcomes the development of the draft Implementing Decision in order to ensure correct implementation of Article 9 of Directive 2019/904 on Single-use Plastics setting separate collection targets for beverage bottles. However, we cannot stress enough the importance of having a more ambitious and precise text than this draft to have efficient and clean recycling channels.

GLOBAL 2000 (Friends of the Earth Austria) is pleased to have the opportunity to comment on this draft Implementing Act. The long-awaited draft plays an overriding role for the circular economy and in what form resources and the environment will be conserved. It is the great task of our time to curb our extremely high consumption of resources and the littering of nature.

• Strict requirements for the quality of the material, even if it is collected together with other recyclables, so that closed-loop bottle-to-bottle recycling is still possible: SUP bottles should be collected in a way that allows recycling into foodgrade material • It should be very strictly stated that bottles should not be collected with hazardous waste/contaminated materials, and such a requirement should also…

It is our view that the current draft Implementing Act contains vague and unclear terminology, leaving room for interpretation which in turn could have negative consequences. For instance, this includes the definition of how bottles can be collected for recycling, terms with regards to quality control (“like skilled personnel”), there being no clear statement on quality aspect and no explicit phrasing clearly…

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the drafted implementing decision laying down rules for the application of Directive (EU) 2019/904 (SUPD) as regards the calculation, verification, and reporting of data on the separate collection of waste single-use plastic beverage bottles.

The objective of Article 9 SUPD is the seperate collection of plastic bottles in order to ensure that they don’t end up littered in the environment and the evidence shows that the only way to achieve viable and long-term 90% separate collection rates is through mandatory Deposit Return Systems.

Interafval is 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. We appreciate the opportunity to give feedback on the draft EU calculation rules on separate collection of single-use plastic bottles.

Citeo welcomes that the new draft implementing decision makes clear that the comparability criteria apply to all collected bottles and not only to bottles collected in co-mingled collection systems and does no longer require cross-checks and the characterisation of non-targeted material and other substances.

We, as Comuni Virtuosi, the IT national association of virtuous (green) municipalities support and signed the position paper released by Reloop which already includes our full contribution. In addition just few lines to state that , also in our country, the focus (at both national and local policies), is mainly concentrated on reaching the highest separate waste collections and on massive cleaning up operations, at…

All this is supposed to be aimed at: 1. To reduce the amount of bottles in the environment. 2. To increase the quality of the material obtained in order to have greater availability of food contact grade PET. Certainly, I see this as a giant step backwards. Issues.

Reloop welcomes the development of the draft Implementing Decision in order to ensure correct implementation of Article 9 SUPD on setting separate collection targets for beverage bottles. We are concerned that the current draft is ambiguous, and can be intepreted to include bottles pulled from mix-waste/residual waste.

The Austrian Federal Economic Chamber thanks for the opportunity to comment on the draft implementing decision laying down rules for the application of Directive (EU) 2019/904 of the European Parliament and of the Council as regards the calculation, verification and reporting of data on the separate collection of waste single-use plastic beverage bottles.The full commentary on the drafted Decision is attached.

At the level of the beverage retail sector, the proposed data collection on the weight of returned bottles is not possible. It would be necessary to facilitate the collection of data on the volumes of bottles returned by final consumers at the clearing houses of the RVM manufacturers or deposit-refund companies such as DPG, EPG and others. These processes are already largely automatic.

Filed in German · English published by the European Commission

From ZERO's point of view it will be very important that strict requirements for the quality of the material are set, even in the cases where plastic botles are collected together with other recyclables, so that closed-loop bottle-to-bottle recycling is still possible.

TOMRA has, like many other stakeholders who are interested in a high level Circular Economy and the avoidance of litter at source rather than cleaning up afterwards, supported and signed the position paper of Brussels based not-for-profit organization Reloop. Insofar we would like to refer to Reloop´s contribution.

The objective of Article 9 SUPD is the seperate collection of plastic bottles in order to ensure that they don’t end up littered in the environment. Putting an end to littering of SUP products is one of the main parts of the Plastic Strategy’s vision.

We must have a definition that aligns with what the Waste Framework Directive defines as SEPARATE COLLECTION to avoid a precedent for future misalignment. Waste splitting of residual waste MUST clearly be EXCLUDED: A collection with the residual waste, mixed waste, black bin, etc. should be banned from being counted as separate collection of SUP bottles for recycling.

EKO-KOM, a.s. is the sole Packaging Recovery Organization (PRO) in the Czech Republic providing EPR services to over 21 thousand enterprises placing packaging on Czech market and assuring its separate collection and recycling within 6160 municipalities covering 99 % of the Czech population. The full commentary on the drafted Decision is attached to this feedback. Only the core of the commentary is provided below.

Brief note on the proposal for a European Commission Decision “establishing rules for the implementation of Directive (EU) 2019/904 of the Parliament and the Council that regards the calculation, verification and reporting of data on the separate collection of waste of single-use plastic bottles for beverages”. This Decision is provided for in art.