Lone Mikkelsen, seniorrådgiver i Rådet for Grøn Omstilling har indgivet kommentarer til Kommissionens køreplan for reviderede regler om reduktion af emballageaffald. Kommentarerne er på engelsk.

Green Transition Denmark comments on the European Commission roadmap on ’Reducing packaging waste – review of rules’

In Green Transition Denmark, we clearly support circular economy and the thought that waste is reduced and goods are re-used and recycled as much as possible. However, it is very important to be aware of the limitations – hazardous chemicals. This can in many cases be a big problem, e.g. when old goods with a content of chemicals that that are not allowed today are being recycled or goods are recycles to other types of goods with higher requirements for chemical content. We have seen examples where children’s toys made of recycled plastic contained extreme levels of hazardous chemicals, e.g. dioxins. Dioxins are considered to be some of the world’s most toxic chemicals and are extremely harmful even in very small quantities at a few tenths of a picogram per gram. Some of the toys examined contained thousands of times this amount. Brominated dioxins affect the brain’s development, damage the immune system and increase the risk of cancer.

Therefore, when talking circular economy, it is very important to strictly keep waste containing hazardous chemicals out of the circular economy loop. This further leads to the importance of banning chemicals that are today a barrier for the circular economy to be fully implemented.

We need to use taxes and fees to push industry and companies in the right direction. Historically we know, that voluntary efforts do not work – fees and taxes does. In part C in the Roadmap under ‘Likely economic impacts’ it suggests that ‘businesses that adapt to the new requirements could be rewarded through lower extended producer responsibility fees..’. But it should be the other way around, that businesses that do not adapt should pay higher extended producer responsibility fees.

It is important not only to focus on circular economy as in recycling of waste. Instead, most importantly, we need to lower production and use of packaging and wrappings. Hereafter, we need smarter designs, to be able to reuse more directly (e.g. through a deposit and return system – like the Danish model). Lastly, if not possible to reuse, then we need designs that makes the packaging and wrappings recyclable (the Danish Plastics Federation, together with other Danish organisations, has developed a design guide for reuse and recyclability.)

Moreover, it is important to keep the high-quality plastics (like food contact materials) in the top of the loop, so it is not mixed with low quality or contaminated plastics (e.g. from cleaning agents) that are unsuitable to recycle to high quality materials. In the worst-case scenario, all the high-quality plastics ends like flowerpots and road cones.

The possibility to sort high quality plastics separately should be further investigated.