Current EU regulation for recycling food packaging waste
The European Packaging and Packaging Waste Directive 94/62/EC obligates member states to meet targets for the recovery and recycling of packaging waste. By 31 December 2025 a minimum of 65% (by weight) of all packaging waste should be recycled. Member states must also ensure that Extended Producer Responsibility (EPR) schemes, which encompass food packaging, are established by 31 December 2024.
However, this Directive does not cover recycling logos and there are no harmonised standards for recycling labelling in the EU at present. This makes it difficult for food and beverage companies to label products effectively and prevent consumers from being well informed on the best way to dispose of packaging. In many cases, consumers do not fully understand which types of food packaging are recyclable. There is also the issue of ‘wishful recycling’ where all packaging is disposed of in recycling bins, resulting in the contamination of recycling streams.
Recycling logos
Logos are widely regarded as a clear and effective way to convey information to consumers, and mandatory recycling logos are emerging to promote and encourage good practice. Several EU member states and the UK have developed their own recycling logo initiatives, but this has led to confusion amongst food and beverage companies who trade in multiple countries. The following examples indicate some of the challenges faced.
France – mandatory recycling logo and waste disposal instructions
France introduced the mandatory Triman Logo in 2015. However, it can be confused with the Green Dot logo which denotes a manufacturer’s financial contribution to the collection, sorting and recovery of used packaging in the EU.
To overcome this issue, France banned the Green Dot which in turn caused difficulties for food and beverage companies selling products in France and other EU member states where the Green Dot is mandatory.
The following steps have been taken to mitigate the confusion:
- Following the intervention of professional organisations including the National Association of Food Industries (ANIA) and the Federation of Commerce and Distribution (FCD), the French Council of State suspended the ban on using the Green Dot until further notice
- To raise consumer awareness of separate waste collection, the French Government issued decree No. 2021-835 of 29 June 2021. This states that sorting information guidelines must be developed for each waste stream falling under EPR
- French packaging waste take-back schemes published new guidelines on how the Triman Logo should be printed on packaging in France from January 2022. The symbol will now appear alongside sorting advice in a format dubbed ‘Info-Tri’
A transition period is in place until 8 September 2022, and packaging which does not follow the rules can be sold until stocks are exhausted up to 9 March 2023. From this point, packaging that doesn’t comply may no longer be placed on the French market.
Italy - new mandatory recycling instruction postponed
Environmental labelling will soon become mandatory in Italy. As yet, there are no clear rules on how to present information on products, but this situation is expected to change soon. In 2020, Legislative Decree No. 116 of 3 September 2020 was published in the Italian Official Gazette, amending the information required to facilitate correct disposal of packaging. It introduces a simplified form of plastic resin code logos and covers sorting instructions as well as individual labelling of separable components (e.g., bottle and cap).
When Legislative Decree No. 116 was first introduced, it was mandatory with no transitional period and no exemption for imported products, which resulted in confusion. Recognising the administrative challenge, the government published Law Decree No. 228 of 30 December 2021 (also known as 'Milleproroghe') in the Italian Official Gazette. This postponed the entry into force of mandatory labelling for recycling information to 31 December 2022.
Portugal - new recycling instruction soon to become mandatory
In Portugal, draft regulation would make it mandatory to include sorting instructions for packaging waste, including the colour of the relevant recycling bin. It also puts forward a ban of the Tidy man logo on recyclable packaging. Moreover, as in Italy, a simplified form of the resin code logos for identifying plastic materials will become mandatory. It is currently unclear whether Portugal will go ahead with the draft regulation, and if so, in what form.
UK - On-Pack Recycling Label (OPRL) logo
The UK’s OPRL scheme and logos provide a simple and consistent ‘reuse and recycling’ message on consumer packaging, which is used on a voluntary basis. The logos have recently been updated to reflect simpler, binary (recycle/don’t recycle) messaging. All packaging must switch to the new logos by 1 January 2023.
The way forward
With individual countries introducing new logos and more stringent rules, the situation is becoming difficult for food and beverage companies who sell products across different European markets. In some cases, it may be necessary to develop alternative packaging for specific countries, increasing production costs and adding complexity to manufacturing and logistics processes. Food and beverage companies and industry organisations are encouraging governments to adopt a more joined-up approach. In the meantime, food and beverage packaging needs to align with current and forthcoming requirements in the markets where the products are sold.
How Leatherhead Food Research can help
Here at Leatherhead, we help you comply with the latest recycling rules across multiple markets and advise on how to ‘cluster’ markets for more efficient labelling strategies. In addition to providing clarity on current regulations our team can provide insights on the future state of recycling regulations in Europe and beyond. Get in touch with our team of regulatory experts for clear and actionable guidance on how to approach your labelling strategy at [email protected]
