The story of the EU's plastic packaging conflict of interests

Some 20,000 cubic meters of waste float on Lake Potpecko in Serbia: plastic bottles, cans, old refrigerators and other rubbish.

The floating pollution threatens to clog the dam’s hydroelectric power station in the lake. Since last week, the Serbian authorities have sent two boats to the lake, collecting up to 100 cubic meters of plastic and other rubbish every day.

  • An estimated 40 percent of litter in the Netherlands and Belgium is said to consist of beverage packaging (Photo: Karolina Grabowska)

Serbia is not the only European country affected by plastic pollution. Plastic is everywhere.

About 85 percent of the litter on beaches consists of plastic. Five-out-of-ten most-found items on beaches are plastic packaging.

And almost two-thirds of all plastics consumers throw away, is packaging waste. Who wants to tackle plastic pollution, should look at packaging.

Currently, environmental policy on packaging waste is largely in the hands of the packaging industry itself, through Green Dot organisations.

This creates a conflict of interest, because the industry that benefits from the sale of as many individual bottles, wrappers, cans and trays as possible, is the same industry that takes back, recycles and prevents that packaging.

Through lobbying and influencing tactics, Green Dot organisations – the packaging sector – try to prevent more responsibility and costs from being placed with producers, according to this investigation into seven Green Dot organisations in Europe.

A key player is the Brussels lobby organization EXPRA, a platform representing the interests of many Green Dot organisations, with the mission “to ensure the recovery and recycling of packaging waste in the most economically efficient and ecologically sound manner.”

Via lobbying documents to the European Commission, which we consulted through freedom of information, we gained insight into the positions of the Green Dot organisations EXPRA stands for.

We documented lobbying against various European plans for plastic packaging, such as the mandatory increase of the recycled plastic content in PET bottles, the mandatory introduction of a deposit system or higher contributions from the industry to litter cleanup.

The central thread in these lobbying practices can be found in the mission of EXPRA: “ensuring low costs to [our members’] client companies”.

The power of Green Dot organisations

But first: how is the packaging industry involved in environmental policy?

Via the principle ‘the polluter pays’, all producers of packaging – such as Coca-Cola or Unilever – in Europe are obliged to take back a part of their packaging.

It would be inefficient if producers would take back and recycle their own wrappers and bottles. Instead, producer responsibility organisations do this for them, in exchange for a contribution.

These organisations ‘conduct’ the collection, sorting and recycling of packaging, like a conductor in an orchestra. They pay municipalities and sorting centres to work for them, sell usable raw materials such as PET to recyclers and ensure that the rest of the waste goes to incineration or landfill.

The best-known and largest group of producer responsibility organisations for consumer packaging can be recognised by the Green Dot logo, a symbol that a company paid a fee to process their waste.

In some countries, where Green Dot organisations have a monopoly, their influence is particularly great.

This is the case in Spain, Belgium, the Netherlands, the Czech Republic or Austria.

In other countries, such as Germany and Poland, Green Dot organisations share the waste market with other producer responsibility organisations and their power is more limited.

In many countries, Green Dot organisations do more than handle waste: they are strongly involved in prevention and litter policy, for example by financing that policy, by promoting sustainable packaging design or by funding clean-up organisations such as Mooimakers in Flanders, NederlandSchoon in the Netherlands or Reinwerfen in Austria.

Almost all Green Dot organisations are private non-profit organisations, fully-owned by their members – the packaging industry.

Although Green Dot organisations carry out a legal requirement, our study shows that few governments succeed in sufficiently controlling or directing Green Dot organisations.

As a result, Green Dot organisations have de facto great autonomy and power when it comes to processing packaging waste.

According to the EU Transparency Index, EXPRA participated between 2015 and 2019 in activities on the themes of circular economy, new waste legislation and plastics-related policy, such as the EU Plastics Strategy and the Single Use Plastics Directive.

Opposing deposit systems

Across Europe, Green Dot organisations are protesting against a mandatory introduction of deposit-refund systems.

A deposit is very suitable to keep plastics out of the environment. The seven countries where most PET bottles are collected after use, such as Germany or Lithuania, all have a deposit system, with collection figures of 90 percent or more.

And while all European countries are obliged to collect nine-out-of-ten plastic bottles by 2029, many Green Dots oppose deposit systems.

The reason? In countries such as Belgium, Austria and the Czech Republic, where a ‘selective collection system’ has been developed over the years (with waste bags or yellow garbage cans) such a deposit system is a threat to the investments made by the Green Dot organisations.

Green Dot organisations claim similar results by intensifying their current collection system.

But how does this bag and container system really perform?

In countries with selective collection, litter figures continue to risedespite industry efforts.

In addition, the data with which Green Dot organisations argue that their collection and recycling is under discussion in all the countries studied.

A recent report by the European Court of Auditors states that estimates are often inaccurate, are hardly controlled by the authorities and not comparable. More accurate numbers will reduce the reported collection and recycling rates significantly, the report warns.

In the meantime, beverage packaging continues to end up in the environment: an estimated 40 percent of litter in the Netherlands and Belgium is said to consist of beverage packaging.

Yet it is mainly the local authorities – taxpayers – who bear the costs of cleaning up that litter.

And these are high: although there are no European figures, member states assess annually between €100m to €700m in clean-up costs.

Green Dot organisations only bear a small part of that cost: at maximum, one-tenth, according to our calculations for the Netherlands and Flanders.

Clean-up costs

Green Dot organisations are also opposed to the European intention to pass on the full clean-up cost to packaging producers, as evidenced in this example, joint statement from 2018.

Remarkable in this regard is the relationship between many Green Dots and litter organisations such as NederlandSchoon, Mooimakers and BeWapp in Belgium, Reinwerfen in Austria and Paisaje Limpio in Spain.

These clean-up organisations, financed by Green Dot organisations, encourage citizens to take more responsibility for litter. Although necessary and useful, critics argue that these litter organisations might act like lightning rods for more responsibility for the industry.

Because although deposit systems can prevent packaging from ending up in a verge or ditch, these litter organisations are structurally opposing the introduction of deposits.

In addition, many of them are directly involved in Clean Europe Network, a pan-European platform criticised for representing the interests of the packaging industry.

What Green Dot organisations do want, as has emerged from various letters from EXPRA to the Commission that we consulted through freedom of information, is national flexibility.

But control of government bodies is generally inadequate, we documented, and environmental movements are also banned from the cockpit of Green Dot organisations.

As a matter of fact, EXPRA strives to ensure that packaging companies keep the reins of Green Dot organisations themselves as much as possible, because then “…they have control over the expenditure for all activities of the (…) organisation and will keep costs to the minimum necessary in their own interest.”

Still, strong government and environmental movements are a necessary watchdog when it comes to social and ecological consequences of recycling and waste policy.

Because there is a conflict of interest ingrained in the system with Green Dot organisations. Plastic packaging is cheap and small packaging provides large profit margins.

The system with Green Dot organisations is aimed at achieving minimum mandatory percentages at the lowest cost possible.

Today, how we recycle plastic packaging, is primarily a matter of cost savings for the packaging industry. This distracts the focus from the essence of that waste policy: protecting our living environment.

In the meantime, the bill is being passed on to society: millions of euros in cleaning up costs for litter, loss of income due to plastic pollution, repair costs to a dam in Serbia.

EXPRA was not available for a statement.


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