As discussions continue around transitioning provincial recycling programs to extended producer responsibility for printed paper and packaging (PPP), it can be helpful to understand how European systems operate, including Austria, Germany, Belgium, the UK and Ireland. These systems have evolved over decades and can provide helpful context, including what types of materials are collected, whether the system is a monopoly or competitive with multiple producer responsibly organizations (PROs), and more. This post is intended to provide you with a quick snapshot of European systems for comparison to provincial recycling systems in Canada.
As a member state of the European Union (EU), Austria, Germany, Belgium and Ireland are required to follow various EU Directives and targets to increase recycling and reuse. Despite this, there is flexibility in how countries achieve these targets in terms of system design but most member states have implemented some form of extended producer responsibility (EPR) to manage packaging.
On April 18, 2018, Members of the European Parliament adopted a circular economy package which included new legally binding targets and deadlines for recycling and the reduction of landfilling. Targets include: recycling at least 55% of municipal waste by 2025 with targets increasing to 60% by 2030 and 65% by 2035. In addition, no more than 10% of municipal waste should be landfilled by 2035.
Material specific targets include:
|By 2025||By 2030|
|Paper and cardboard||75%||85%|
As of March 11, 2020 the European Commission also released a New Circular Economy Action Plan, including strategies for plastics and packaging. Strategies include the review of various Directives to promote the eco-design of packaging, clarity around labelling, and cooperation among Member States to work towards a circular economy and the targets stated above.
Type of system: Competitive recycling marketplace – multiple PROs (e.g. ARA and Reclay)
The Austrian constitution divides up responsibility for waste management between federal and provincial governments. The federal government provides ordinances for various waste streams, such as the Packaging Ordinance (originally adopted in 1992 and amended overtime), which required a nationwide recovery system (pg. 5). In addition, there are regional and local waste management policies.
Starting in 1992, the Austrian recycling system was a monopoly with one producer responsibility organization (PRO), Alstoff Recycling Austria (ARA) (pg. 7-8). As of 2014, the system has transitioned to multiple PROs following Reclay’s challenge of the monopoly in the European Commission Court. The system is 100% financed by industry and includes household and commercial packaging. For the majority of Austrians, plastic and composite packaging is collected in yellow bins along with packaging made of wood, textiles, ceramics and biodegradable materials.
In general, Austria follows the EU’s targets but if producers choose not to go with a PRO, there are higher management targets (pg. 20). If targets are not met, producers are required to join a PRO.
In terms of a beverage deposit-return scheme, Austria has a country-wide system for refillable PET bottles.
Type of system: Competitive recycling marketplace – multiple PROs
In 1991, Germany introduced the Packaging Ordinance making it the first country to have “binding requirements for the recycling and recovery of sales packaging” (pg. 6). It required retailers and producers to collect a certain amount of materials every year based on incrementally increasing targets. Due to this, it also provided producers with the option of using producer responsibility organizations (PROs) to help them meet their obligations which lead to the creation of the Duales System Deutschland (DSD).
Overtime, the system has evolved into one of the most competitive marketplaces with multiple PROs (up to 10 PROs have existed). Types of materials include household packaging and some commercial packaging (e.g. paper, plastics, etc.).
As of January 2019, the Packaging Ordinance has been replaced by the German Packaging Act, which includes a few important updates:
- Central Packaging Registry (mandatory registration)
- Promote eco-friendly and recyclable packaging
- Updated targets (targets increased in 2019 and will increase again in 2022 – will exceed EU targets)
|2019 Targets||2022 Targets|
|Paper, board and cartons||85%||90%|
|Beverage carton packages||75%||80%|
|Mechanical recovery (plastics)||58.5%||63%|
In terms of a beverage deposit-return scheme, Germany has a country-wide system which includes a variety of materials (e.g. glass, aluminum, plastic) and types of beverages (e.g. beer, soft drinks, etc.).
Type of system: Monopoly – Single PRO model (non-profit called FOST Plus)
In 1981, the region of Flanders developed its first waste decree which set the legal basis for waste management. Today, the federal government shares environmental responsibilities with the three regions: Flemish region (Flanders), Walloon region, and the Brussels-Capital region. Each region has its own waste management programs but in general, they follow Directives provided by the EU (pg. 5).
Within Belgium, there is only one organization accredited by authorities called FOST Plus which is a non-profit that collects all types of printed paper and packaging together. Producers pay annual fees to FOST Plus to collect drink cartons and packaging made of plastic and metal. Meanwhile, municipalities are responsible for paying for the collection of printed paper based on negotiated cost models with FOST Plus.
Belgium does not have a country-wide beverage deposit-return scheme but Brussels implemented its own deposit-return system for beverage cans and plastic bottles. Many organizations are lobbying for a country-wide deposit-return program.
Type of system: Limited producer responsibility – proposal to transfer to full EPR
Current system: The UK currently has a limited producer responsibility system called the Packaging Recovery Note (PRN) System. As part of this system, material reprocessors issue PRNs “when they have recycled or recovered one tonne of relevant material; these PRNs are then sold on to obligated producers as proof that a tonne of packaging has been recycled on their behalf.” This system has received complaints since local councils are left covering a significant portion of recycling costs. For example, the PRN system contributed to £73 million in 2017 while councils spent almost £700 million on material collection and sorting.
Proposed changes: The UK Government has expressed its intention to introduce EPR for packaging and a deposit-return scheme in 2023 for England, Wales and Northern Ireland. In 2019, Environment Secretary Michael Grove said the government “will introduce a world-leading tax to boost recycled content in plastic packaging, make producers foot the bill for handling their packaging waste, and end the confusion over household recycling.” Producers will be responsible for paying the proposed tax if they fail to meet recycled content requirements.
Based on consultations in 2019, the proposed targets are shown below with the EU’s targets for context:
|Proposed Target (2025)||EU Target (2025)||Proposed Target (2030)||EU Target (2030)|
|Paper and cardboard||82%||75%||85%||85%|
|Steel||75%||70% (ferrous metals)||80%||80% (ferrous metals)|
|Total Packaging Recycling||66%||65%||70%||70%|
Type of System: Single government approved compliance scheme – Repak (not-for-profit PRO); additional support from aluminum sector-specific PRO, Alupro
Within Ireland, the main government body that is responsible for environmental protection and monitoring recycling rates is the Environmental Protection Agency (EPA) with support from local authorities. The regulatory regime for packaging has been in place since 1997 but legislation has been revised or replaced overtime.
The not-for-profit organization Repak was formed in 1997 to assist producers with their legal obligations to recycle packaging supplied into the marketplace. It started as “Ireland’s only government approved packaging recycling compliance scheme” and has grown into a leading environmental organization. Repak now has over 3,400 members who fund household recycling bins, bottle banks and more through member fees. Accepted materials include: paper and cardboard, rigid plastic, tins, cans and foil.
There is also the not-for-profit organization, Alupro, which represents the aluminum packaging industry and helps members fulfill recycling obligations. Through various initiatives like Every Can Counts consumers are able to dispose of aluminum packaging (e.g. beverage cans) away from home in addition to curbside.
Ireland does not have a country-wide beverage deposit-return scheme but as of 2019, the government was considering a scheme for single-use plastic bottles (e.g. reverse vending machines).
Figure 1. Comparison of 2016 and 2017 recycling rates in Austria, Germany, Belgium, the UK and Ireland. Packaging Waste Recycling Rates refer to the amount of packaging recycled as a proportion of packaging waste generated. Recycling Rates refer to the percentage of municipal waste generated that is recycled, composted and anaerobically digested. EU targets for packaging are provided for reference. Data from European Recycling Agency.
As various provinces, including Ontario, discuss transitioning recycling systems to extended producer responsibility, it is helpful to review the various European recycling systems in terms of targets, number of PROs, materials collected, financing and more. Some countries, like Germany, have competitive marketplaces with multiple PROs while Belgium utilizes a monopoly system with a single PRO. Meanwhile, Austria has a competitive marketplace where producers have higher management targets if they choose not to join a PRO. If they fail to meet those targets, they are then required to join a PRO to ensure accountability.
Ireland is also an interesting case study as there is a PRO for the aluminum packaging industry to increase the diversion of beverage containers in public spaces. This is similar to what is being proposed in Ontario since there could be a supplemental system for beverage containers beyond the common collection system to promote collection in public spaces. Overall, these European case studies provide support for extended producer responsibility as it has been proven to increase diversion rates and help promote a circular economy.
|Types of materials||Household and commercial packaging (e.g. packaging made of plastics, composites, textiles, etc.)||Household and some commercial packaging (e.g. bottles, newspaper, cardboard, aluminum cans, etc.)||Packaging made of metal or plastic, drink cartons (paper/printed paper not part of EPR program but collected by municipalities)||Household and commercial packaging (e.g. bottles, newspaper, cardboard, aluminum cans, etc.)||Household and commercial packaging (e.g. bottles, newspaper, cardboard, aluminum cans, etc.)|
|Type of system||Competitive recycling marketplace, multiple PROs||Competitive recycling marketplace, multiple PROs (generally for-profit)||Single PRO model (non-profit called FOST Plus)||Proposal to transition from limited producer responsibility to full EPR||Competitive recycling marketplace (one main PRO – Repak)|
|Financing||100% financed by industry||100% financed by industry||Shared – Producers pay fees to PRO for packaging collection (responsible for 100% of packaging costs). Municipalities are responsible for other materials. Where municipalities collect packaging themselves, FOST Plus pays for “reasonable costs”||Shared financing between municipalities/ producers but proposal to transition to full EPR||100% financed by industry|
|Beverage deposit-return system||Yes, country-wide (some exclusions -e.g. non-refillable plastic containers)||Yes, country-wide (some exclusions – e.g. juice)||Only some regions (e.g. Brussels)||Proposal for scheme starting in 2023for England, Wales and Northern Ireland||As of 2019, considering deposit-return scheme for single-use plastic bottles (e.g. reverse vending machines)|
|2017 recycling rates (Percentage of municipal waste generated that is recycled, composted and anaerobically digested) – European Recycling Agency||58%||68%||54%||44%||41%|
|2016 packaging waste recycling rates (amounts of packaging recycled as a proportion of packaging waste generated) – European Recycling Agency||66.8%||70.7%||81.9%||64.7%||67%|