DGENV A.2 02/04/04 Slide: 1 European Commission DG Environment Production, Consumption and Waste LCA, essential requirements and indicators: Experiences

DGENV A.2 02/04/04 Slide: 1

European CommissionDG EnvironmentProduction, Consumption and Waste

LCA, essential requirements and indicators: Experiences in the

context of the Packaging Directive

Otto Linher,European Commission DG [email protected]:/europa.eu.int/comm/environment/waste



Why is LCA an instrument to evaluate the benefits of policy on packaging?

Traditionally, waste policy focused on limiting the negative consequences of waste disposal In this framework, it is enough to limit analysis to the waste stage

Recycling replaces virgin materials in new products This requires to include the production of virgin materials into the system

boundaries

Packaging prevention, re-use vs. recycling etc. have an impact on all stages of the life-cycle of packaging and the packed product This requires a comprehensive analysis in order not to disregard effects on

other stages of the life cycle or on other relevant systems



How was life cycle assessment used in the context of packaging?

to demonstrate that a particular packaging type or recycling a particular packaging type Is environmentally friendly in line with the

waste hierarchy Or is not environmentally friendly and that the

waste hierarchy does not apply in a particular case



However, …

LCA proved to be time and resource consuming…

…and there were different results on the same question

Therefore, many actors preferred just to apply the waste hierarchy on a common sense basis



The Waste Management Hierarchy: A flexible principle based on common sense

Reuse

Energyrecovery

Landfill

Prevention

Recycling

Incineration without energy recovery



Life Cycle Assessment and the Packaging Directive (1)

Recital 8: “Whereas, until scientific and technological progress is made with regard to recovery processes, reuse and recycling should be considered preferable in terms of environmental impact; […]; whereas life-cycle assessments should be completed as soon as possible to justify a clear hierarchy between reusable, recyclable and recoverable packaging”



The work done since the adoption of the Packaging Directive

LCA data and methods were greatly improved (ISO 14040, databases, many studies)

RDC/Coopers and Lybrand for the European Commission 1997: Eco-balances for policy-making in the domain of packaging and packaging waste● Results of LCA depend on a number of crucial variables and

assumptionsE.g. energy scenariosDistribution distances…

● It is also not easy to weigh various impact categories against each other

● However, it is possible to identify ranges of probable impacts



Life Cycle Assessment and the Packaging Directive (2): Reuse

Article 5: “Member States may encourage reuse systems of packaging, which can be reused in an environmentally sound manner, in conformity with the Treaty”● What is environmentally friendly? LCA!● How to weigh environmental and Internal

Market objectives?



Life Cycle Assessment and the Packaging Directive (3): Prevention

Articles 9, 10 and 18 in relation to annex II: ● Packaging may only be placed on the market if it fulfils

the essential requirements● Member States may not impede the placing on the

market of packaging that fulfils the essential requirements

● The Commission shall encourage standardisation relating to essential requirements

Article 4: additional prevention measures

DGENV A.2 02/04/04 Slide: 10


The “New Approach” Concept taken from directives relating to health and safety

requirements of products circulating freely in the internal market: ● Classical regulation proved to be too heavy and technical for the

Community legislative process● Therefore, limitation to “essential requirements”● For details, mandates are given to standardisation bodies (CEN,

CENELEC, ETSI) to elaborate “harmonised standards”● These harmonised standards give automatic presumption of

conformity with essential requirements● Member States check compliance on the basis of conformity

assessment procedures and market surveillance

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The essential requirements in the Packaging

Directive Minimisation to minimum adequate amountMust permit reuse or recovery, including

recycling, and minimise its environmental impact of disposal

Minimise noxious or hazardous substances

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The problems with the “New Approach” in the context of the environment

It is relatively easy to determine whether a product is safe or not

In the context of health and safety, companies have a clear interest to eliminate products which do not fulfil the essential requirements

However, it is much more difficult to determine what is environmentally friendly and what is not

DGENV A.2 02/04/04 Slide: 13


The problems with the essential requirements in the Packaging Directive

Proved to be difficult to implement● What is minimisation?● What is an adequate amount?● Standardisation could not give clear yes/no answers (management-

oriented standards)● In the absence of such clear answers, it is difficult for enforcement

authorities to decide what is acceptable or not● This is aggravated by the fact that the directive still does not have a

conformity assessment procedure● Currently, only the UK and France are known to systematically

enforce the essential requirements

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The resulting dilemmaMany Member States and the European

Parliament want to do more on packaging prevention

Prevention measures on the basis of Article 4 such as consumer campaigns have limits

Restrictions of particular packaging types are not allowed under Article 18 of the directive

DGENV A.2 02/04/04 Slide: 15


Packaging prevention targets?It is not necessarily the weight which

determines whether a packaging is environmentally friendly or not

Cutting the weight for all packaging may result in breakage and spilling of products

If not all packaging has to reduce weight, which ones have to?

DGENV A.2 02/04/04 Slide: 16


Is life cycle assessment a solution? Ultimately, it is the overall environmental impact

throughout the life cycle of packaging which counts

LCA is the yardstick to measure these impacts However, LCA is a heavy tool – simplified

procedures and indicators may help to an extent However, it is not an automatic decision making

tool and needs to be properly understood

More inventive approaches are needed…

DGENV A.2 02/04/04 Slide: 17


The Review Clause in the Revised Packaging Directive (Art 6(8)):

Commission to present a report by 30 June 2005, as appropriate accompanied by proposals for revision of the related provisions of this Directive

Evaluation of impact on environment and Internal Market Prevention: essential requirements, packaging environment

indicator, prevention plans Re-use Producer responsibility Heavy metals and other hazardous substances

DGENV A.2 02/04/04 Slide: 18


The challenge for the Commission Carefully study all options to strengthen the prevention of

packaging Explain all elements in a clear and understandable language

which correctly reflects advantages and disadvantages of options

Sketch options for a consistent system to minimise environmental impacts

Ensure that such a system can be operated without overburdening small and medium-sized companies (life-cycle thinking versus life-cycle assessment)

Find ways to use the experiences of companies to improve their packaging

Make sure that the system can be enforced if companies do not comply

DGENV A.2 02/04/04 Slide: 19


Conclusion Life cycle assessment is the yardstick to

measure environmental impacts related to the life cycle of packaging and the packed products

In order to make LCA operational in a legislative context, an intelligent framework is needed

Options to improve the current framework are being studied

Documents

DGENV A.2 02/04/04 Slide: 1 European Commission DG Environment Production, Consumption and Waste LCA, essential requirements and indicators: Experiences