The long-awaited draft report from the European Parliament on the Circular Economy Package (CEP) was finally released on 2^nd June by rapporteur Simona Bonafe, MEP.

We have always supported the Commission’s CEP and its ambitious recycling targets as being key towards a more efficient and resource-efficient economic Europe.

However a key recommendation from the draft report has immediately drawn the attention of APEAL, namely the use of recycled content as an indicator to bolster the market for secondary materials (scrap).

APEAL also opposes the use of recycled content as an environmental indicator for steel packaging. Secondary material markets are already established for steel, and demand outstrips supply. We develop these arguments further in a separate article in this newsletter.

With these concerns in mind, rest assured APEAL will be campaigning on this issue, both in our published materials and in the meetings we have with key influencers, to raise this point.

In parallel we will continue to scrutinise and contribute positively to the ongoing debate around the circular economy as the next round of discussions takes place within the Environment, Public Health and Food Safety committee (ENVI).

We look forward to productive talks with those involved in the weeks and months ahead.

Slovakia is keen on green.

We witnessed its deep understanding of the need for sustainable choices when we organised our first “Steel packaging: Green Solutions for Central Europe” event there in 2011. Slovaks are actively recycling - 57% of steel packaging was recycled in 2014. It is also home to one of our four members, U. S. Steel Kosice.

So APEAL welcomed the start of Slovakia’s EU presidency this month as its mandate will cover voting of the CEP in the European Parliament (EP). But it must also deal with migration, growth and the recent climate deal from Paris – is that not a tall order for just 6 months of rotating presidency?

When Ambassador Alexander Micovčin¹ and Katarina Butkovska, Environmental Attaché, joined the APEAL Board for an informal discussion last May, we were keen to learn where the CEP sits in their list of priorities.

EP voting on the package is currently planned for November but much discussion is anticipated in the next review stages with the Environment, Public Health and Food Safety committee (ENVI). Still the Slovak representatives appeared motivated to advance the package as much as possible before the end of their country’s presidency in December.

Katarina Butkovska is pleased that the CEP is getting so much attention. “The advantages are not only environmental, but social and economic too. It’s one of the most comprehensive packages published by the European Commission last year”.

Harmonising definitions and calculation methods remains a challenge. As does reaching targets across all member states. “We need to keep a balance in order to reach a workable and feasible outcome” she said.

APEAL shares this concern.

The proposed CEP target for steel is 80% for all EU member states by 2025. The top 5 steel recycling countries across Europe already recycle an average of 90% but there is still some work to do for others, even though steel’s magnetic properties make it the easiest and most economical packaging material to recover, sort and recycle.

That’s why we are creating a platform of best practices to be shared across Europe so that all member states can leverage existing knowledge and infrastructure to increase recycling across the continent.

“The CEP is an important move within EU legislation, a real opportunity to reduce levels of landfill, create new business models and use resources more efficiently" stated Ambassador Micovčin.

Indeed the Slovak presidency will lead a number of environmental initiatives during the next 6 months. More information can be found here http://www.eu2016.sk/en

¹ Ambassador for Slovakia’s Permanent representation to the EU

The case for compulsory thresholds for recycled content is being made in the European Parliament in order to stimulate demand for secondary materials. We look at the case against. Why this tool is not an effective indictor for sustainability in the context of steel for packaging and why we should look at the recycling rate as environmental indicator instead.

The secondary materials market for steel packaging requires little stimulus.

Recycling is an integral part of the steel production process and steel scrap is a required component in the production of new steel. Demand already outstrips supply.

At the same time, steel is a permanent material that can be infinitely recycled without loss of quality so steel makers re-melt & recycle constantly. As there is no structural difference between new and secondary steel, no known technique exists to identify the level of recycled content in any given finished steel product. Even the CEN standard quoted in the EU Packaging and Packaging Waste directive stipulates this.

So a threshold for a compulsory level of recycled material has no practical benefit.

Can-makers do not source primary and secondary steel separately. Diverting a scrap flow to a specific product in order to increase its recycled content would make recycling less efficient and shift environmental benefits between steel products. In turn, this would simply create a higher overall environmental burden with no benefit.

Whilst we acknowledge that recycled content targets may be a useful policy tool in markets where waste is abundant and too much material is sent to landfill (such as plastics), this is not the case for steel packaging.

Steel packaging already has high recycling rates, well-established secondary material markets and low rates of landfill. Recycled content targets will not contribute to increasing recycling rates. As such, they are not an effective sustainability indicator for steel packaging.