More plastic, More carbon, More cost:
Why attached bottle caps are not the way to fix waste

With industry, government and society all stepping up action to stop waste, UNESDA Soft Drinks Europe and the European Federation of Bottled Waters join forces to voice their support for the EU’s 90% collection goals and their fears for the detrimental environmental and economic consequences of mandating attached bottle caps as proposed in the Single Use Plastics Directive.

By Sigrid Ligné, Director General, UNESDA Soft Drinks Europe and Patricia Fosselard, Secretary General, European Federation of Bottled Waters.

How much of a concern is packaging waste in the European Union?

It’s a severe problem that requires immediate action.  Latest estimates suggest that almost 900 metric tonnes of plastic waste enter the world’s oceans every single hour.  For all of us – industry representatives and European citizens alike - this simply must stop.  Packaging is part of modern consumer lives, but as an industry that contributes to the packaging waste problem, we are absolutely determined to stop littering of all our packaging.  And that includes bottles and their caps.  We’re making progress but know we must move faster.  Both our sectors – the soft drinks and bottled water industries – use recyclable packaging and have made pledges to the European Commission to improve collection and increase the use of recycled materials. Our member companies and national associations are equally focused and determined.

What is your perspective on the path set by the European Commission?

Firstly, partnership is at the heart of progress and the waste problem can only ever be truly addressed through collaboration among industry, government and society.  We believe that we are largely aligned with the European Commission in both overall ambition and approach.  This includes our shared goal to reach 90% collection across the EU.  However, while our destination is the same, we have contrasting views on how to get there.  In particular: article 6 of the Single Use Plastics directive which proposes to introduce mandatory tethered caps on beverage bottles.  While well intentioned, tethered caps would result in a number of unintended consequences which include environmental, safety and economic concerns.

Why are you concerned about the proposals to mandate tethered caps?

In the absence of any impact assessment by the European Commission, we asked PricewaterhouseCoopers (PwC) to complete an independent study.  And their findings only reinforced our concerns.  Looking at environmental consequences alone, PwC’s report estimates that tethered caps could result in between 50,000 to 200,000 tonnes of additional plastic being used annually, with exact amounts depending on the extent of technical changes required.  These numbers would essentially reverse almost a decade’s work by industry in light-weighting our packaging to use less plastic, undoing substantial and significant progress.  The report also estimates that introducing the caps would create an additional 58-381 million kg CO2 equivalent.  At a time when the European Commission is also striving to reduce carbon emissions, this is clearly an illogical and backward step.

What solution would work better?

We are absolutely convinced that focusing our efforts and investments on increasing collection rates of bottles and caps to 90% will achieve more effective and more efficient results than tethering caps to bottles.  Looking across Europe, we already see well-managed, well-run and proven schemes such as in Germany and Denmark where collection rates of bottles and caps are already over 90%.  Now, it’s not the same picture everywhere, but that's exactly why we need to invest in both extended producer responsibility and deposit refund schemes to meet the standards we see working well.  We have several concrete plans that can achieve this: upgrading collection systems to incentivize people to return caps, re-designing waste recovery fees; and introducing consumer awareness campaigns to help people dispose properly of caps.  All of these will make a difference.  Tethered caps won’t.

Why is consumer safety a concern with mandatory tethered caps?

Because tethered caps are essentially unproven, particularly in soft drinks and sparkling water, but also in juices and teas.  No established technologies currently exist which can guarantee consumer safety.  As an industry that has always placed product quality and safety as our foremost priority, this is a major concern.  Any closures on beverage containers must be safe, reliable and strong, including being safe from tampering.  They must also allow the smooth release of gas when bottles open.  With no current solution meeting these strict safety standards, this will prove an unwelcome and unnecessary distraction from our efforts to address the core environmental issues at play.

What are the cost implications of moving to tethered caps?

The costs of introducing tethered caps are significant, but the largest concern for us is proportionality.  Bottle caps represent around 4% of litter found on beaches in Europe - an amount that must be addressed.  But the cost of introducing tethered caps is estimated by PwC to be between €2.7 billion and up to €8.7 billion to adapt bottling lines.  This includes capital investment and significant losses of productivity.  To put these costs into perspective, the entire industry currently pays around €3 billion in extended producer responsibility fees for the whole of the European Union, meaning introducing tethered caps may cost nearly three times as much as the annual spend on waste management.  We are fully focused on investing more in designing better packages, improving collection and increasing consumer awareness, but this measure would divert resources unnecessarily.  A bottle with a cap, dropped on the street is still litter.  We’re trying to ensure that both are collected, recycled and re-used.

How will you prove your approach works?

Through transparent measurement of the caps and bottles that are collected.  Simply, if the measures we are proposing do not prove effective in reaching 90% collection by 2025 then we will accept tethered caps as a solution.  The Commission can review progress and we will share our data transparently.  We suggest – in parallel – the process of developing standards begins immediately.  This would mean that, in the unlikely case that improving collection does not deliver the required results, tethered caps could be introduced as of 2025.  We are passionate about investing, innovating and partnering, but it would be a great shame at this critical time if unhelpful policy and legislation are introduced that would undermine the great progress that has been made towards a circular economy.  We aim to be a true partner with the EU in achieving its objectives and want to invest in high recycling rates - not in a requirement that would bring such damaging environmental and economic cost and not achieve the goals and ambitions we share.

As first appeared in POLITICO, December 2018