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The environmental benefits must have the highest priority
Näringslivets Producentansvar works daily to increase the recycling of packaging waste and enable more packaging to become packaging again. In order to reach the recycling targets, all actors in the chain must contribute. An important help along the way are policy instruments and political measures similar to those proposed by the Swedish Environmental Protection Agency in the government mission "Åtgärder för att öka materialåtervinningen av avfall", where Näringslivets Producentansvar has submitted a referral response.
In order for as much waste as possible to be recycled, high material quality is required throughout the chain, which is currently mainly achieved through collection in clean fractions. Simply enabling sorting into additional fractions will not in itself guarantee a higher material recycling and several factors need to be taken into account before deciding to change the existing system.
– The purpose of the Swedish Environmental Protection Agency’s proposal is that more waste should be recycled. It is of course an ambition that we stand behind, and we want to raise the issue of the quality of the recycled material in this context. A prerequisite for high material recycling is that the material maintains a high quality throughout its life cycle, which promotes circular material flows. A lower quality will most likely lead to increased low-value linear recycling or even incineration. The environmental benefits of material recycling must therefore have the highest priority, comments Henrik Nilsson, head of Business Development and Community Relations at Näringslivets Producentansvar.
Demand must be matched against availability of recycled raw material
The recycled raw material must then be traded on a market, here the quota obligation will have a significant impact on demand and we agree that demand needs to be stimulated. However, the NPA requests a further investigation for concrete proposals for policy instruments for this.
Increased demand will require increased volumes of recyclable material, which in turn means that products put on the market must be adapted for recycling from the beginning, that is upstream. Näringslivets Producentansvar therefore believes that there is a need for legislation that directs that products must be adapted for material recycling already in the design phase, with the aim of achieving a higher material recycling.
Evaluation and actions before further changes can be implemented
We agree with Avfall Sveriges referral response regarding follow-up of effects and compliance with already existing requirements, before further changes are implemented. We note that, unfortunately, there are significant deficiencies in the Swedish Environmental Protection Agency’s factual basis for material recycling of packaging waste, something that must be addressed before a decision is made on what measures are needed to increase the material recycling of packaging. We also see well-founded facts about material recycling as a prerequisite for reliable follow-up of implemented measures.
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