LCA, essential requirements and indicators: Experiences in the context of the Packaging Directive

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• LCA, essential requirements and indicators
  Experiences in the context of the Packaging
  Directive
• Otto Linher,
• European Commission DG Environment
• Otto.Linher_at_cec.eu.int
• http/europa.eu.int/comm/environment/waste

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• 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

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• 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

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• 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

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

Prevention Recycling Incineration without
energy recovery
Reuse Energy recovery Landfill
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• 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

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• 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 assumptions
• E.g. energy scenarios
• Distribution distances
• It is also not easy to weigh various impact
  categories against each other
• However, it is possible to identify ranges of
  probable impacts

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• 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?

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• 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

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• 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 amount
• Must 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

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• 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 dilemma
• Many 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

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• 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?

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• 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

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• 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

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• 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

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• 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