David O'Donnell

ACE, the Alliance for Beverage Cartons and the Environment, and its members SIG Combibloc, BillerudKorsnäs, Elopak, Stora Enso and Tetra Pak, have set the industry’s vision for the future: we will deliver the most sustainable packaging for resilient food supply systems which is renewable, climate positive and circular.

Through its robust and ambitious roadmap, the industry commits to take action on all parts of the industry value chain, from sustainable sourcing to climate impact and recycling. Increasing the collection and recycling of beverage cartons to reach a 90% collection rate and at least a 70% recycling rate by 2030, and the decarbonisation of the industry’s value chain in line with the 1.5^oC aligned science-based targets are included in the ten commitments.

In line with the vision of ACE members, beverage cartons will be:

• Made only from renewable and / or recycled material.
• Fully recyclable and recycled.
• Made entirely from sustainably sourced raw materials.
• The packaging solution with the lowest carbon footprint 

“The industry has set high and ambitious standards for the next ten years,” said Annick Carpentier, Director General of ACE. “We look forward to fostering a dialogue with EU decision makers to ensure that the necessary regulatory conditions are in place to support the industry’s journey towards beverage cartons as the sustainable packaging choice for today and tomorrow.”

Beverage cartons are a recyclable low carbon packaging solution that protect food and beverages, allowing their safe use and transport while also preventing food waste. With the commitments and targets set in the 2030 Roadmap, the industry will strive for its packaging to continue to actively contribute towards the ambitions of the EU Green Deal, specifically climate neutrality, circularity, biodiversity, and resilient food systems, while never compromising the health and safety of consumers.

“The industry continues to invest in innovation and technology to increase beverage carton recycling,” said Marcelle Peuckert, President of ACE. “The industry needs an enabling policy framework that will continue to support our investments and innovation over the next decade.”

ACE members have outlined clear deliverables, will report on the Roadmap’s overall progress on a regular basis, and will develop, add, and adapt metrics should they not currently exist, also in partnership with others.

Members of the Alliance for Beverage Cartons and the Environment Ireland (ACE Ireland) – Tetra Pak, Elopak and SIG Combibloc – are continuing to build on their commitment to wood fibre traceability achieved in 2015, according to the 10th Proforest report on the industry’s Chain of Custody (CoC) progress.

In 2015, ACE Ireland members met the targets committed to in 2007, that 100 per cent of wood fibre purchased globally by the member companies was either FSC certified or FSC controlled wood. Proforest, an independent organisation working in the field of natural resource management, recently carried out a tenth progress update to cover the period of 1^st January to 31^st December 2019. The report shows that the companies have continued to make progress on their commitments and extend this across their supply chain.

The report shows:

• All 46 of the manufacturing plants operated by the three ACE Ireland members are Chain of Custody-certified.
• All of the mills and traders which supply liquid packaging board (LPB) to the ACE members were Chain of Custody-certified.

Commenting, Chief Executive of ACE Ireland, Richard Hands said: “The latest report from Proforest illustrates the beverage carton industry’s continuing commitment to ensuring sustainable sourcing of its raw materials and incorporating this commitment into their business strategies.”

Responsibly sourced, renewable materials have a key role to play in supporting a low carbon circular economy. In Sweden and Finland, where most of the wood fibre for European food and drink cartons originates, forests are expanding with growth in forest volume increasing year-on-year as annual growth exceeds cuttings.

“ACE Ireland members have a clear interest in ensuring that forests are responsibly managed as, on average, 75 per cent of a food or beverage carton is made from this natural renewable material.

“Traceability is one of our industry’s key strategies in ensuring the responsible sourcing of primary raw materials, which is, in turn, critical to achieving sustainable economic growth”, concluded Mr Hands.

The Irish Government in its Waste Action Plan for a Circular Economy committed to introducing a Deposit and Return Scheme (DRS) for Ireland. In November 2020, ACE Ireland responded to an Irish Government ‘consultation on potential models’ to share our views on how a DRS should operate in Ireland.

ACE Ireland strongly advocates for consideration to be given for the inclusion of Beverage Cartons in any DRS for Ireland. See below our response to the questions asked as part of the consultation.

The Report recommends a centralised, operational model for Ireland. Do you agree with this recommendation?

ACE Ireland agrees with the recommendations of the Eunomia report for a centralised operational model for Ireland that is producer owned and led. The establishment of a Central System Operator would help ensure greater transparency and accountability for the implementation of a DRS system which via underpinning legislation can be mandated by Government to achieve performance targets, particularly in the context of ambitions targets set out in the Waste Action Plan for a Circular Economy.

As referenced in the consultation document, a centralised approach has worked well in terms of other extended producer responsibility models such as Repak and WEEE Ireland. As this DRS will be a relatively new approach to recycling in Ireland, ACE Ireland believes that centralised model is will be the most effective means to drive public awareness and educate Irish citizens with regards to how the DRS works and why they should engage with it.

Are there other models you believe could work in an Irish context?

While ACE Ireland welcomes the proposed introduction of a DRS scheme and supports a centralised model for the introduction of the scheme, we do believe there is room to significantly broaden the scheme to include a wider selection of materials. In a Red C poll of over 1,006 Irish adults aged 18 or over, environment charity Voice Ireland revealed that 88 per cent of people surveyed ‘support an expansive DRS system taking in as many drink containers as possible’. The poll conducted from 1^st – 5^th October 2020, showed that most Irish people support the inclusion of metal cans, plastic water bottles, plastic milk bottles, glass bottles, coffee cups and drink cartons and pouches.

As noted in Section 6 of the Consultation Document on Potential Models for Ireland, the scheme will ‘not apply to glass bottles or composite beverage containers such as Tetrapak/Elopak’. However, there is a strong rationale for considering the inclusion of beverage cartons within the DRS, particularly in the context of the Government’s commitment to set specific recycling targets for packaging formats such as beverage and food cartons, as set out in the Waste Action Plan for a Circular Economy.

It is worth noting that life cycle analysis undertaken by the Heidelberg Institute for Energy and Environmental Research shows that beverage cartons are among the best environmental performers of all drinks packaging formats. They are also fully recyclable and primarily made from renewable, low-carbon paperboard. It is crucial, therefore, that systems which seek to drive greater circularity in the economy also support such low-impact packaging, thereby helping to achieve the Irish Government’s objectives outlined in the Waste Action Plan.

The results in the VOICE Ireland, Red C poll highlights the public appetite to see an expanded range of materials for inclusion in the DRS. We therefore recommend that there should be a deposit return trial of all materials to provide the evidence needed for a well-informed decision on materials which could be included in the DRS further down the line. Such a trial should include beverage cartons which can be recycled into a range of high-quality products.

Furthermore, if beverage cartons continue to remain excluded from the initial list of materials in-scope, we would strongly advocate the inclusion of a formal mechanism in the legislation underpinning the scheme to require the regular review of materials included. This mechanism would place the responsibility upon the DRS operator, in consultation with relevant stakeholders, to provide recommendations to the DCCAE for additional materials to be incorporated into the Scheme.

Incorporating such a mechanism will provide a way for new materials to be considered, helping to futureproof the Scheme, embedding flexibility and responsiveness, and enabling it to adapt to new materials and innovations in the packaging market.

What role should waste collectors play in the operation of a DRS?

We do not have a view on the role the waste collectors should play in the operation of the DRS, but it is critically important that existing kerbside collections must not be undermined by high-value materials being diverted away by the DRS. Many packaging formats will remain out of scope of the DRS – both beverage and non-beverage – and they will continue to rely on existing systems for collection. It will be important to ensure that a well-designed EPR system maintains the viability of high-quality kerbside collections, otherwise recycling performance overall could decrease.

The DRS study proposes a deposit per container of €0.20. Do you think this is appropriate? If not, should it be higher or lower or should different deposit rates apply depending on container size?

It is too early to put a figure on the optimum deposit level but understanding the experience of other similar countries would be useful. There are many factors that will determine optimum deposit level, and these will vary by country. However, the deposit would need to be high enough to incentivise consumers to return the container, but not so high as to distort the market and encourage fraud.

We note that some 78 per cent of people who responded to a VOICE Ireland Red C poll in October 2020 said they backed the introduction of a variable deposit fee, where consumers pay a deposit that varies based on the size and material of the container.

While a flat fee would seem to be the simplest approach and would not discriminate, further information is required to determine whether a flat rate or variable rate is appropriate or a composite of both. It must be considered that the purpose of the DRS is to incentivise consumers to return their package for recycling, irrespective of size or type, rather than encourage the use of one package over another. However, the principle should be that all containers carry a deposit, including those sold in multi-packs.

Consumers need to know about a DRS long before it becomes operational – do you have any suggestions as to how best the introduction of a DRS can be communicated to the public?

Ensure comprehensive national consumer outreach using all available channels.

What enforcement measures should be considered in parallel with the introduction of a DRS?

Consider financial penalties for non-compliance.

How should cross-border issues be treated to ensure producers are not at a competitive disadvantage relative to producers in Northern Ireland?

A simple and clear visible marking should be mandatory for all in-scope materials so that consumers can easily identify whether they have paid a deposit reducing the risk of fraud. It would be useful to learn from the experience of other countries with regard to this issue.

EU beverage carton recycling hits 51 per cent

ACE Ireland has welcomed the latest figures released by ACE Brussels on EU beverage carton recycling rates, which exceeded 50 per cent for the first time. The recycling rate for beverage cartons in the EU28* rose to 51 per cent in 2019, a rise of 2 per cent on 2018 figures and a continued year-on-year increase.

“We are pleased that the steady annual increase of the recycling rate for beverage cartons in 2019 surpassed 50 per cent,” said Annick Carpentier, Director General of the Alliance for Beverage Cartons and the Environment (ACE) in Brussels. “This is proof of our industry’s efforts and enhances the message that beverage cartons are recyclable and are being recycled at scale in Europe.”

Beverage cartons, made largely from renewable materials, contribute positively to a low carbon circular economy. The industry is driving beverage carton recycling across Europe and is committed to efforts that support the increase of the recycling rates in all EU Member States. The industry calls on policymakers at the European and national levels to assure that beverage cartons are collected for recycling separately, and to support a collection target to ensure beverage cartons are collected for recycling.

“With an upcoming EU legislative agenda towards more sustainable packaging, the beverage carton is well positioned with a 51 per cent recycling rate. This is an opportunity to inform policymakers at all levels that beverage cartons are a safe, circular and sustainable packaging solution with a low carbon footprint, and how the beverage carton you use at your table can be easily collected and recycled,” continued Ms Carpentier.

A key objective for ACE Ireland is to profile and benchmark beverage cartons as a renewable, recyclable, and low carbon packaging choice. To that extent, at the outset of 2020, ACE Ireland explored opportunities around the potential roll-out of a dedicated beverage carton sorting and recycling trial in partnership with one of Ireland’s leading waste collection companies and material recovery facilities (MRFs).

A 2018 Environmental Protection Agency (EPA) Household Waste Characterisation study revealed that composite beverage cartons collected at kerbside in Ireland make up:

• 1.7% of mixed dry recycling (MDR).
• 0.6% of mixed residual waste (MRW).
• 0.8% (8,025 tonnes) of the total national waste profile between MDR and MRW.

An analysis of the capture rate per waste category and collection system in the same study revealed that of the 8,025 tonnes, 53 per cent was captured through MDR and 43 per cent through MRW, demonstrating a need for greater consumer awareness around the recyclability of beverage cartons. See tables below.

My Waste, Ireland’s official guide to managing waste supported by the Irish Government and operated by the offices of the three waste regions, has included beverage cartons on its list of paper and carboard items acceptable for household mixed dry recycling. Repak, the State company responsible for subsidising recycling efforts through charges levied on firms producing packaging waste has also included beverage cartons on its list of recyclable items.

Most beverage cartons placed on the Irish market end up in household waste. A 100 per cent kerbside collection system for mixed dry recycling across the country means that all Irish households have an accessible means for easily disposing mixed dry recycling items like beverage cartons.

Table 1: Kerbside collected household waste composition

Table 2: National kerbside collected household waste 2016

Challenges facing beverage carton recycling in Ireland

Irish MRFs currently categorise beverage cartons a non-target material meaning that they are capable of being recycled but are not being targeted by the collector for separation and sale. This may be because they do not have a buyer or because the materials recovery facility or reprocessor excludes it from their specification.

Beverage cartons that arrive at Irish MRFs through MDR kerbside collection are sorted as part of paper and mixed fibre streams, where they are baled and exported with other paper and mixed fibre materials. ACE Ireland emphasises that all paper-based beverage cartons should be sorted from mixed paper and card, so that they can be reprocessed in a dedicated facility which recycles all components properly like ACE’s plant in Halifax in the UK.

Establishing a beverage carton sorting trial with Clean Ireland and Forge Hill Recycling

Through engagement with Clean Ireland, one of Ireland’s largest waste management companies operating in the Mid-West and Forge Hill Recycling one of the largest MRFs in the country based in Cork, ACE Ireland ran a sorting during August and September 2020.

The key objectives of the trial were to:

• Establish recognition and awareness of best practice solutions in terms of the separation, sorting and recycling of beverage cartons from paper and fibre.
• Demonstrate the possibilities as regards the recovery of beverage cartons from co-mingled recycling streams in the existing logistical set-up of Irish MRFs.
• Highlight the opportunities dedicated beverage carton sorting offers Irish MRFs in terms of improving the quality of their paper and fibre output.
• Showcase how dedicated sorting can help drive consumer awareness of the recyclability of beverage cartons, in turn helping Ireland achieve any specific beverage carton recycling targets set out by Government, as committed to in the ‘Waste Action Plan for a Circular Economy’.
• Ensure that best practice is developed by way of the trial being spread to other Irish MRFs.

Key learnings from the sorting trial

While this initial trial demonstrated that the dedicated separation and sorting of beverage cartons in Irish MRFs is possible in their current configuration, work still needs to be done to improve the quality of materials sorted and achieve a 95 per cent target material rate. This can be achieved through investment in additional sorting lines in Ireland’s MRFs and the monitoring of existing lines over time.

The trial also highlighted the financial shortfall to make the sorting of beverage cartons viable for Irish MRFs, which will need to be addressed. This can be done through increasing subsidy rates for MRFs targeting beverage cartons in household MDR and via an increased gate revenue for materials delivered to encourage MRFs to maximise capture for beverage cartons and minimise leakage to cardboard or mixed papers. Furthermore, an increase in presentation rates by households would also make a significant difference to financial viability for the MRFs to target beverage cartons. For example, increasing the capture rate from 1 per cent to 2 per cent would play a significant part in the commerciality for MRFs of adding new streams.

In February 2020, the Irish Government through the Department of Communication, Climate Action and Environment launched a public consultation to gather views on the development of Ireland’s new Waste Action Plan for a Circular Economy. The objective of the plan is to help Ireland move to a more Circular Economy where resources are kept in use for as long as possible and then recycled or reused at the end of their service life.

The purpose of the consultation was to enable Ireland develop a new waste policy / circular economy plan to meet the emerging challenges and build on targets set out in the Climate Action Plan and match the level of ambition in the waste and climate space shown across the European Union.

In our response to the consultation, ACE Ireland called on the Irish Government to adopt a whole life-cycle approach when shaping proposals for packaging in a low-carbon economy, including taking account of the vital role of packaging in preventing food waste and the benefits of using packaging made from low carbon, bio-based raw materials and to ensure that systems are in place to collect and recycle all recyclable packaging, including for on-the-go consumption.

Download our full consultation response here.