The communication aims to secure the sustainable use of resources, such as natural resources and energy. However, some of the proposed changes to waste legislation steer the EU’s waste legislation further away from measures that reduce the environmental impact of the use of natural resources in Finland.
Strict recycling targets would weaken companies’ opportunities to take full account of the environmental impact of their operations and to operate in a resource efficient manner.
Opportunities in resource efficiency
Resource efficiency can create added value to processing, reduce the environmental impact of operations, improve waste utilisation, as well as reduce the raw material costs of production. Companies’ voluntary resource efficiency initiatives take into consideration local conditions so that goods can be produced as efficiently as possible. This has been common practice in the forest industry for a long time, as has been the continuous improvement of operations efficiency.
Recycling targets for packaging becoming disproportionately demanding
The targets the Commission’s communication sets for the recycling of packaging are extremely demanding and leave very little room for the consideration of national conditions. Making recycling targets more strict does not necessarily reduce the environmental impact of operations but may instead even increase it.
The Commission proposes to gradually raise the recycling target for fibre packaging, such as corrugated board and paperboard packaging, from the current 60 per cent to 90 per cent. The current recycling rate is 77 per cent, the achievement of which has required efficient recycling of packaging in the retail and industrial sectors and the maintenance of a broad consumer packaging recovery network. Finland is sparsely populated and it is not appropriate to maintain a comprehensive recycling system where the environmental load of waste transportation exceeds the benefits of recycling.
The recycling target set for wooden packaging is even more ambitious than the one set for fibre packaging. The current recycling target of 15 per cent would be increased to 50 per cent by 2020 and as high as 80 per cent by 2030. Because energy recovery is not considered recycling, the recycling rate of wooden packaging in Finland has remained at around 18 per cent.
Many wooden packages are reusable and refurbishable. Then again, no recycling methods that would meet the Commission’s extremely ambitious targets are found in Finland. Exporting wood waste abroad does not make sense ecologically and, furthermore, wooden packaging can be easily used as renewable energy.
A realistic and environmentally optimal recycling target for wooden packaging, in Finland at least, is at most 17 per cent by 2020 and 20 per cent by 2025.
The recycling target calculation method must not be changed
The European Commission also proposes to change the way recycling targets are calculated. This would reduce realised recycling rates and would make the achievement of targets even more difficult.
Waste statistics vary a great deal between EU member states. A new, more strict recycling target calculation method would further distort waste statistics and thus put member states in an unequal position.