Oireachtas Joint and Select Committees
Tuesday, 21 May 2024
Joint Oireachtas Committee on Climate Action
Circular Economy in the Food Sector: Discussion
Mr. Paul Kelly:
I will address the final question on barriers first and then respond to the question on packaging. Four immediate barriers come to mind, one that I did touch on in my opening statement, which was food safety and the need to take account of that and in particular, food contact material legislation. It is great to have initiatives in sustainability but if we are not cognisant of the food safety implications, we are going to run into problems. A second issue is to do with recyclate. It is important that the timelines for both initial own targets from companies and more recently, recycling content targets from European legislation are looked at, in order to ensure that they take account of the potential for market distortions. We regularly see situations where the price of recyclate is significantly higher than the price of virgin raw material and that is to do with supply and demand in balance. That needs to be combined with increased investment in infrastructure so that we can not only collect, but recycle, prepare and develop the sufficient quantities of recyclate that will be required.
Policy certainty is really important. We can see that in the case of anaerobic digestion, of which we have a small amount in the country. It is expensive and technically complex. In the absence of policy certainty, the risk appetite will not be there to the same extent as it would be otherwise.
I will go back to a point I mentioned in my opening statement, namely, implementation timelines and timeframes. We saw quite a few examples of that during the introduction and roll-out of the single-use plastics directive when much of the detail was left to the Commission to introduce by means of implementing regulations and harmonised norms, the European standard from the European Committee for Standardization, CEN, and so on. They came at a very late stage. That creates great difficulties for companies when they are trying to change and update their supply chains to meet the new requirements in a pretty tight timeframe.
On the issue regarding vegetable packaging, that is addressed in part by the packaging waste regulations. I will ask my colleague Mr. Kevin Maher to touch on that.