Can you briefly describe the activities of the Circular Packaging Association (CPA) and its role in promoting sustainable packaging in the UAE and GCC region?

The CPA was established in 2019 as the CIRCLE Coalition by industry participants to promote recycling and circular economy for packaging in the Middle East. Under a Memorandum of Undertaking with the Ministry of Climate Change and Environment, the CIRCLE Coalition funded a proof of pilot concept in Abu Dhabi to identify barriers and enablers for the circular economy for packaging. The study resulted in 35 recommendations, including those related to extended producer responsibility (EPR) implementation, standards for recycled content in food-grade packaging, consumer education, awareness on source segregation and so on. We presented these recommendations to the UAE’s Circular Economy Policies Committee, and 12 of them were adopted as policy decisions by the Committee. 

The culmination of these and various other efforts was the formal establishment of the CIRCLE Coalition as the Circular Packaging Association in November 2022 licensed under the Dubai Chambers. 

Essentially, the founding members came together to facilitate public-private dialogue between the government and the industry, bringing industry expertise and global experience to the conversation. The association is focused on circular management of post-consumer packaging, which involves mobilising consumers, promoting segregation at source, enhancing collection and recovery, and increasing the use of recycled content in packaging. A key goal is to develop an EPR framework for the entire GCC region, not just the UAE. 

We are now working with the UAE Ministry of Climate Change and Environment on EPR framework design and supporting startups on collection and recovery mechanisms.  We are also working with the Saudi Standards Organization on sustainable packaging guidelines. Together with the Ministry of Industry and Advanced Technology, our Regulatory experts supported the development of standards that allow the use of food grade recycled content in packaging. 

What does the current landscape of sustainable packaging in the UAE and the Middle East look like?

The sustainable packaging landscape in the Middle East is still in its infancy, especially compared to regions like Europe. And challenges remain. For instance, waste management and recycling infrastructure are not yet fully developed, and segregation at source is not widely practiced. 

Although material recovery facilities in the UAE are well-developed, handling a wide range of materials, including end-of-life vehicles, batteries, tyres, organic waste, and plastics, with efforts to divert waste from landfills, the overall infrastructure and recycling capacity across the region, including Saudi Arabia, are still insufficient. The right technologies and sufficient feedstock for recyclers are lacking. Only about 10% of plastic materials are recovered from landfills. Of this, only around 7% is recycled, with approximately 3% being exported as scrap. Despite some efforts by brands to achieve circular packaging, the region still struggles with high landfill rates. 

What are the main challenges and opportunities for brands, recyclers, and other stakeholders in achieving circularity in packaging?

The biggest challenge is the lack of segregation at source. Most of the material coming from the consumer households is mixed waste.  Additionally, there are technological gaps, such as the lack of facilities for producing food-grade recycled content. The economic viability of recycling is also a concern, as recyclers struggle with inconsistent feedstock supply and the high costs of using recycled content. Brand owners using recycled content in their packaging often have to import recycled resin, which is more expensive than virgin materials. EPR can address some of these issues by creating a demand for recycled materials and supporting collection and recovery efforts. 

How can source segregation be improved?

A common approach is needed across the region. Currently, different areas have different coloured bins and inconsistent waste management practices. Harmonising these practices between the Emirates would help consumers understand and participate in segregation efforts. Additionally, ensuring that segregated waste is not contaminated with organic materials during collection is crucial for the delivery of high quality clean segregated materials for recycling. 

What challenges and opportunities do you foresee in implementing the EPR scheme in the UAE? 

Implementing EPR will be challenging but necessary. The environmental and economic impact assessment we conducted in 2019 estimated that diverting 75% of plastic from landfills with a 60% conversion rate could result in an economic benefit of 800 million dirhams per year, based on an oil price of $41 per barrel. Additionally, this diversion could reduce emissions by 45% and water usage by 40%.

EPR, which operates on a "polluter pays" principle, is widely recognised for keeping materials in circulation in the economy and diverting them from landfills. However, the costs associated with EPR, such as fees for collection and recovery, need to be managed equitably across different materials and should be directed towards addressing the core problem, including consumer education, segregation at source and the availability of recycled content.

Ensuring that the framework incentivises sustainable practices without disproportionately burdening any particular sector is crucial. 

EPR does not directly pay for recycling infrastructure but can create demand for recycled materials and ensure a steady supply of feedstock, thus encouraging investments in recycling facilities. The economic viability of these investments will depend on consistent feedstock supply and market demand for recycled materials. The EPR journey will be gradual, requiring technological advancements and a collaborative approach among stakeholders. The region's transition towards circularity will be a phased process, similar to the evolution seen in Europe. 

The circular economy, particularly in packaging, offers significant economic opportunities for Middle Eastern countries. Policies and strategies for a circular economy are being developed, with EPR for packaging expected to be implemented in Saudi Arabia by 2025 and the UAE by 2026.  

What role does the CPA play in policy and regulatory development in the region?

The CPA works to harmonise policies and standards across the GCC countries, ensuring consistency for companies manufacturing and exporting within the region. We collaborated with the GSO on GSO standard 2545, which led to the inclusion of rPET in food-grade packaging, adopted as Ministerial Decree 105/2022 by the Ministry of Industry and Advanced Technology (MOIAT).  We also worked to set standards for mechanical and advanced recycling technologies, including chemical recycling. The CPA works with various regional governments, including the UAE, Saudi Arabia, Qatar, and Bahrain, to create a cohesive regulatory environment. It is working with international bodies such as the League of Arab States and the United Nations to align regional policies with global best practices.