The Belgian and Luxembourg association for producers and distributors of cosmetics, cleaning and maintenance products, adhesives, sealants, biocides and aerosols.
The Belgian and Luxembourg association for producers and distributors of cosmetics, cleaning and maintenance products, adhesives, sealants, biocides and aerosols.
In Belgium, as in many European countries, the tax system is being repositioned as regards the environment with a view to easing the burden on work, on the one hand, and supporting environmental policies and the fight against climate change on the other. In the current context, this is clearly a good direction in which to take taxation, even if, in some cases, the proceeds from such a tax are not used for environmental protection.
Nevertheless, it is essential to make sure that taxation does not promote systems which may not be better for the environment than the pre-existing ones. Unfortunately, this appears to be happening at the moment. On the initiative of the Finance Minister, the Minister for the Environment wants to levy a tax on all packaging that cannot be reused and in particular the plastic packaging used for cosmetics and detergents. In other words, the aim is to promote refilling at the point of sale in the belief that the environmental impact of such systems is less than that of cosmetics or detergents in conventional packaging.
Analysis of the life cycle of refilling systems reveals multiple constraints and limits which very clearly affect their environmental efficiency. In fact, in order to ensure a lower environmental impact than conventional packaging, it must be possible to use a refilling system several times. This level of reuse is relatively high and depends solely on the consumer’s willingness. Below this level of reuse, there is no environmental benefit. Furthermore, for cosmetics in particular, there is a real risk that the environmental impact will migrate elsewhere in the life cycle. Actually , to be able to provide an adequate guarantee of the bacteriological quality of water-based products ‒ i.e. most cosmetics ‒ the formulators will either have to add or increase the concentration of preserving agents. This, in turn, will affect the product’s ecotoxicity and will simply transfer the environmental burden to another stage in its life cycle.
Since these constraints are well known, it is surprising that those experts working for the minister are ignoring them. In fact, the cosmetics and detergents sectors are currently participating in initiatives like the Green Deal ‘Anders Verpakt’, organised by the Flemish government, which aims to work on implementing refilling systems that are both efficient and safe for the consumer. These systems have yet to be perfected but it seems extremely likely that the best environmental approach would be to develop mixed, standardised solutions in the context of a controlled circular economy. This, incidentally, is the case in Belgium where selective sorting is yielding excellent results.
Consequently, the Minister for the Environment has recently created a tax which, bizarrely, constitutes greenwashing and will foster methods of consumption able to create an unpredictable, uncontrollable and possibly even negative environmental impact. This is regretful, particularly as solutions are currently being developed. Such solutions will no doubt be complex, and mixed, but they are perfectly feasible and the cosmetics and detergents industrial sectors are working on them enthusiastically. If the government needs money to support its policies, whatever they may be, and wants to levy an environmental tax, then this tax should, at the very least, be relevant. However. this appears not to be the case. The claims made by the Minister for the Environment constitute greenwashing. How ironic!