The Coca-Cola Company

…1 Classified - Confidential POSITION PAPER ON THE COMMISSION PROPOSAL FOR THE REVISION OF PACKAGING AND PACKAGING WASTE REGULATION (COM(2022) 677) COCA-COLA IN EUROPE INTRODUCTION Tackling the global packaging waste crisis requires cross-sector collaboration and alignment on common principles and targets.

…the global packaging waste crisis requires cross-sector collaboration and alignment on common principles and targets. Coca-Cola’s global packaging strategy called World Without Waste, is anchored by three fundamental goals: collection, design and partnerships, that are being delivered together with the bottling companies in Europe, Coca- Cola Europacific Partners and Coca-Cola Hellenic Bottling Company: making 100% of our primary packaging recyclable globally by 2025— and using at least 50% recycled material in our primary packaging by 2030 (Design); collecting and recycling a bottle or can for each one we sell by 2030 (Collect); and bringing people together to support a healthy, debris-free environment (Partner). In Europe, we are working hard to accelerate those targets where possible. In 2022, The Coca-Cola Company announced a new global reusable packaging goal.

…accelerate those targets where possible. In 2022, The Coca-Cola Company announced a new global reusable packaging goal. By 2030, we aim to have at least 25% of our beverages sold by volume worldwide in refillable/ returnable glass or plastic bottles or in fountain dispensers with reusable packaging. It is key for the industry to have a supportive legislative framework that enables us to integrate reusable beverage systems within our recycling efforts and investments, while appropriately assessing the environmental impact. We believe that reuse should be applied with a broad perspective in mind based on the four modalities of reuse defined by the Ellen MacArthur Foundation, so that producers and distributors can apply the most effective reuse modality from a geographical, environmental, economic and infrastructure perspective.

…apply the most effective reuse modality from a geographical, environmental, economic and infrastructure perspective. For example, in Nordic markets, due to the geography of these markets with the long distance between production plants and communities, the return logistic distances for reuse could have a worse environmental than one way formats that are part of a well-functioning DRS with high collection rates. A World Without Waste, where materials are reused and recycled as part of a circular economy, is a world with dramatically lower carbon emissions and climate impacts, which is why our packaging and climate strategies are intertwined.

…lower carbon emissions and climate impacts, which is why our packaging and climate strategies are intertwined. Because packaging accounts for around 40% of our overall carbon footprint (percentage varies among different Member States), our World Without Waste efforts are essential to meeting our science-based target to reduce greenhouse gas (GHG) emissions and our vision to be net zero carbon. We’re reducing our carbon footprint by lightweighting our packaging, incorporating more recycled and renewable material, investing in local recycling and collection programs, and increasing our use of reusable packaging. We continue to rethink our beverage packaging to become more sustainable and explore options to increase reuse.

We continue to rethink our beverage packaging to become more sustainable and explore options to increase reuse. The Commission’s Packaging and Packaging Waste Regulation (PPWR) proposal is aligned with Cola-Cola’s World Without Waste packaging strategy: both aspire to do more with less, recognise the intertwined nature of the packaging and climate strategies, support the waste hierarchy, and in this vein, reuse, high collection rates, as well as an enhanced use of recycled content. For these ambitions to be achieved, the main challenge lays in setting the right enabling conditions, which we outline below. This paper touches upon the enabling conditions to scale collection, use of recycled content and reuse, in Europe. 1.

This paper touches upon the enabling conditions to scale collection, use of recycled content and reuse, in Europe. 1. COLLECTION & DEPOSIT RETURN SYSTEMS Coca-Cola supports mandatory Deposit Return Systems (DRS) and the need for minimum requirements as guardrails of how these systems will operate (list in Annex X of the proposal). We also support the proposed exception by the European Commission, for the countries that achieve above 90% separate collection via different collection systems. For DRS across Europe to be effective and cost efficient, the proposed minimum requirements need to be complemented with the following elements: • The system should be run by the industry financing and participating in the system, in a not-for-profit structure.

…system should be run by the industry financing and participating in the system, in a not-for-profit structure. • Beverage producers financing the DRS as part of their extended producer responsibility have a priority fair priority access to the feedstock for recycling issued from the packaging material they put on the market and Ref. Ares(2023)2881995 - 24/04/2023 2 Classified - Confidential that was collected via the system they have financed. Such a mechanism would support high-quality recycling, avoid downcycling of cans or PET bottles into non-food applications, and encourage all other sectors to invest in their own circularity rather than to free-ride on the beverage circular system. • The revenues coming from the sales of the collected materials and unredeemed deposits stay in the system to cover both setup and operational costs.

…sales of the collected materials and unredeemed deposits stay in the system to cover both setup and operational costs. This is key to ensure that DRS revenues are not allocated to other initiatives, to the detriment of the functioning of the DRS itself.  New DRS should accommodate refillable beverage packaging, where possible from the outset to drive synergies financially, logistically and make it shopper / consumer friendly to facilitate the return and collection of all packaging.

…logistically and make it shopper / consumer friendly to facilitate the return and collection of all packaging. In order to have well-designed Deposit Return Schemes in place that are efficient and effective, the minimum requirements need to be applicable to all schemes in Europe If this is not possible and there are existing well- functioning schemes, that may not adhere to all minimum requirements: In order for them to not incur costly or disruptive changes without bringing a positive impact on the collection rates we believe it is important to differentiate between mandatory criteria all DRS should comply with (owned by beverage industry, not for profit, priority access and revenues staying in the system) and the other requirements. For existing systems that don’t comply even with those three criteria we would ask for more time (e.g.

…requirements. For existing systems that don’t comply even with those three criteria we would ask for more time (e.g. by 2028) for them to be able to comply for a smooth transition. RECYCLED CONTENT IN PET BOTTLES We support the increased use of recycled content in beverage packaging & promoting high-quality, closed loop recycling. Packaging sustainability is also about ensuring that the recyclable materials being collected are recycled in a closed loop. Using recycled content in our cans and bottles also contributes to lowering our emissions. The beverage industry therefore needs to have access to its own food grade feedstock for recycling to contribute to Europe’s net zero goal.

…therefore needs to have access to its own food grade feedstock for recycling to contribute to Europe’s net zero goal. In addition to circularity, food safety requirements only allow beverage cans and bottles to be used in recycled content for beverage packaging making priority fair access a critical element in the uptake of recycled content. We welcome the Commission’s ambition to increase the part of recycled content in packaging by setting new recycled content targets for various types of packaging (Art.7). However, a pre-condition to this ambition is the creation of a well-functioning market for recycled materials that: • gives the sectors covered by the scope of the targets a fair access to sufficient recycled materials to meet the targets • promotes high-quality recycling and avoids downcycling In this respect, we believe that some elements of the proposal need to be strengthened.

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