European Snacks Association

…1 Accompanying note Public Consultation to inform the review of the requirements for packaging and other measures to prevent packaging waste December 2020 The European Snacks Association asbl (ESA) is Europe's only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers, as well as national trade organisations. ESA members are involved in the manufacture of potato crisps, corn chips /tortillas, pellet snacks, baked snacks, crackers, pretzels, savoury biscuits, popcorn, pork rinds, meat snacks, fruit snacks, peanuts, other snack nuts and various other savoury snacks in this category.

…pork rinds, meat snacks, fruit snacks, peanuts, other snack nuts and various other savoury snacks in this category. Savoury snacks products therefore differ significantly in density, size, shape and fragility, while packaging techniques and technologies will vary to accommodate the contents to meet essential requirements and consumers’ needs Our members support the objectives of promoting a transition to a circular economy model and are striving to manufacture products with packaging that maximise the use of resources and minimise waste, while constantly ensuring the optimum safety and quality of the food. Our members have a high interest in decreasing the quantities of packaging that go into their products as volume and weight of packaging is a determining factor in the costs of packaging purchase, transport, and logistics and end of life, on top of environmental considerations.

…in the costs of packaging purchase, transport, and logistics and end of life, on top of environmental considerations. They have made noticeable efforts to reduce the use of packaging by for instance reducing presence of plastics in the packaging making the packaging lighter (thereby reducing waste energy for transport and production), investing in innovative packaging technology or, when feasible, switching to materials that are less complex and more easily recyclable. While manufacturers intend to continue to invest resources to offer more sustainable packaging solutions, we would like to emphasise that the ambition to achieve efficient circularity for flexible packaging cannot happen without the development of infrastructures to properly collect, sort and recycle, which are currently lacking.

…happen without the development of infrastructures to properly collect, sort and recycle, which are currently lacking. Policy options focusing on packaging requirements and preventing packaging waste have to be sensibly designed against this factual situation. ESA therefore welcomes the opportunity to submit its comments on the objectives and policy measures presented in the public consultation informing the review of the requirements for packaging and other measures to prevent packaging waste. Ref. Ares(2020)8012402 - 31/12/2020 2 I.

…the requirements for packaging and other measures to prevent packaging waste. Ref. Ares(2020)8012402 - 31/12/2020 2 I. Comments on the objectives (questionnaire part 3) Objective 2 - To limit and/or reduce the packaging waste generated across the EU To achieve a more circular, resource efficient economy, it is important to clearly distinguish measures aimed at reduction of unnecessary packaging from measures aimed to reduce the quantities of materials lost to the environment, and to clearly define the ultimate common goal of those measures. The main goal of both types of measures should be to achieve minimum environmental footprint for the provision of products to the consumer up until the end of life and allow innovation at scale. We would therefore conceive this objective as avoiding that packaging materials and its value are lost to the environment by fostering recycling and reuse.

…as avoiding that packaging materials and its value are lost to the environment by fostering recycling and reuse. Objective 3 - To promote the use of reusable packaging whenever logistically feasible with a view to reduce packaging waste generation We agree with the objective to promote the use of reusable packaging given the following additional considerations, on top of logistical feasibility: • Life cycle advantage over other options • Economic feasibility • Food safety of the reused materials according to EU food safety legislation Reuse and refill systems should be implemented only when it makes sense from a life cycle assessment point of view. These systems should for instance not lead to long distance return transport and greater energy and water use to meet the necessary hygiene requirements of the returned packaging as well as the whole reuse logistic and infrastructure.

…the necessary hygiene requirements of the returned packaging as well as the whole reuse logistic and infrastructure. They should neither lead to issues on the recycling of reusable packaging once their functional life has ended. Such balance of impacts needs to be assessed on a case by case basis and enable business operators to take the decision as to what is the best environmentally wise option. The majority of savoury snacks are packaged using flexible plastic films because they are one of the most resource efficient options which are currently available. It is made of several different types of plastics laminated together generally including a thin layer of aluminium. Savoury snacks are much more susceptible to light, temperatures, levels of oxygen in comparison to other packaged food products.

…are much more susceptible to light, temperatures, levels of oxygen in comparison to other packaged food products. Flexible packaging is currently the only light weight solution that responds to the requirements. However, manufacturers are constantly looking into new material design, working to simplify packaging to make it more recyclable. Reusable models should be considered when they make environmental sense and along with a transition phase to accommodate for a systemic, sustainable, and effective industry change that respects the complexities in supply chains 3 Objective 4 - To increase the recyclability of packaging Savoury snacks manufacturers are working on innovation to improve the sustainability of their plastic packaging, for instance to increase their recyclability, or to make them biodegradable or compostable.

…of their plastic packaging, for instance to increase their recyclability, or to make them biodegradable or compostable. However, today there are still a limited number of flexible packaging materials that are promoted as alternatives to current technologies. All plastics materials are in theory recyclable, but the mixture may not always allow for full recovery. There are opportunities to recycled flexible packaging but the sector needs a more efficient extended producer responsibility system in place that would incentivise the collection and sorting of flexible films, as well as greater investments in other promising recycling technologies such as chemical recycling. Moreover, there is a lack of infrastructure in place in many EU countries to collect and reprocess this kind of materials.

…there is a lack of infrastructure in place in many EU countries to collect and reprocess this kind of materials. If collection and segregation of plastic film could be introduced at scale and promoted to consumers then the recycling technologies will become financially viable and will lead to a reduction in waste disposal of these materials. The flexible packaging used within our sector is legally required to meet specific food safety requirements which are set out within the food contact materials regulations. For instance, due to the lack of traceability within the recycling chain, the use of recycled materials in primary packaging is therefore extremely challenging. Objective 8 - Increase the level of recycled content in packaging ESA could support this objective provided that it is technically and regulatory possible.

…recycled content in packaging ESA could support this objective provided that it is technically and regulatory possible. The right policy tools need to be in place to enable more recycled content in multilayer flexible packaging. The flexible packaging used within our sector is legally required to meet specific food safety requirements which are set out within the food contact materials regulations. For instance, due to the lack of traceability within the recycling chain, the use of recycled materials in primary packaging is therefore extremely challenging.

…within the recycling chain, the use of recycled materials in primary packaging is therefore extremely challenging. Pre-requisites would include for instance: • Introduction of new quality standards beyond the current food-contact in order to support wider and safe use of secondary raw materials and avoid competition with food and drink applications • Developing guidance to promote the circularity of materials especially with regards to redirect as a priority food-contact plastics (PE, PP) into food-contact recycled plastic to secure adequate supply without compromising safety standards for the food and beverage sectors and allow them to fulfil their legal obligations.

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originalus šaltinis (PDF) ↗

ESA considerations on the Inception Impact Assessment on the Review of the requirements for packaging and other measures to prevent packaging waste July 2020 The European Snacks Association asbl (ESA) is Europe's only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers, as well as national trade organisations. ESA members are involved in the manufacture of potato crisps, corn chips /tortillas, pellet snacks, baked snacks, crackers, pretzels, savoury biscuits, popcorn, pork rinds, meat snacks, fruit snacks, peanuts, other snack nuts and various other savoury snacks in this category.

…pork rinds, meat snacks, fruit snacks, peanuts, other snack nuts and various other savoury snacks in this category. Our members have a high interest in decreasing the quantities of packaging that go into their products as volume and weight of packaging is a determining factor in the costs of packaging purchase, transport, and logistics and end of life, on top of environmental considerations. They have made noticeable efforts to reduce the use of packaging by e.g. investing in innovative packaging technology, such as light weighting or switching to materials that confide a higher resistance/weight ratio to the packaging. Close collaboration with their packaging suppliers and customers has been instrumental in these efforts.

…the packaging. Close collaboration with their packaging suppliers and customers has been instrumental in these efforts. Our members support the objectives of promoting a transition to a circular economy model and are striving to manufacture products with packaging that maximise the use of resources and minimise waste, while constantly ensuring the optimum safety and quality of the food. ESA welcomes the opportunity to submit its views to the inception impact assessment on the review of the requirements for packaging and other measures to prevent packaging waste. I. Key facts on savoury snacks packaging Functionality and design The majority of savoury snacks are packaged using flexible plastic films because they are one of the most resource efficient options which are currently available.

…using flexible plastic films because they are one of the most resource efficient options which are currently available. It is made of several different types of plastics laminated together generally including a thin layer of aluminium. Furthermore, savoury snacks are much more susceptible to light, temperatures, levels of oxygen in comparison to other packaged food products. Flexible packaging is currently the only light weight solution that responds to the requirements. These have a specific purpose: they are lightweight (thereby reducing waste energy for transport and production), they are hygienic and, depending on the needs of the product and the choice of materials, they can provide excellent moisture, oxygen, aroma and UV light barrier properties. The food is protected and its shelf-life significantly extended, thereby reducing food waste.

…light barrier properties. The food is protected and its shelf-life significantly extended, thereby reducing food waste. Longer shelf-life also allows products to be exported within the Single Market and to compete in foreign markets. Ref. Ares(2020)4114025 - 05/08/2020 Savoury snacks products differ significantly in density, size, shape and fragility, while packaging techniques and technologies will vary to accommodate the contents to meet essential requirements and consumers’ needs. Savoury Snacks manufacturers are working on innovation to improve the sustainability of their plastic packaging, for instance to increase their recyclability, or to make them biodegradable or compostable. However, today there are still a limited number of flexible packaging materials that are promoted as alternatives to current technologies.

…are still a limited number of flexible packaging materials that are promoted as alternatives to current technologies. The key issue is how functional these alternatives are when compared to existing packaging solutions, and the reality is that very few have an equivalent performance standard. Another relevant issue is the need to have support from recycling technologies; there are opportunities to recycled flexible packaging but the sector needs a stronger extended producer responsibility system in place that would incentivise the collection and sorting of flexible films, as well as greater investments in other recycling technologies such as chemical recycling.

…of flexible films, as well as greater investments in other recycling technologies such as chemical recycling. Some savoury snacks manufacturers are involved in research programmes and consortiums at European1 and international level to mature more sustainable packaging options and work on the recyclability (from the packaging design, the collection and the sorting to the development of reprocessing infrastructure). Circularity All plastics materials are in theory recyclable, but the mixture may not allow for full recovery. Moreover, there is a lack of infrastructure in place in many EU countries to collect and reprocess this kind of materials. If collection and segregation of plastic film could be introduced at scale and promoted to consumers then the recycling technologies will become financially viable and will lead to a reduction in waste disposal of these materials.

…technologies will become financially viable and will lead to a reduction in waste disposal of these materials. The flexible packaging used within our sector is legally required to meet specific food safety requirements which are set out within the food contact materials regulations. For instance, due to the lack of traceability within the recycling chain, the use of recycled materials in primary packaging is therefore extremely challenging. II. Review of the requirements for packaging and other measures to prevent packaging waste The EU Packaging and Packaging Waste Directive (PPWD) provides a longstanding and successful legislative framework, enabling continuous innovation and environmental improvements, as well as sustainable growth and jobs. As stated above, packaging plays an important role in protecting food products as they make their way to consumers across Europe and beyond.

…plays an important role in protecting food products as they make their way to consumers across Europe and beyond. To ensure that the review of the requirements for packaging and other measures to prevent packaging waste achieves its 1For instance, CEFLEX, a collaborative project of a European consortium of companies and associations representing the entire value chain of flexible packaging to enhance the performance of flexible packaging in the circular economy.

…the entire value chain of flexible packaging to enhance the performance of flexible packaging in the circular economy. https://guidelines.ceflex.eu/?sf236093724=1 objectives while balancing potential trade-offs, we recommend including the following elements in the impact assessment: Economic impacts  With Europe facing a recession of historic proportions2 and an uncertain economic recovery, it is imperative that the European Commission’s impact assessment take into account the economic implications for consumers of potential revisions to the Packaging and Packaging Waste Directive when combined with other ongoing packaging measures: EU / national plastics taxes, extended producer responsibility fees, adaptation to the Single-use Plastics Directive and litter clean-up cost requirements.  The competitiveness of products that are exported from Europe should be considered.

…clean-up cost requirements.  The competitiveness of products that are exported from Europe should be considered.  Market trends and retailers’ and consumers’ actual willingness to pay more for sustainable packaging should be considered.  The mechanism for ensuring that investments could be rewarded through lower extended producer responsibility fees and better consumer acceptance should be examined thoroughly. If the essential element of consumer acceptance will be neglected, consumer purchasing decisions might lead to detrimental effects with regards to environmental sustainability.  The administrative burden and cost of proving compliance for businesses should be considered. Social impacts  Packaging plays an important role in ensuring that food makes it to the consumer in perfect condition.

Social impacts  Packaging plays an important role in ensuring that food makes it to the consumer in perfect condition. Food safety and quality for consumers is of utmost importance, especially for food packaging, and must be a priority.  The Commission’s roadmap states that packaging manufacturers and fillers may face an increase in costs as they adapt to the new requirements. The assessment should therefore consider the impact of this for consumers in lower socio-economic groups. Environmental impacts  When considering the complexity of packaging materials, it should be fact-based and should consider that recycling processes can evolve over time. Policymaking foscussed on packaging has to be done in view of an entire life cycle assessment, i.e. considering all unintended eventualities like increase of food waste etc.

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…1 1 ESA members are involved in the manufacture of potato crisps, corn chips /tortillas, pellet snacks, baked snacks, crackers, pretzels, savoury biscuits, popcorn, pork rinds, meat snacks, fruit snacks, peanuts, other snack nuts and various other savoury snacks in this category. The European Snacks Association asbl (ESA) is Europe’s only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers, as well as national trade organisations1. Our members support the objectives of promoting a transition to a circular economy model and are striving to manufacture products with packaging that maximise the use of resources and minimise waste, while constantly ensuring the optimum safety and quality of the food.

…maximise the use of resources and minimise waste, while constantly ensuring the optimum safety and quality of the food. The majority of savoury snacks are packaged using flexible laminated plastic films because they are one of the most resource-efficient options which are currently available. While manufacturers intend to continue to invest resources to offer more sustainable packaging solutions, we would like to emphasise from the outset that the ambition to achieve efficient circularity for flexible packaging cannot happen without the development of services and infrastructures to properly collect, sort and recycle, which are lacking across the European Union (EU). Current barriers to recycling processes and technologies (such as chemical recycling) are also hampering the development of innovative solutions for packaging.

…and technologies (such as chemical recycling) are also hampering the development of innovative solutions for packaging. We believe that the European Commission’s proposal for a Packaging and Packaging Waste Regulation, notably by addressing the above shortcomings, could represent a significant step towards a circular economy for packaging - including flexible plastic packaging - and hence contributing to the European Union’s climate neutrality goal and the Green Deal objectives. This document provides an overview of the elements of the proposed Regulation which should be modified or further improved to achieve the desired outcomes. POSITION PAPER Packaging and Packaging Waste Regulation APRIL 2023 Ref.

…improved to achieve the desired outcomes. POSITION PAPER Packaging and Packaging Waste Regulation APRIL 2023 Ref. Ares(2023)2498566 - 06/04/2023 Packaging and Packaging Waste Regulation Position paper, April 2023 Provide sufficient time for economic operators to re-design their packaging Adopt a pragmatic approach when setting design for recycling criteria Improve sorting and collection rates Harmonise and clarify the definition of ‘composite packaging’ 2 3 1 Key recommendations 1 Recyclable packaging (articles 6, 11 and 43) While we believe the proposal to make recyclability a market requirement for packaging in the EU goes in the right direction, economic operators need time and an environment that foster the necessary changes.

…the EU goes in the right direction, economic operators need time and an environment that foster the necessary changes. Providing sufficient time and flexibility for economic operators to conduct the changes The Regulation empowers the European Commission to adopt delegated acts to establish design for recycling criteria and the methodology to assess if packaging is recyclable at scale – but it does not guarantee that these instrumental acts will be ready in time before the 2030 deadline (design for recycling) and 2035 (recyclable at scale). Redesigning flexible packaging requires time and involves important financial and human resources. If all packaging needs to be compliant with design for recycling guidelines, sufficient transition time should be granted. Hence economic operators should have clarity well ahead the adoption of the delegated acts.

…time should be granted. Hence economic operators should have clarity well ahead the adoption of the delegated acts. We believe the Regulation should grant at least 5 years to comply with the design for recycling, from the date of adoption of the delegated acts. The same approach should be taken for the recyclability at scale criteria. During the time the criteria are developed, the Regulation should clarify that current standards apply to help economic operators comply with the legislation.

…the Regulation should clarify that current standards apply to help economic operators comply with the legislation. Unlock authorisation of new and innovative recycling technologies such as chemical recycling Avoid that recycled content in packaging is calculated per unit of packaging Reconsider the restrictions on the use of certain packaging formats Clarify that empty pace means the pack-fill level for certain products 4 6 7 5 8 2 They are articulated around the following key recommendations: “ Redesigning flexible packaging requires time and involves important financial and human resources.” 2 CEFLEX, a collaborative project of a European consortium of companies and associations representing the entire value chain of flexible packaging to enhance the performance of flexible packaging in the circular economy.

…the entire value chain of flexible packaging to enhance the performance of flexible packaging in the circular economy. https://guidelines.ceflex.eu/guidelines/ 3 Packaging and Packaging Waste Regulation Position paper, April 2023 Given the importance of these delegated acts, which are crucial for the authorisation of packaging from 2030 onwards, they should therefore be closely timed and economic operators should be involved in the process leading to the adoption of such secondary legislation. Using existing harmonised standards for design for recycling guidelines Some savoury snacks manufacturers are already involved in research programmes and consortia at European and international level to develop more sustainable packaging options and work on recyclability (from packaging design, collection and sorting to the development of reprocessing infrastructure).

…on recyclability (from packaging design, collection and sorting to the development of reprocessing infrastructure). We recommend that in the case of flexible packaging the design for recycling criteria should be based on already existing harmonised standards such as the ones developed by The Circular Economy for Flexible Packaging (CEFLEX) initiative 2. The guidelines have been developed by, and for, the whole value chain, from flexible packaging manufacturers to brand owners and retailers. It contains information and practical advice on designing polyolefin- based flexible packaging to be recyclable, covering the key elements of a flexible packaging structure. This includes setting limits on specific materials and elements to enable designers to maximise the sortability and recyclability of their flexible packaging.

…materials and elements to enable designers to maximise the sortability and recyclability of their flexible packaging. Boosting separate collection and sorting is an essential condition The proposal stresses that Member States shall ensure that systems are set up to provide for the return and separate collection of all packaging waste from the end users. We believe that this obligation for Member States to ensure separate collection of all packaging waste is an instrumental prerequisite for achieving recycling targets and meeting the recyclability requirements, including recycled content targets. This provision should go a step further and mandate collection of all packaging that has been designed following design for recycling criteria. Furthermore landfill and incineration of such packaging should be banned.

…following design for recycling criteria. Furthermore landfill and incineration of such packaging should be banned. The introduction of harmonised labels should also further help with the objective of boosting separate collection and sorting. “ Separate collection of all packaging waste is an instrumental prerequisite for achieving recycling targets” Packaging and Packaging Waste Regulation Position paper, April 2023 2 Minimum recycled content in plastic packaging (articles 7) Moreover, to further stimulate the recycling of flexible plastic packaging, the contribution paid by manufacturers under Extended Producer Responsibility (EPR) schemes for this material should be clearly earmarked and directed to contribute to increased and improved waste collection and management infrastructure for this specific packaging type.

…contribute to increased and improved waste collection and management infrastructure for this specific packaging type. Harmonising and clarifying the definition of ‘composite packaging’ EU Member States have different definitions for composite packaging material classifications, leading to a fragmented understanding of what composite packaging is across the EU. This results in packaging, especially packaging that is as high as 85-90% paper-based, being classified as composite and not being officially separately collected for recycling in some countries, while in other countries the same packaging is officially classified as paper and is officially collected and recycled. In both cases, consumers tend to put packaging that is predominantly paper in the paper stream in practice, and it is often sorted and sent to either standard or specialised paper recycling mills.

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originalus šaltinis (PDF) ↗