FCIO · Trade and business associations · AT
…06.08.2020 ROADMAP “ESSENTIAL REQUIREMENTS FOR PACKAGING AND REDUCE (OVER)PACKAGING AND PACKAGING WASTE” - FCIO COMMENTS FCIO welcomes the European Commission’s European Green Deal and supports the overarching goals of the European Union to become CO2 neutral by 2050. Circular economy will not only contribute to reduce CO2 emissions through better use and reuse of the materials that already exist, but can also address the global resource challenge, reduce environmental littering, create new jobs, and contribute to the necessary economic growth. Enhanced circularity means contributing to meeting the Paris Agreement and the broader UN 2030 Sustainability Development Goals.
…circularity means contributing to meeting the Paris Agreement and the broader UN 2030 Sustainability Development Goals. In this context, we formulated 10 key points for sustainable plastic packaging under our initiative “RETHINKING PLASTICS” together with our member companies early FCIO considers the following principles as critical elements for the upcoming European Commission policy discussion on “Essential requirements for packaging and reduce (over)packaging and packaging waste”: • The faster we can develop and deploy circular solutions and technologies, the faster we can make the EU economy fully circular. For example, chemical recycling, a set of technologies developed by the chemical industry, can be an additional key for plastic waste management and support the creation of a new plastics economy.
…industry, can be an additional key for plastic waste management and support the creation of a new plastics economy. The next step is to create the right conditions for our industry to develop this and other promising solutions in Europe. This includes the creation of a European Single Market for Waste and progressive transition from a waste-oriented to a resource-oriented policy framework: o Landfill of packaging waste should cease across Europe as quick as possible. o Chemical recycling must be recognized as equal recycling processes in the European waste hierarchy to other (mechanical) recycling processes. o Reduction of barriers to the use of recyclate e.g.
…waste hierarchy to other (mechanical) recycling processes. o Reduction of barriers to the use of recyclate e.g. in food packaging, packaging of dangerous goods, and packaging of cosmetics o Measures to achieve reduction in the consumption of the single-use plastic packaging should be limited to virgin plastics material, as otherwise innovation performance of companies will be counteracted. o Additional criteria of packaging need to be considered, that conflict consumption reduction, e.g. protection against theft, legal requirements including labelling of products, convenience (consumer safety, handling, usability, age appropriateness, etc.) • The European Single Market is one of the European Union’s greatest achievements, underpinning the competitiveness of European businesses and establishing the EU as a global market and export partner to third countries.
…of European businesses and establishing the EU as a global market and export partner to third countries. A level playing field must be ensured through Single Market protection and harmonization. The gradual fragmentation of the Single Market must be prevented, and its smooth functioning and the free movement of goods, which is vital to competitiveness and growth, must be assured by removing barriers: o A functioning Single Market for secondary raw materials with harmonised rules on packaging is key to allow the free movement of packaging and packaged goods in the EU. Ref. Ares(2020)4146186 - 06/08/2020 06.08.2020 • When amending the essential requirements on packaging to improve design for reuse and promote high quality recycling, it should be considered that the functionality of the packaging (e.g. protection of the packaged product) and other parameters) are not affected adversely.
…of the packaging (e.g. protection of the packaged product) and other parameters) are not affected adversely. Therefore, we support the introduction of the concept for “design for sustainability” instead of “design for recycling”: o A holistic assessment of the environmental impact of packaging whereby environmental performance is assessed throughout the entire life cycle of the packaged product is key. Packaging primarily serves the purpose of protecting the goods it contains. The more resource-intensive the production of the goods is, the more important is their protection. Studies show that the climate footprint caused by destroyed and spoiled goods weighs many times more heavily than that of packaging.
…that the climate footprint caused by destroyed and spoiled goods weighs many times more heavily than that of packaging. o Mechanically recycled, chemically recycled and biobased materials should be evaluated based on their circularity and sustainability potential, especially with regards to CO2 emissions.
…should be evaluated based on their circularity and sustainability potential, especially with regards to CO2 emissions. • FCIO supports the strengthening of the market for secondary raw materials through: o Optimized implementation and enforcement of existent legislation including a proper evaluation of the recently adopted changes of the EU Packaging Directive (with quantifiable effects not before 2025), o Establishment of better harmonised collection and recycling systems across Europe, including a quick cessation of landfill of packaging waste, o Timely investment in Member States’ infrastructures for return/separate collection, sorting and recycling, and o Availability of secondary raw materials at competitive prices and of appropriate quality ensuring consumer and product safety, based on EU-wide definitions of recyclability (packaging sustainability) and minimum quality standards…
…based on EU-wide definitions of recyclability (packaging sustainability) and minimum quality standards for recyclate. FCIO looks forward to contributing actively to the future policy discussions on the “Essential requirements for packaging and reduce (over)packaging and packaging waste” Dr. Susanne Gfatter Association of the Austrian Chemicals Industry Wiedner Hauptstraße 63 1045 Vienna Austria T 0043(0)5 90 900 – 3369 E [email protected] Internet www.fcio.at