ALDI Nord Holding Stiftung & Co. KG

Our ambition in the ALDI Nord Group of Companies (ALDI Nord), one of the leading pan-European discount retailers, is to make sustainable products affordable. This includes initiatives to make all kinds of packaging reusable, recyclable and containing recycled content. 80% of ALDI Nord’s product portfolio is composed of our own brands, enabling us to implement end-to-end circular solutions and business models at scale, if reasonable, and achieve real impact on the ground. We support the policy measures introduced within the PPWR that bring genuine environmental benefits, and believe that further assessment and fine-tuning will ensure that the proposal achieves the desired goals while enabling existing, well-functioning systems to be maintained. The starting point is ensuring an efficient internal market, which the European Commission rightly recognises in moving from a Directive to a…

…a Directive to a Regulation. The specifications must be supportive and reduce bureaucratic hurdles in the process. 1. REUSE TARGETS ALDI Nord welcomes the introduction of reuse targets for secondary and tertiary packaging (e.g. crates and pallets), which we have already been implemented by ALDI Nord across Europe (e.g. for fruits and vegetables). However, the proposed reuse targets for beverage packaging (Article 26, par. 2, 4, 5, 6) could result in more transportation and related CO2 emissions. This is especially the case when refilling is not available locally and packaging needs to travel long distances to be refilled (e.g. wine produced in the south of Europe and exported across Europe would have to be returned to the south to be refilled). Reuse targets could, however, work for high volume beverages such as water and beer when there are unified packaging standards instead of…

ON PACKAGING AND PACKAGING WASTE (PPWR) 1 / 3 Ref. Ares(2023)2796316 - 20/04/2023 2 / 3

THE PROPOSAL FOR A REGULATION ON PACKAGING AND PACKAGING WASTE (PPWR) 1 / 3 Ref. Ares(2023)2796316 - 20/04/2023 2 / 3 2. DEPOSIT AND RETURN SYSTEM (DRS) The introduction of DRS across the EU for single-use plastic and metal beverage packaging (Article 44) is an important step to improve separate collection and access to materials. This will facilitate high- quality recycling, availability of materials, and reduce littering. However, the new minimum requirements for DRS in Annex X may undermine existing, well-functioning DRS in a number of Member States. Such schemes should be allowed to continue without having to comply with the new requirements, given that they have already demonstrated positive results (e.g. high take-back rates in the return-to-retail model).

…given that they have already demonstrated positive results (e.g. high take-back rates in the return-to-retail model). To facilitate the launch of new DRS, Annex X should allow for more than a single system operator to enable competition and promote innovation. Retailers should be able to design their systems to imple­ ment DRS requirements, for instance to integrate them into their existing infrastructure, to optimize the customer experience, and to fund their system (e.g. by Reverse Vending Machines (RVMs)) and methods granting them ownership of the returned materials). Our recommendations • Existing, well-functioning schemes should be exempt from the minimum DRS requirements in Annex X to ensure their continuity and customer confidence; • As retailers are required to provide the infrastructure for DRS (e.g.

…their continuity and customer confidence; • As retailers are required to provide the infrastructure for DRS (e.g. Reverse Vending Machines / RVMs), minimum DRS requirements should grant them the right to material ownerships. Alternatively, handling fees should be provided to the retailers by the system operator(s). Retailers should also have the freedom to select the RVMs of their choice; • Minimum volumes for packaging included in DRS should be set, excluding packaging <100 ml from DRS, as the current technology does not support this; • To prevent fraud, a secure deposit label must be used. A harmonized deposit label should be voluntary and left to the discretion of Member States. 3.

…label must be used. A harmonized deposit label should be voluntary and left to the discretion of Member States. 3. RECYCLED CONTENT TARGETS FOR PLASTIC PACKAGING As part of our ALDI International Packaging Strategy, we have set targets to have an average recycled content of at least 30% in the plastic packaging of our own brands and to reduce the amount of virgin plastic by at least 20% by 2025 (baseline 2020). While we support the proposed targets for the share of recycled plastics, it is important to ensure continued access to high-quality recycled materials in sufficient volumes to be able to meet these targets. In any case, leakages to other production areas must be prevented (e.g. PET from DRS for the automotive industry), in order to ensure that supply and demand are not unnecessarily imbalanced.

PET from DRS for the automotive industry), in order to ensure that supply and demand are not unnecessarily imbalanced. POSITION PAPER ON THE PROPOSAL FOR A REGULATION ON PACKAGING AND PACKAGING WASTE (PPWR) ANNETTE KIRSTE Teamlead Public Affairs +49 151 5044 5593 [email protected] ARNE RINGKOWSKI Director Reverse Logistics Supply Chain Management Solutions +49 201 8593-573 [email protected] CONTACT 3 / 3 Given very strict legal requirements for food safety and hygiene, it is especially challenging to use post-consumer recyclates for food packaging. Their use will also have to be approved by the European Food Safety Authority (EFSA) and, so far, EFSA has only approved rPET plastics from DRS (where the packaging can be traced to the place of origin) for food purposes, while packaging from other collections is excluded.

…packaging can be traced to the place of origin) for food purposes, while packaging from other collections is excluded. This process needs to be harmonised with recycling targets and generally facilitated. Our recommendations • Introduce priority access to feedstock for recycled materials (right of first refusal) for stakeholders across the whole value chain (e.g. retailers); • Maintain Article 7(10) as a safeguard clause to take account of situations where there is lack of sufficient recyclates available on the market or where the price of recyclates is excessive; • Set targets per manufacturer based on the total quantity of packaging it places on the market rather than per unit of packaging, to simplify data collection while achieving the objectives of increased recycled content in plastic packaging. to simplify data collection while achieving the objectives of increased recycled…

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