L'Oréal

Position for the European Commission – Not to be made public January 2021 L’Oréal response to the public consultation on the revision of the Packaging and Packaging Waste Directive For more than a century, L'Oréal, world leader in beauty, has focused its energy and competencies solely to one business: Beauty. L’Oréal has chosen to offer its expertise in the service of women and men worldwide, meeting the infinite diversity of their beauty desires. L’Oréal has been developing an innovative approach to packaging for a number of years. Already in 2007, eco-design was integrated into our packaging policy. In 2013, Sharing Beauty with All, the first transformation programme of the Group, included a series of bold objectives for the sustainability of packaging. L’Oréal for the Future, our very new transformation programme to 2030, entails further commitments in this field.

L’Oréal for the Future, our very new transformation programme to 2030, entails further commitments in this field. We welcome the opportunity to comment on packaging design requirements and other measures to prevent packaging waste. As we show throughout the response to the consultation and this paper, we support the Commission’s intention to make all packaging recyclable or reusable. More broadly, we believe it is crucial to address the environmental impact of packaging in its entirety, as we have done over the years at L’Oréal.

…is crucial to address the environmental impact of packaging in its entirety, as we have done over the years at L’Oréal. L’Oréal approach to the reduction of virgin plastics in packaging To meet consumer asks and our corporate responsibility duty, we embarked our suppliers in 2007 into a new eco-design policy framework to create environment-friendly packaging based on the 3Rs: Respecting safety, biodiversity and the environment; Reducing the footprint, volume and weight of packaging by only using necessary components and optimal dimensions; and Using lower impact materials and promoting circularity. Along other initiatives, we have been at L’Oréal :  Eliminating PVC-based materials in finished products;  Reducing the weight and size of packaging, removing it entirely and promoting recharge systems; and  Increasing the use of recycled materials for plastics by 60% between 2018 and 2019.

…promoting recharge systems; and  Increasing the use of recycled materials for plastics by 60% between 2018 and 2019. More substantially, we have been approaching our products from a life cycle perspective and have committed to improving the environmental profile of 100% of L’Oréal products by 2020. 85% of products launched or renewed in 2019 had an improved social or environmental profile. For example, in 2019, Redken, one of the Group’s 36 brands, reformulated a series of iconic product lines leading to a new series of products with a packaging now composed of 100% post-consumer recycled (except for the colouring) and with 83% to 99% of ingredients of natural origin. Assessing the real benefits of packaging and products onto the environment can be undertaken only thanks to a multi-criteria life cycle analysis.

…of packaging and products onto the environment can be undertaken only thanks to a multi-criteria life cycle analysis. Therefore, we developed the Sustainable Product Optimisation Tool (SPOT) to improve the eco-design of our products, both for packaging and formula, all along the life cycle of the product. Following the European Union’s Product Environmental Ref. Ares(2021)151964 - 08/01/2021 Position for the European Commission – Not to be made public January 2021 Footprint (PEF) guidelines1, the methodology was developed between 2014 and 2016 together with 11 independent international experts. The methodology includes all the PEF impact factors. The main impact, representing on average 52% of the total footprint of a cosmetic product is water, whilst the second, representing 14% of the total footprint is carbon.

…total footprint of a cosmetic product is water, whilst the second, representing 14% of the total footprint is carbon. Designing packaging of an optimal size and weight with fewer resources and refillable formats represents a major opportunity to drive improvement. For example, Yves Saint Laurent, a luxury brand of the Group, launched refillable bottles with reloadable glass cartridges. This eco-design enables a significant water saving and a carbon footprint reduction, compared to producing a non-refillable bottle. The impact is halved if customers use an entire product and three refills, instead of four whole products, leading to a 52% reduction in total packaging weight. This type of innovation demonstrates that luxury and sustainability go hand-in-hand.

…in total packaging weight. This type of innovation demonstrates that luxury and sustainability go hand-in-hand. In the continuity of the 3R strategy, we have just adopted our new 6Rs packaging policy for Recycling, Reducing, Replacing, Refilling, Recharging and Reinventing. Our new policy reframes all the packaging levers to decrease the environmental footprint of packaging, being part of the eco-design approach. End of life is one of them, with the use of recycled content and recyclability at the end-of- life. When it comes to the use of recycled content and recyclability at the end of life, we have found ways for recycling unavoidable waste. For example, the L’Oréal Luxe sites in France have forged a partnership with a company called Cèdre, which dismantles the perfumes and transforms the recovered materials, particularly glass, into secondary raw materials.

…which dismantles the perfumes and transforms the recovered materials, particularly glass, into secondary raw materials. The recovered glass is then sent to one of our bottle suppliers, which incorporates it within its new bottles. When it comes to the end of life our packaging and when the use of mechanical recycling process is not enough (e.g. quality, availability of feedstock), innovative recycling can provide a useful alternative. L’Oréal has created a consortium with Carbios to perfect the enzymatic bio recycling process for PET and entered in a partnership with PURECYCLE to produce recycled food-grade quality PP. To pursue our commitments towards giving up the use of virgin plastics for our packaging, we announced in June 2020 the creation of a 50-million-euro fund dedicated to finance innovative projects in the field of recycling and the management of plastic waste.

…fund dedicated to finance innovative projects in the field of recycling and the management of plastic waste. As consumer behaviour plays a critical role, we have engaged our consumers in a recycling campaign called “Trions en beauté”. The campaign launched in France and Belgium explains how to sort each packaging of cosmetic products. We are also using globally the power of our brands to drive consumer changes. Khiehl’s, one of the brands of the Group, signed a global partnership singer John Legend around Kiehl’s sustainability platform “Kiehl’s Future Made Better”, which connects the brand’s ongoing efforts in sustainability - through formulation, packaging, manufacturing and recycling - and community commitments. We strongly believe that criteria for choosing the right packaging go beyond protection of the formula and safety of our consumers.

…believe that criteria for choosing the right packaging go beyond protection of the formula and safety of our consumers. Ergonomics, performance, distribution, application and communication of the brand value matter very much when choosing the right packaging for the benefit of the formula, the consumers and the environment.

…matter very much when choosing the right packaging for the benefit of the formula, the consumers and the environment. We are convinced that it is possible to improve the Position for the European Commission – Not to be made public January 2021 environmental performance of packaging without compromising on any of these aspects, and we are doing it: • By 2025, 100% of our plastic packaging will be refillable, reusable, recyclable or compostable; • By 2030, 100% of the plastics used in our packaging will be either from recycled or bio-based sources; and • By 2030, we will reduce by 20% in intensity the quantity of packaging used for our products compared to 2019 (either through reuse, reducing unnecessary packaging or removing packaging entirely). Key policy signals for packaging sustainability We want to do more, and appropriate legislation is necessary to help us in this endeavour.

…for packaging sustainability We want to do more, and appropriate legislation is necessary to help us in this endeavour. Having a harmonized definition of recyclability, quality recycled content and unnecessary packaging will help us appropriately channel investments and R&D in long-term. If we are to invest into new packaging materials and eco-design, legislation should give the necessary signals without unduly restricting the way companies can achieve this. Need for a harmonised approach to packaging sustainability Currently, there are diverging signals between countries, especially with regard to single-use plastic packaging and products, the inclusion of recycled content and its alternatives.

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