WWF Deutschland

Position WWF Germany on draft proposal of the PPWR WWF Germany on Packaging and Packaging Waste Regulation 01 20. April 2023 Thank you for the opportunity to comment on the EU COM proposal for a Regulation on packaging and packaging waste. WWF Germany welcomes the basic direction of the proposal of the new EU regulation. However, with the amount of packaging growing, the high use of virgin materials, too often poor disposal routes and the resulting environmental impact, there is a need to raise the ambition of the proposal. The PPWR needs more ambitious targets, faster implementation timelines, and a more holistic approach to materials, in order to avoid negative substitution effects. For WWF Germany, the prevention of unnecessary packaging is a top priority. Reusable packaging, components and systems must be standardised and promoted. All non- avoidable packaging must be recyclable.

…components and systems must be standardised and promoted. All non- avoidable packaging must be recyclable. Virgin material from renewable resources such as wood needs to come from sustainably managed sources and needs to be deforestation and conversion free. Material and product design of packaging must be fully circular with no toxic effects occurring along the value chain. Therefore, WWF Germany asks the following points to be included in the further discussion of the proposal: Prevention of packaging waste (Art. 38), Re-use and refill targets (Art. 26), Restriction on use of certain packaging formats (Art. 22), Annex V to the PPWR • Overall, WWF Germany welcomes the concrete targets for reducing packaging waste, including minimization, for reuse and the restrictions on use of packaging formats. • However, from WWF Germany's point of view, the targets need to be more ambitious.

…on use of packaging formats. • However, from WWF Germany's point of view, the targets need to be more ambitious. A reduction goal of 5 % until 2030 with base year 2018 as laid down in Article 38 is not sufficient considering that in the last ten years alone, the amount of packaging waste has increased by around 20 %. We need at least 10 % until 2030 and 20 % until 20401. While bans of selected single-use items will decrease packaging waste, the increased number of reuse systems will also contribute to reaching this reduction goal. • Further, the targets for reuse systems in Article 26, have been lowered dramatically since the first draft. This is disadvantageous as reuse systems have to be implemented at scale. They need to be easily accessible and integrated into the routines of consumers. Under no circumstances should all these targets be further watered down.

…and integrated into the routines of consumers. Under no circumstances should all these targets be further watered down. Furthermore, it will be important to promote reusable packaging, components, and systems in a standardised form (pool systems) to avoid diverse individual solutions. 1 See also WWF-Study „Pathways to a circular plastic packaging system in Germany“ (2021) which showed that with regard to plastic packaging, material consumption can be reduced by 31% until 2040 by overall reduction and reuse models. Ref. Ares(2023)2829809 - 21/04/2023 WWF DE on Packaging and Packaging Waste Regulation 02 Packaging minimisation (Art. 9) • WWF Germany welcomes the proposed measures for minimizing packaging size (weight, volume). However, it should be clarified what “designed so that its weight and volume is reduced to the minimum necessary” means.

…it should be clarified what “designed so that its weight and volume is reduced to the minimum necessary” means. Analogous to Article 21, maximum empty-space-ratios should be introduced for product packaging. Secondary packaging that only serves marketing purposes should be avoided. Obligation related to excessive packaging (Art. 21) • WWF Germany agrees to the binding targets for avoiding excessive packaging. However, the currently proposed specification of up to 40 % justified empty volume should be further reduced for packaging and e-commerce packaging. Minimum recycled content in plastic packaging (Art. 7) WWF Germany welcomes the binding targets and minimum quotas for the use of post-consumer recyclates (PCR) and supports the approach of relating the quotas to the individual packaging per sales unit.

…recyclates (PCR) and supports the approach of relating the quotas to the individual packaging per sales unit. Recyclate use quotas are important to encourage investment in sorting and recycling infrastructure and to expand the use of recyclates. • However, binding recyclate use quotas should not apply just for plastic. To ensure the environmental benefits of the use of recyclates, it must also be ensured that the packaging is highly recyclable and is mechanically recycled in practice. • The proposed quotas should refer exclusively to recyclates from mechanical recycling. To achieve high-grade recyclates, mechanical recycling needs to be further strengthened. Open questions with regard to chemical recycling need to be answered before the role of this technology in the process of reaching these targets is determined (e.g.

…need to be answered before the role of this technology in the process of reaching these targets is determined (e.g. environmental benefits, energy consumption, greenhouse gas emissions, material losses, toxicological aspects and economic feasibility).2 • The envisaged recyclate use quotas for contact-sensitive materials made from non-PET cannot be met as things stand, as no corresponding recycling processes are approved yet. To ensure sufficient recyclate availability and quality rates, the challenges of packaging design and recycling must be solved. Therefore, quotas for contact-sensitive materials should only come into force once the optimisation of existing and the approval of further suitable mechanical recycling processes have taken place.

…once the optimisation of existing and the approval of further suitable mechanical recycling processes have taken place. 2 See also WWF-Position „Chemical Recycling Implementation Principles“ (2022) WWF DE on Packaging and Packaging Waste Regulation 03 • From WWF Germany’s point of view, the envisaged recyclate use quotas for non-contact-sensitive materials are set too low and must be increased to at least 50 % by 2030 and 80 % by 2040. Recyclable packaging (Art. 6) • WWF Germany welcomes the fact that minimum requirements for recyclability should be made a market prerequisite and that the highest possible degree of recyclability should also be financially supported. The criteria for measuring design for recycling and recyclability will be established by a "delegated act" of the EU. The concrete design requirements should be developed by 2025 at the latest.

…established by a "delegated act" of the EU. The concrete design requirements should be developed by 2025 at the latest. • The requirements for recyclability should be raised from 70 % to at least 90 % in order to minimise both quantity and quality losses in recycling and to achieve high-quality recycling. • Every European country needs a functioning EPR system. However, the set timeline to achieve this by 2035 is insufficient (Art. 6 (2e)). Recycling ‘at scale’ should be achieved by 2030 already. Labelling of packaging (Art. 11) • WWF Germany welcomes that packaging shall be marked with a label containing information on its material composition. This should include the share of recycled material on the total share of material and should apply to all packaging materials including paper and cardboard packaging. Article 11 should equally apply to transport packaging.

…materials including paper and cardboard packaging. Article 11 should equally apply to transport packaging. We thank you again for the opportunity to comment. We remain at your disposal for follow-up questions or discussion. About WWF Germany: WWF Germany is part of the international conservation organization World Wide Fund For Nature (WWF). For more than 50 years, the WWF network has been working around the globe to stop environmental degradation and build a future in which humans live in harmony with nature. In more than 100 national and international projects, WWF Germany is currently working to preserve biodiversity and our natural livelihoods. WWF Germany conceptualized a circular economy programme targeted at different focus sectors, including packaging. From WWF Germany's perspective, a sustainable circular economy enables economic activity within planetary boundaries.

From WWF Germany's perspective, a sustainable circular economy enables economic activity within planetary boundaries. This requires systemic change, including ambitious policy frameworks in a way that pushes necessary transformation forward. Contact: Tom Ohlendorf Senior Manager Circular Economy focus on Packaging WWF Germany | Reinhardtstraße 18 | 10117 Berlin | Germany Mobile: +49 151 18854168 Mail: [email protected]

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