European agri-cooperatives

Copa - Cogeca | European Farmers European Agri-Cooperatives 61, Rue de Trèves | B - 1040 Bruxelles | www.copa-cogeca.eu EU Transparency Register Number | Copa 44856881231-49 | Cogeca 09586631237-74 Ref. CCC(23)00680(7) 22.3.2023 Copa-Cogeca feedback: Packaging and Packaging Waste Regulation 2022/0396(COD) Introduction In view of the publication of the Commission’s proposal for the Packaging and Packaging Waste Regulation, Copa and Cogeca – who represent 22 million farmers and their families, and over 22,000 cooperatives – would like to express their concerns as regards some of the extremely ambitious targets and measures that are included in the proposed regulation of 30 November 2022, as well as their expected impact on key agricultural sectors.

…included in the proposed regulation of 30 November 2022, as well as their expected impact on key agricultural sectors. Context Copa and Cogeca support the sustainability objectives set in the European Green Deal and the importance to continue the transition to a more circular economy, which includes ensuring sustainable packaging. Our members have been engaged and orienting their investments in this direction, for years. To move forward this change, an appropriate regulatory framework is needed. However, it is paramount that all three pillars of sustainability (economic, social and environmental) be given equal weight and the socio-economic circumstances (high production costs, challenges regarding the availability/affordability of raw materials), as well as the health and safety considerations, be taken into account and factored into new legislative proposals.

…as well as the health and safety considerations, be taken into account and factored into new legislative proposals. It is through this very delicate balancing of principles, as well as an evidenced-based and cost-effective approach, that the set objectives can be attained. Moreover, the Commission should foresee a proper and reasonable timeframe and transitional period for implementation. Taking the aforementioned into account, we would like to share our responses to specific aspects of the proposal: 1. Targets for recycled plastic packaging As far as the specific provisions are concerned, European farmers and agri-cooperatives are extremely worried about the impact of the proposed targets for recycled plastic packaging content and reuse/refill, as well as the absence of downcycling measures and harmonised labelling.

…plastic packaging content and reuse/refill, as well as the absence of downcycling measures and harmonised labelling. With respect to recycled plastic packaging, we consider that the definition for plastic packaging is concurrently wide and very restrictive, as it neither refers to types of packaging nor does it encompass innovation in terms of material. To ensure clarity and a definition that is future-proof, the EU-level definition should cover aspects such as the type of packaging (containers, bags, ties etc.) and the types of plastic and materials allowed (i.e., bio-based, biodegradable or compostable). Ref.

…bags, ties etc.) and the types of plastic and materials allowed (i.e., bio-based, biodegradable or compostable). Ref. Ares(2023)2123391 - 23/03/2023 Copa - Cogeca | European Farmers European Agri-Cooperatives 61, Rue de Trèves | B - 1040 Bruxelles | www.copa-cogeca.eu EU Transparency Register Number | Copa 44856881231-49 | Cogeca 09586631237-74 Furthermore, these targets and requirements do not consider the challenging socio-economic context, the efforts made by producers and their cooperatives (who have made heavy investments to implement the use of ecological packaging that have not yet been amortized) and the repercussions for the latter. The war in Ukraine has exacerbated the difficulties with access to packaging material due to reduced availability and affordability of raw materials.

…the difficulties with access to packaging material due to reduced availability and affordability of raw materials. This is compounded by the surging costs of inputs, energy and food, as well as supply chain disruptions. The proposed regulation does not contain any measures to prevent downcycling of food packaging used for non-food packaging. We believe that high-quality plastic used as food contact materials should be recycled in a way that ensures its continued use in the same product category with minimal losses in terms of quantity, quality or function. Measures to prevent downcycling will render possible the establishment of closed-loop systems. We hereby encourage, in line with the EU circular economy strategy, the inclusion of measures to prevent recycled plastic from being downcycled and non-food sectors’ unrestricted access to food-grade materials.

…to prevent recycled plastic from being downcycled and non-food sectors’ unrestricted access to food-grade materials. The classification as "recyclable packaging" should also take into account the quality of secondary materials and infinite recycling. The same applies to the closed-loops not considered in the current draft in this respect. Furthermore, the criteria for recyclability should not be developed separately for each packaging material in a delegated act, as this could lead to different classifications for recyclability. This point is also of relevance to sectors relying on glass, including the wine sector. Although the proposal sets ambitious targets for the use of recycled material, the availability of such materials that comply with food safety standards are not yet available in the desired quantity.

…availability of such materials that comply with food safety standards are not yet available in the desired quantity. Indeed, in the event of implementation of these targets in the near future, European packaging manufacturers would not even have the capacity to supply all operators. While we take note of the “derogations” set out in Art. 7, paras 9 and 10, we do not consider these sufficient to consider the issues raised above. Therefore, as a solution, Copa and Cogeca call for the targets for contact sensitive plastic packaging (food packaging) to be set by manufacturer and not by unit, and corresponding amendments to Art. 7, paras 1 and 2.

(food packaging) to be set by manufacturer and not by unit, and corresponding amendments to Art. 7, paras 1 and 2. The proposal for a regulation also envisages a series of obligations, not only for the packaging manufacturer which would penalised due to the technological progress achieved not being taken into account, but also for the seller that needs packaging to place their product on the market. This is the case at both the farmer level (including the production phase and direct sales within farmers’ markets), and for the HORECA sector, with particular reference to the marketing and catering level, especially for take-away. Additionally, we note that the minimum recyclate content of 30% for PET-based packaging proposed in Art. 7 has already been achieved.

…we note that the minimum recyclate content of 30% for PET-based packaging proposed in Art. 7 has already been achieved. However, for packaging made of other plastics (such as PP or PE), the recyclate targets would require industrial-scale availability of recyclate from chemical recycling in the coming years, which is not yet the case. In this respect, Copa and Cogeca call for this measure to be revised, to exclude targets for other plastics, until such a time that such recyclate is sufficiently available. Finally, in order to ensure that the food sector is not discriminated against compared to non-food sector products, the Commission should present figures or launch a comparative study concerning the quantities of plastic packaging and other single use packaging in the individual food sectors and non-food sector.

…quantities of plastic packaging and other single use packaging in the individual food sectors and non-food sector. Copa - Cogeca | European Farmers European Agri-Cooperatives 61, Rue de Trèves | B - 1040 Bruxelles | www.copa-cogeca.eu EU Transparency Register Number | Copa 44856881231-49 | Cogeca 09586631237-74 2. Provisions applicable to the fruit and vegetables sector Copa and Cogeca support efforts to make fruit and vegetable packaging more sustainable and welcomes harmonisation across the EU in this area. However, Packaging and labeling of fruits and vegetables ensures their traceability, which is important for ensuring product safety. Therefore, the proposed ban on single-use packaging is disproportionate, does not consider the reasons why a product is packaged and risks leading to undesirable effects such as food waste and potential food safety hazards.

…a product is packaged and risks leading to undesirable effects such as food waste and potential food safety hazards. In general, measures in this regulation with regard to the fruit and vegetables sector are discriminatory and repeat the problematic approach taken by the SUR regulation, that is a focus on bans instead of practical recommendations for solutions. Given that reduction in food waste is also a priority of the Commission, setting ambitious targets on packaging for fruit and vegetables will require setting an appropriate transition period until suitable new generations of packaging materials and technological solutions are available at affordable prices and in a form that can replace packaging current and provide the same shelf-life.

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