Polyolefin Circular Economy Platform

…6 January 2020 Polyolefin Circular Economy Platform AISBL, Rue Belliard 40, bte 16, B-1040 Belgium RPM BE 0737.397.463 [email protected] www.pcep.eu PCEP Response to PPWD Consultation The Polyolefin Circular Economy Platform (PCEP), brings together actors from all across the circular polyolefin value chain united in our common mission to drive the transition to a circular economy for polyolefins (polypropylene and polyethylene). Polyolefins are highly versatile and valuable materials, reflected in their use across all sectors of the economy. PCEP has three strategic goals to achieve our mission: designing out waste, keeping maximum products and material in use for as long as possible, and then recycling into high quality new raw materials.

…maximum products and material in use for as long as possible, and then recycling into high quality new raw materials. This includes working on design of our products, innovation in products and technologies, enhancing collection and sorting to ensure we get all our materials back at end of use and that significantly higher volumes are sent for recycling, mechanisms to improve the secondary materials market and drive quality of recycled polyolefins, as well as exploring new, and expanding existing, end markets for the uptake of recycled polyolefins. Our role in the transition to a carbon neutral circular economy for packaging is clear.

…uptake of recycled polyolefins. Our role in the transition to a carbon neutral circular economy for packaging is clear. Polyolefins represent 70% of Europe’s plastic packaging market and at the end of life that packaging represents the majority, 71%, of the collected post-consumer polyolefin waste.1 That collected material goes on to be transformed into over 80% of the post-consumer recycled polyolefins being used today in European products - across packaging, construction, automotive, electronics, agriculture and other sectors. In this respect, packaging is a lynchpin for making significant progress on the transition to a circular polyolefin economy, and a supportive policy framework that encourages innovation and incentivises investment is critical.

…economy, and a supportive policy framework that encourages innovation and incentivises investment is critical. We welcome this opportunity to input to the European Commission’s consultation on reviewing the requirements for packaging and other measures to prevent packaging waste. In a circular economy there should not be waste to prevent, all packaging should be feedstock for new products. Recyclable As PCEP we fully support that all packaging placed on the market should be recyclable in a cost effective manner. Indeed we are pleased to observe already the polyolefin market changing rapidly to make this reality. Recyclability, as is observed in the definition proposed in this consultation, is a function of material, collection and sorting infrastructure, and recycling technologies.

…in this consultation, is a function of material, collection and sorting infrastructure, and recycling technologies. PCEP supports a harmonised and actionable definition of recyclable that is applicable to all packaging 1 All percentages stated are taken from a PCEP study by Conversio covering EU27, UK, Norway and Switzerland. The demand figures reflect the 2018 market and waste figures the collected PO waste in 2019. Ref. Ares(2021)148985 - 07/01/2021 Page 2 of 5 placed on the market. This will continue to drive packaging that is fully compatible with an existing or emerging recycling technology, and has the appropriate infrastructure to ensure it is actually recycled. The latter part, however, requires investment and an appropriate transition time for that investment to be translated into on the ground capacity.

…investment and an appropriate transition time for that investment to be translated into on the ground capacity. In this respect we ask the European Commission to consider carefully how the definition of recyclability in essential requirements and the implementation of the EPR fee modulation interact. We would like to see time to allow the full implementation of fee modulation, to generate the investment and deliver the infrastructure and recycling capacities needed. This will enable the scaling of proven existing and emerging recycling technologies for polyolefin packaging and encourage innovation throughout the system. We would not expect this scaling to take long with today’s market dynamics already enabling new capacities to come on line much faster than was expected only a few years ago.

…market dynamics already enabling new capacities to come on line much faster than was expected only a few years ago. Another critical aspect to encourage investment in innovation is the clear recognition that all forms of recycling, in line with the EU Waste Framework Directive, will count towards both recycling rates and recycled content targets. This is required to encourage innovation and investment in all recycling technologies, physical and chemical. It will also require recognition for and establishment of a common approach to mass balance methodology for recycled content. At the same time, while infrastructures, capacities and innovations in sorting and recycling technologies expand, we need a policy framework that allows the shipment of collected polyolefin waste between member states to locations where recycling capacities exist.

…allows the shipment of collected polyolefin waste between member states to locations where recycling capacities exist. This is critical to create volumes of waste at a scale that makes recycling economically viable. PCEP believes that the circular economy is best helped by policies which focus first and foremost on quality of the recycled material, as this drives technology innovation and capacities to meet the needs of the markets using the recycled material. Quantity will follow. In this regard, we welcome a drive towards mono-material packaging by design but note that the 95% threshold proposed needs examination to ensure it is appropriate for different packaging types dependent on the functionality. Similarly, where materials are fully separable the percentage of each should not impact recyclability.

Similarly, where materials are fully separable the percentage of each should not impact recyclability. We look forward to working with the Commission and all other stakeholders to further elaborate and establish these critical elements of the recyclable definition. As you see from our comments PCEP fully supports that all packaging should be designed for the circular economy, which requires simplification of materials, or fully separable materials, all of which must be compatible with an existing or emerging recycling technology. However we do not support reducing the number of polymers, or materials in general, available for packaging designers to choose from. This could limit innovation and would not reflect the rapidly evolving nature of what is possible to recycle.

…from. This could limit innovation and would not reflect the rapidly evolving nature of what is possible to recycle. Page 3 of 5 Reusable PCEP welcomes and encourages the development of reusable packaging, except where the use of a circular single-use packaging item has a better environmental footprint. Many aspects of reusable and refillable packaging need to be further explored with all stakeholders to ensure a successful system development which brings overall environmental benefit. We need to establish a common understanding of the environmental footprint, logistics and infrastructure, liabilities, hygiene, consumer safety and behaviour, product integrity, product losses in transport and at home due to damage etc. for different packaging types, business models, and markets.

…product losses in transport and at home due to damage etc. for different packaging types, business models, and markets. Assessments of social and environmental impacts need to be scientifically based and holistic, considering both the pack and the product. Polyolefins are widely used in reusable packaging systems today, noting in particular uses in agriculture and food distribution within commercial value chains where these applications also have positive EFSA opinions for recycled content in this food contact packaging. PCEP is actively engaged in encouraging the shift to using reusable pallets made from recycled post-consumer polyolefins in transport packaging. We note that a critical aspect of the improved environmental footprint here is that such pallets are in an effective pooling system.

…a critical aspect of the improved environmental footprint here is that such pallets are in an effective pooling system. Any reusable package should also be recyclable, otherwise we simply create a future waste management problem rather than driving a circular economy. Recycled Content PCEP is actively engaged in voluntarily increasing the use of recycled content across all polyolefin applications, through our own work and in platforms such as the Circular Plastics Alliance. Recycled content is at the heart of a circular economy, reducing reliance on virgin resources and saving CO2 emissions. We support recycled content obligations, which will help to balance the availability and usage of recycled polyolefins in the market.

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