Henkel AG & Co. KGaA

Public Affairs & Governmental Relations | Henkel EU Office Reducing Packaging Waste – review of rules 1 In its recently published new Circular Economy Action Plan, the European Commission announced the establishment of a sustainable product policy framework based on the concept of circularity. Henkel supports the European Commission’s ambitions for a transition towards a more sustainable and circular economic system in packaging. Thus, we are welcoming the review of the Packaging and Packaging Waste Directive in order to fully realize the potential of a Circular Economy. With more than 185 production sites worldwide and around 20 billion Euros in sales in 2019, Henkel is a globally leading company in markets for Laundry and Home Care, Beauty Care and Adhesive Technologies solutions.

…is a globally leading company in markets for Laundry and Home Care, Beauty Care and Adhesive Technologies solutions. Europe is a key region for Henkel, with over 50 production sites and about 20,000 employees generating roughly half of global sales. Thanks to our broad portfolio, we provide our products to both strategic industrial value chains such as construction, packaging, and aerospace as well as to consumers. Henkel has clearly demonstrated its commitment to circularity from the very beginning, participating in the voluntary pledging exercise of the European Commission and being an active signatory of the Circular Plastics Alliance Declaration and the European Plastics Pact. As an advocate for the Circular Economy, Henkel enables product design for recyclability and provides solutions for repair and maintenance, and has developed ambitious sustainable packaging targets until 2025:

…provides solutions for repair and maintenance, and has developed ambitious sustainable packaging targets until 2025: 1. 100 per cent of packaging to be recyclable or reusable1; 2. 50 per cent reduction of fossil-based virgin plastics by increasing the proportion of recycled plastic to more than 30 percent, reducing the plastic consumption, and using biobased plastics; 3. Progressively moving to no plastic waste in the nature by supporting waste collection and recycling initiatives, investing in innovative solutions and technologies, and providing consumers with targeted information on recycling (e.g. through disposal instructions).

…and technologies, and providing consumers with targeted information on recycling (e.g. through disposal instructions). In cooperation along the value chain, such as with the Alliance to End Plastic Waste (AEPW), the New Plastics Economy (NPEC) by the Ellen MacArthur Foundation, the Plastic Bank and CEFLEX (A Circular Economy for Flexible Packaging), Henkel aims at making packaging more sustainable and addressing the global challenge of plastic packaging waste in the environment.2 1 Excluding adhesive products where residue may affect recyclability or pollute recycling streams.

…in the environment.2 1 Excluding adhesive products where residue may affect recyclability or pollute recycling streams. 2 Please find more information on the initiatives here: AEPW: https://www.henkel.be/fr/presse-et-medias/communiques-de-presse/2019-01-16-henkel-is-founding- member-of-new-global-alliance-to-end-plastic-waste-901534 NPEC: https://www.henkel.be/fr/presse-et-medias/communiques-de-presse/2018-10-29-henkel-signed- commitment-to-drive-progress-toward-a-circular-economy-for-plastic-886096 Plastic Bank: https://www.henkel.com/press-and-media/press-releases-and-kits/2019-11-13-henkel-extends- partnership-with-plastic-bank-997608 CEFLEX: https://ceflex.eu/ Background Ref.

…https://ceflex.eu/ Background Ref. Ares(2020)7779825 - 19/12/2020 Public Affairs & Governmental Relations | Henkel EU Office Reducing Packaging Waste – review of rules 2 To make a Circular Economy a reality in Europe and support EU industry in their efforts to further develop and implement sustainable technologies and business models, a conceptual change to a value-chain thinking is needed. Recycling becomes sourcing and shifts value from the end to the beginning of the packaging and chemical industry value chain, enabling true circularity of materials. In this context, Henkel specifically calls on policy makers to: 1. Create a functioning Single Market for secondary raw materials and packaging; 2. Shape and fine-tune the regulatory framework; 3. Promote technological progress to improve recyclability and sortability of packaging;

…the regulatory framework; 3. Promote technological progress to improve recyclability and sortability of packaging; 4. Leverage digital means to facilitate the recyclability of products and materials; 5. Create secure framework conditions for dangerous goods packaging. Please find below a more detailed elaboration on these five key demands:

…conditions for dangerous goods packaging. Please find below a more detailed elaboration on these five key demands: 1. Create a functioning Single Market for secondary raw materials and packaging • A functioning Single Market for secondary raw materials is a fundamental element to establish a circular economy in Europe. As a precondition, harmonized rules on packaging requirements across EU Member States enabling the free movement of packaging and packaged goods must be ensured. The EU Commission must conduct a critical review on the existing legal framework to detect obstacles and to provide clarity for Member States and industry stakeholders. In parallel, national legislation needs a thorough assessment of its compatibility with the objectives of the Single Market. 2.

…national legislation needs a thorough assessment of its compatibility with the objectives of the Single Market. 2. Shape and fine-tune the regulatory framework • Harmonised collection and recycling systems across Europe must be established to incentivise recycling in Member States. Increased separate collection, better and harmonised sorting and investment in the recycling infrastructure are crucial pre-conditions for turning packing waste into valuable raw materials. Harmonised systems would also enable producers to provide the right packaging design for all geographical areas. • Further harmonisation of extended producer responsibility (EPR) schemes at EU Level is needed. EPR fees should be uniform, independent of the volume of packaging as well as modulated according to the recyclability and use of recycled and biobased plastics.

…the volume of packaging as well as modulated according to the recyclability and use of recycled and biobased plastics. Also, the industry should be given ample time to adapt its packaging. • National design guidelines and test methods should be replaced by binding EU-wide definitions on design/recyclability of packaging. The CEFLEX guidelines on flexible packaging were developed by stakeholders along the value chain and are a good example to be considered as a European standard. Another illustration of our commitment to accelerate the transition to a circular economy and our open collaboration, is the EasyD4R Tool. This easy-to- use software can be employed to verify the recyclability of a packaging early in the product development phase and is available upon request to economic players along the value chain.

…early in the product development phase and is available upon request to economic players along the value chain. • Minimum quality standards for recyclates that differentiate between different materials and uses, notably concerning non-food applications, should be established. The Recyclates Call for action Public Affairs & Governmental Relations | Henkel EU Office Reducing Packaging Waste – review of rules 3 Characterization Guidance is a useful tool to evaluate recycled materials and assess their quality in line with European standards. These guidelines are accessible for the biggest recycling streams in Europe and use parameters such as origin, colour and technical properties. • Free competition must allow producers to choose the packaging that is most appropriate for the respective product and distribution system.

…allow producers to choose the packaging that is most appropriate for the respective product and distribution system. Functions of packaging must not be limited to product protection, hygiene, safety and legally required information, but also address product application. • The principle of technology neutrality should be maintained with regards to the design/recyclability of packaging as well as innovative technologies, to guarantee a life-cycle approach and product innovation along the entire value chain. To realise the Circular Economy, virgin-like qualities from biobased or chemically recycled sources need to complement mechanical recycling. Hence, all types of ‘de-fossilized’ plastics should be considered equally. Notably, mechanically and chemically recycled as well as biobased plastics should be evaluated based on their carbon footprint and circularity potential.

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originalus šaltinis (PDF) ↗

Public Affairs & Governmental Relations | Henkel EU Office Reducing Packaging Waste – review of rules 1 In its recently published new Circular Economy Action Plan, the European Commission announced the establishment of a sustainable product policy framework based on the concept of circularity. Henkel supports the European Commission’s ambitions for a transition towards a more sustainable and circular economic system in packaging. Thus, we are welcoming the review of the Packaging and Packaging Waste Directive in order to fully realize the potential of a Circular Economy. With more than 185 production sites worldwide and around 20 billion Euros in sales in 2019, Henkel is a globally leading company in markets for Laundry and Home Care, Beauty Care and Adhesive Technologies solutions.

…is a globally leading company in markets for Laundry and Home Care, Beauty Care and Adhesive Technologies solutions. Europe is a key region for Henkel, with over 50 production sites and about 20,000 employees generating roughly half of global sales. Thanks to our broad portfolio, we provide our products to both strategic industrial value chains such as construction, packaging and aerospace as well as to consumers. Henkel has clearly demonstrated its commitment to circularity from the very beginning: Participating in the voluntary pledging exercise of the European Commission, signing the Circular Plastics Alliance Declaration, and organizing Circular Economy Missions. As an advocate for the Circular Economy, Henkel is actively working on further improving the recyclability and sortability of its consumer goods packaging with concrete sustainable packaging targets until 2025:

…and sortability of its consumer goods packaging with concrete sustainable packaging targets until 2025: 1. 100 per cent of packaging to be recyclable or reusable; 2. 50 per cent reduction of fossil-based virgin plastics by increasing the proportion of recycled plastic to more than 30 percent, reducing the plastic consumption, and using biobased plastics; 3. Progressively moving to no plastic waste in the nature by supporting waste collection and recycling initiatives, investing in innovative solutions and technologies and providing consumers targeted information about recycling (e.g. through disposal instructions).

…and technologies and providing consumers targeted information about recycling (e.g. through disposal instructions). In cooperation with organizations along the value chain, such as the Alliance to End Plastic Waste (AEPW), the New Plastics Economy (NPEC) by the Ellen MacArthur Foundation, the Plastic Bank and CEFLEX (A Circular Economy for Flexible Packaging), Henkel aims at making packaging more sustainable and addressing the global challenge of plastic packaging waste in the environment.1 1 Please find more information on the initiatives here: AEPW: https://www.henkel.be/fr/presse-et-medias/communiques-de-presse/2019-01-16-henkel-is-founding- member-of-new-global-alliance-to-end-plastic-waste-901534 NPEC: https://www.henkel.be/fr/presse-et-medias/communiques-de-presse/2018-10-29-henkel-signed- commitment-to-drive-progress-toward-a-circular-economy-for-plastic-886096 Plastic Bank:…

…https://ceflex.eu/ Background Ref. Ares(2020)4120596 - 05/08/2020 Public Affairs & Governmental Relations | Henkel EU Office Reducing Packaging Waste – review of rules 2 To make a Circular Economy a reality in the EU and support European industry in their effort to further develop and implement sustainable technologies and business models, a conceptual change from treating post-consumer waste in an environmental friendly way to a value-chain thinking is needed. Recycling becomes sourcing and shifts value from the end to the beginning of the packaging value chain, enabling true circularity of materials. In this context, Henkel specifically calls on policy makers to: 1. Create a functioning Single Market for secondary raw materials and packaging; 2. Shape and fine-tune the regulatory framework; 3. Promote technological progress to improve recyclability and sortability of packaging;

…the regulatory framework; 3. Promote technological progress to improve recyclability and sortability of packaging; 4. Leverage digital means to facilitate the recyclability of products and materials; 5. Create secure framework conditions for dangerous goods packaging. Please find below a more detailed elaboration on these five key demands:

…conditions for dangerous goods packaging. Please find below a more detailed elaboration on these five key demands: 1. Create a functioning Single Market for secondary raw materials and packaging • A functioning Single Market for secondary raw materials is a fundamental element to establish a circular economy in Europe. As a precondition, harmonized rules on packaging requirements across EU Member States enabling the free movement of packaging and packaged goods must be ensured. The EU Commission must conduct a critical review on the existing legal framework to detect obstacles and to provide clarity for Member States and industry stakeholders. In parallel, national legislation needs a thorough assessment of its compatibility with the objectives of the Single Market. 2.

…national legislation needs a thorough assessment of its compatibility with the objectives of the Single Market. 2. Shape and fine-tune the regulatory framework • Harmonised collection and recycling systems across Europe must be established to incentivise recycling in Member States. Increased separate collection, better and harmonised sorting and investment in the recycling infrastructure are crucial pre-conditions for turning packing waste into valuable raw materials. Harmonised systems would also enable producers to provide the right packaging design for all geographical areas. • Further harmonisation of extended producer responsibility (EPR) schemes at EU Level is needed. EPR fees should be uniform, independent of the volume of packaging as well as modulated according to the recyclability and use of recycled and biobased plastics.

…the volume of packaging as well as modulated according to the recyclability and use of recycled and biobased plastics. Also, the industry should be given ample time to adapt its packaging. • National design guidelines and test methods should be replaced by binding EU-wide definitions on design/recyclability of packaging. The CEFLEX guidelines on flexible packaging were developed by stakeholders along the value chain and are a good example to be considered as a European standard. Another illustration of our commitment to accelerate the transition to a circular economy and our open collaboration, is the EasyD4R Tool. This easy-to- use software can be employed to verify the recyclability of a packaging early in the product development phase and is available upon request to economic players along the value chain.

…early in the product development phase and is available upon request to economic players along the value chain. Call for action Public Affairs & Governmental Relations | Henkel EU Office Reducing Packaging Waste – review of rules 3 • Minimum quality standards for recyclates that differentiate between different materials and uses, notably concerning non-food applications, should be established. The Recyclates Characterization Guidance is a useful tool to evaluate recycled materials and assess their quality in line with European standards. These guidelines are accessible for the biggest recycling streams in Europe and use parameters such as origin, colour and technical properties. • Free competition must allow producers to choose the packaging that is most appropriate for the respective product and distribution system.

…allow producers to choose the packaging that is most appropriate for the respective product and distribution system. Functions of packaging must not be limited to product protection, hygiene, safety and legally required information, but also address product application. • The principle of technology neutrality should be maintained with regards to the design/recyclability of packaging as well as innovative technologies, to guarantee a life-cycle approach and product innovation along the entire value chain. To realise the Circular Economy, virgin-like qualities from biobased or chemically recycled sources need to complement mechanical recycling. Hence, all types of ‘de-fossilized’ plastics should be considered equally. Notably, mechanically and chemically recycled as well as biobased plastics should be evaluated based on their carbon footprint and circularity potential.

…recycled as well as biobased plastics should be evaluated based on their carbon footprint and circularity potential. To create a broader sourcing base for secondary raw materials, a more strategic allocation of public funds to promote innovative technologies such as chemical recycling and the building of pilot plants powered by green energy is needed. • The introduction of mandatory recycled content targets for specific packaging formats does not promote high quality recycling but hinders innovation and the development of new recycling streams. As members of the Circular Plastics Alliance, Henkel and other industry stakeholders have committed to ambitious voluntary targets for recycled content. • Tax measures on certain packaging materials undermine innovation and investment in new technologies as well as recycling and waste infrastructures.

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originalus šaltinis (PDF) ↗