European Aluminium Foil Association

POSITION ON PACKAGING AND PACKAGING WASTE REGULATION PROPOSAL April 2023 About us The European Aluminium Foil Association is the main trade association, specifically representing companies engaged in the rolling and rewinding of aluminium foil and the manufacturing of semi-rigid alufoil containers and household foil in Europe. With its more than 40 members, the organisation represents the total aluminium foil rolling market in Europe. Aluminium foil and its markets Aluminium represents only 1.2% of the packaging waste composition by weight in the EU27 in 2018. If we look at the waste generation by packaging type and material, semi rigids (e.g. food trays and containers) accounts for 0.32% of the packaging waste generation and flexible aluminium packaging (e.g. foils) represents only 0.03%1.

…for 0.32% of the packaging waste generation and flexible aluminium packaging (e.g. foils) represents only 0.03%1. Despite aluminium low contribution to packaging waste, and because of its unique properties, aluminium foil is used in a wide variety of applications and markets. From foil wrappers and household foil to semi-rigid foil containers and laminated foil pouches, aluminium foil applications offer a versatile range of packaging solutions to meet today’s sustainability challenges. The physical properties of aluminium foil, such as the absolute barrier effect, lead to more protection and longer shelf-lives for the product contents, as well as better preservation of their nutritional and health benefits. 1 Impact Assessment Report accompanying the PPWR proposal, Figure 49 on page 290. Ref.

…nutritional and health benefits. 1 Impact Assessment Report accompanying the PPWR proposal, Figure 49 on page 290. Ref. Ares(2023)2803536 - 20/04/2023 Aluminium circularity 75% of all aluminium ever produced is still in use. It can be recycled without loss of quality and used again in new aluminium products and packaging. Packaging with aluminium as a major component can be easily recycled via the regular aluminium recycling stream. For laminates with aluminium foil or small aluminium packaging items, pyrolysis can be used to recover the aluminium. Even in waste to energy operations aluminium foil can be partially recovered from the bottom ashes and then recycled. Also, the recycling process for aluminium requires up to 95% less energy compared to its primary production. Aluminium in packaging is increasingly recycled in Europe.

…up to 95% less energy compared to its primary production. Aluminium in packaging is increasingly recycled in Europe. The amount of aluminium in packaging recycled greatly depends on the efficiency of the national packaging collection schemes in each European country. For aluminium in packaging, national rates across Europe vary from 30% to more than 80%2. Aluminium high circularity is able to significantly reduce overall GHG emission, as demonstrated in the Commission impact assessment3. General remarks on PWPR • The European Aluminium Foil Association (EAFA) welcomes the Commission proposal for a Regulation on Packaging and Packaging Waste (PPWR) repealing Directive 94/62/EC. • We welcome the retention of the internal market legal basis (Article 114 TFEU) and the choice of a Regulation as the legal instrument.

…retention of the internal market legal basis (Article 114 TFEU) and the choice of a Regulation as the legal instrument. The PPWR is an opportunity to halt many diverging national initiatives and we regret seeing that Member States still benefit from wide discretion when it comes to develop national measures. • However, we are concerned that the impact assessment accompanying the proposal is not sufficient to justify product-specific measures such as reuse targets (Article 26) and market restrictions (Article 22). Recyclability and collection (Article 6 and Article 43) • The circularity performances of aluminium products are determined to a great extent by end-of-life recycling rates.

…circularity performances of aluminium products are determined to a great extent by end-of-life recycling rates. Despite the high recyclability of aluminium foil packaging due to its physical properties and its high value, there is a still a room of improved recycling performances in many countries and it is critical to support comprehensive collection, sorting and recycling of used packaging products. • We believe that not enough accountability has been put on Member States, municipalities, and Extender Responsibility Schemes to ensure they set up proper infrastructure for effective collection covering all packaging, including small packaging items. Some countries are making efforts4 but others are not collecting properly and, therefore, valuable resources are lost.

Some countries are making efforts4 but others are not collecting properly and, therefore, valuable resources are lost. • Article 43 alone will most likely not ensure that all packaging is accepted for collection in the appropriate waste stream, and this would result in certain packaging being excluded from collection arbitrarily. 2 Source: EUROSTAT (https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPACR__custom_4295621/default/table?lang=en) 3 Impact Assessment Report accompanying the PPWR proposal, Figure 49 on page 289. 4 In various member states such as GermanyAustria, all aluminium packaging is subject to the general collection, sorting and recycling of packaging since a long time. Some member states, such as Italy and France for example, have set up dedicated programmes to include all aluminium packaging items in the collection for recycling.

…for example, have set up dedicated programmes to include all aluminium packaging items in the collection for recycling. Italy has been collecting all aluminium packaging since the start of the dedicated EPR system (for more info, see here: https://www.cial.it/5regole/). France can collect an additional 60.000 tonnes of aluminium packaging per year through their project dedicated to small aluminium items (for more info, see here: https://www.citeo.com/le-mag/projet-metal-recycler-plus-de-petits-emballages-metalliques/). Reuse targets (Article 26) and bans (Article 22) • We are concerned that proposed reuse targets and bans are arbitrary and unsubstantiated.

…26) and bans (Article 22) • We are concerned that proposed reuse targets and bans are arbitrary and unsubstantiated. The Commission impact assessment does not include any product-specific analysis of the impacts and might result in a switch to unsustainable alternatives with higher environmental footprint and might have impacts on hygiene and food waste. • Aluminium foil packaging is often used in the HORECA sector in the form of aluminium foil containers, aluminium foil wrappers as well as flexible packaging in single portion for condiments. Those packaging items are used both for takeaway as well as for consumption within the premises of a HORECA establishment, including in hotels.

…used both for takeaway as well as for consumption within the premises of a HORECA establishment, including in hotels. • Reuse targets for takeaway ready-prepared food would target aluminium foil wrappers and containers usually chosen, especially by small HORECA operators, due to its functionality (contrary to other materials, the aluminium foil containers keep the food warmer and can be re-heated in the oven) and it also used for its hygienic properties. Aluminium foil packaging can be disposed of in recycling stream for a very high-quality material recovery. Those containers and wrappers represent a sustainable single use alternative to reuse or refill systems5 that should be not discouraged. In this regard, we suggest expanding the exemption to also in Article 26 paragraph 14 point b to small enterprises as in accordance with rules set out in the Commission Recommendation 2003/36.

…paragraph 14 point b to small enterprises as in accordance with rules set out in the Commission Recommendation 2003/36. • Bans on single use packaging for food and beverages filled and consumed within HORECA premises as well as the proposed ban on condiments single use packaging used in HORECA for on-premises consumption should be further assessed to make sure to avoid unintended consequences on hygiene and food waste. An example could be aluminium foil-based packaging used to preserve individual portions of butter6 in hotel breakfast. Another example is the aluminium foil used to wrap foods such as kebab or other similar food products consumed in store where there are currently no available reusable alternatives for such packaging products.

…products consumed in store where there are currently no available reusable alternatives for such packaging products. Aluminium coffee capsules • We are concerned that definitions under Article 3 together with Article 8 put at risk our industry’s investments in providing advanced food packaging solutions and creating systems to effectively recycle them. • The PPWR cites recycling as a critical enabler of circularity by making it a minimum criterion for placing packaging on the market. Beverage capsules which demonstrably lend themselves to recycling are already advanced in this journey, only to be cut short by a shift to mandatory composting. This move finds no justification in the waste hierarchy, undermines the functional approach to packaging with no evidence of better environmental performance of compostability over recycling as a general rule.

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