Interesų grupė
GROW International SARL I www.grow-international.eu [email protected] 6 rue François 1er Paris 75008 (France) Tel: +33 (0)1.56.88.36.75 Fax: +33 (0)1.56.88.06.45 05-01-2020 Response to the European Commission public consultation to inform the review of the requirements for packaging and other measures to prevent packaging waste GROW International (Grow Int) welcomes the opportunity to provide feedback on the public consultation published by the European Commission to review the essential requirements for packaging and other measures to prevent packaging waste. In order to explain further our position with regards to the upcoming review of Directive 94/62/EC on the packaging and packaging waste directive (PPWD), we have developed the present document.
…of Directive 94/62/EC on the packaging and packaging waste directive (PPWD), we have developed the present document. Context The European Forest Institute estimates that by 2050 population increase will require the production of 50% more food, 45% more energy and 30% more freshwater. At the same time the impact of climate change must be reduced as it has an increasingly severe impact on global warming, our planet’s eco-systems and biodiversity. This will be only achieved by promoting a circular bioeconomy which replaces fossil-based materials with bio-based ones (which are renewable, recyclable and reusable). According to the recent European Commission’s proposal on European Climate Law1: “The natural sink of forests, soils, agricultural lands and wetlands should be maintained and further increased “.
“The natural sink of forests, soils, agricultural lands and wetlands should be maintained and further increased “. By actively promoting the planting of trees, the forestry sector contributes to the fight against climate change (the trees fix CO₂ and the wood retains it), promotes the conservation of biodiversity and helps in the fight against poverty. Therefore, it should be supported and promoted.
…conservation of biodiversity and helps in the fight against poverty. Therefore, it should be supported and promoted. Considering that bio-sourced sustainably managed materials should always be preferred to non-sustainable materials (which includes fossil-based ones), Considering that essential requirements for packaging should be different for sustainable materials that for non-sustainable ones, GROW Int would like to highlight the following topics and we hope these elements will be considered by the European Commission: First, it is crucial to adopt a lifecycle approach and promote the use of the Lifecycle Cycle Assessment (LCA) and/ or Product Environmental Footprint (PEF) to understand the whole environmental impact of packaging materials and adopt the most adequate policy measures.
(PEF) to understand the whole environmental impact of packaging materials and adopt the most adequate policy measures. 1 Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing the framework for achieving climate neutrality and amending Regulation (EU) 2018/1999 (European Climate Law) COM/2020/80 final Ref. Ares(2021)124709 - 07/01/2021 GROW International SARL I www.grow-international.eu [email protected] 6 rue François 1er Paris 75008 (France) Tel: +33 (0)1.56.88.36.75 Fax: +33 (0)1.56.88.06.45 Second, essential requirements for packaging should be different for sustainable materials that for non-sustainable ones. Third, develop a clear and realistic definition of recyclability as well as a compostability and biodegradability with the aim to have legal clarity updating the current definitions.
…as well as a compostability and biodegradability with the aim to have legal clarity updating the current definitions. Fourth, we think a mandatory percentage of recycled content should not be imposed for all materials. Fifth, imposing reuse targets and promoting reusable packaging may not be the most adequate solution for all materials. Sixth, a certain harmonisation of the fees from national extended producer responsibility schemes per packaging material is very much needed. Eco-design should also be encouraged by eco-modulation schemes. Finally, wood packaging industries are all SMEs and it is important not to impose a disproportionate administrative burden on them. These companies are usually located in rural areas with limited economic opportunities and should be supported to fight exodus to urban areas. 1.
…located in rural areas with limited economic opportunities and should be supported to fight exodus to urban areas. 1. It is important that the polluter pays principle is really respected: each waste stream should pay for its negative externalities and the whole environmental impact of packaging should be clearly shown. Therefore, it is crucial to adopt a lifecycle approach and promote the use of LCA or Product Environmental Footprint (PEF) for packaging materials. The waste hierarchy pyramid included in the Waste framework directive is a useful tool for policy making but it should not the only criterium as it was conceived for non-renewable materials such as plastics. This will mean that the whole environmental impact should be considered including the impact of preparing the materials for reuse or recycling.
…whole environmental impact should be considered including the impact of preparing the materials for reuse or recycling. The upstream phases of the renewable material and its transformation into packaging which are more or less energy intensive are decisive! Therefore, renewable materials such as wood packaging, if managed sustainably, are always better for the environment2 regardless of the efforts made to reduce the use, promote its reuse, recycling or minimise the impact of fossil-based materials. We believe, it is important to mention the promotion of the use of recycled or renewable materials as included in French legislation3 and consider wood has always the potential to be used in energy recovery.
…materials as included in French legislation3 and consider wood has always the potential to be used in energy recovery. Its natural destination is to be recycled or 2 French Agency for Ecological transition (ADEME), Life cycle analysis study of wooden crates, corrugated cardboard and plastic crates for apples, 2000. 3 ART.
(ADEME), Life cycle analysis study of wooden crates, corrugated cardboard and plastic crates for apples, 2000. 3 ART. 110 1 2 of the Environmental Code, LAW n° 2020-105 of 10 February 2020 relating to the fight against waste and the economy: « Les dispositions du présent code ont pour objet, en priorité, de prévenir l'utilisation des ressources, puis de promouvoir une consommation sobre et responsable des ressources basée sur l'écoconception, puis d'assurer une hiérarchie dans l'utilisation des ressources, privilégiant les ressources issues du recyclage ou de sources renouvelables, puis les ressources recyclables, puis les autres ressources, en tenant compte du bilan global de leur cycle de vie.
…puis les ressources recyclables, puis les autres ressources, en tenant compte du bilan global de leur cycle de vie. » GROW International SARL I www.grow-international.eu [email protected] 6 rue François 1er Paris 75008 (France) Tel: +33 (0)1.56.88.36.75 Fax: +33 (0)1.56.88.06.45 be a resource for energy recovery more that being reused. By using waste wood to manufacture sustainable products and to produce climate-friendly energy, 5.8 million tonnes of CO₂ are saved in Germany every year4. That is why recycling targets set up by the regulator to recover wood in the previous revision of the PPWD as materials are low in comparison with other materials. The waste hierarchy of non-sustainable materials versus sustainable materials for packaging should be adapted according to LCA results.
…of non-sustainable materials versus sustainable materials for packaging should be adapted according to LCA results. In addition, it will be very useful to conduct an LCA or PEF comparative study at EU level on packaging materials for selected applications to understand the whole environmental impact. When discussing the sustainability of packaging, its protective function is often neglected and it usually focuses around the type and amount of material used for production. It is worth noting packaging weight can be a criterium but not the main one and the environmental impact of preparing for reuse and recycling phases should always be accounted for. Materials such as plastic are light but with a heavy negative environmental impact and renewable materials like wood are heavier but with a positive environmental footprint (negative carbon footprint).
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