European Container Glass Federation

December 2020 1 Public consultation to inform the review of the requirements for packaging and other measures to prevent packaging waste FEVE position paper FEVE is the association of European manufacturers of glass containers. The glass packaging industry producing a wide range of glass packaging products for food and beverages, perfumery, cosmetics and pharmacy for European and global customers. The European Container Glass manufacturing is a genuine circular model, which perfectly fits with the EU’s ambition to build a circular economy. FEVE is therefore committed to support the European Commission in assessing the options for reinforcing the Packaging and Packaging Waste Directive (PPWD)’s Essential Requirements and other measures to reduce the generation of packaging and packaging waste.

Directive (PPWD)’s Essential Requirements and other measures to reduce the generation of packaging and packaging waste. FEVE supports the general objective of the Directive, which is to ensure a well-functioning internal market through fully harmonised rules on packaging, while tackling negative impacts on the environment and health from packaging and packaging waste. In addition to our contribution to the public consultation, we would like to outline in this document our position on some of the policy options considered by the European Commission, as well as on additional measures that would help achieve the objectives of the Packaging and Packaging Waste Directive.

…well as on additional measures that would help achieve the objectives of the Packaging and Packaging Waste Directive. Overall, we regret that the questionnaire of the public consultation only allows stakeholders to assess the level of effectiveness and efficiency of the proposed policy measures based on the environmental and cost impacts they would have, without providing the opportunity to highlight additional important considerations or to make a distinction between different packaging materials or formats when necessary. Executive summary I. Waste prevention measures: While we fully share the European Commission’s objective to reduce over-packaging and packaging waste, any waste prevention measures should take into account the differentiated contribution of various packaging materials to waste generation and their intrinsic properties (e.g.

…the differentiated contribution of various packaging materials to waste generation and their intrinsic properties (e.g. ability to be recycled again and again without degrading over time). Waste prevention should be achieved through reduction at source by material and circular packaging materials such as glass should not be discriminated against because of their weight. In addition, potential measures to address “overpackaging” should duly take into account packaging functionalities, which should be acknowledged and protected. Finally, reuse models in packaging for transport and logistics have existed for a very long time, whereas consumer packaging reuse models are much more complex and less contemporary. Despite this there are many examples of such reusable glass packaging systems in place.

…complex and less contemporary. Despite this there are many examples of such reusable glass packaging systems in place. Although setting targets for reusable packaging sound appealing, FEVE cautions that setting such targets do not reflect the complexities and dynamics of the packaging market and may not be effective to promote consumer reuse packaging. II. Measures to reinforce the essential requirements to improve design for reuse and promote high quality recycling and strengthen their enforcement: FEVE fully supports the Commission’s intention to require that all packaging placed on the EU market shall be reusable or recyclable in an economically viable way by 2030 and to introduce a clear, harmonised and enforceable definition of “recyclable packaging”.

…viable way by 2030 and to introduce a clear, harmonised and enforceable definition of “recyclable packaging”. The definition of “recyclable packaging” proposed by EUNOMIA in the final report on the Effectiveness of the Essential Requirements for Packaging and Packaging Waste and Proposals for Reinforcement is comprehensive and a very good basis for further discussion and could be complemented by the use of design for recycling methodologies. Ref. Ares(2020)7795481 - 19/12/2020 December 2020 2 Permanent materials that can be recycled over and over again without losing their inherent properties must be incentivised as they reduce dependence on the use of virgin materials for packaging and are safe for human health and the environment. III.

…reduce dependence on the use of virgin materials for packaging and are safe for human health and the environment. III. Measures related to increasing recycled content in packaging to ensure a well-functioning market for secondary raw materials: Introducing requirements on recycled content has been conceived as a market driver for materials which today are not effectively recycled due to technical and market limitations directly linked to their inherent properties. This approach is not effective for fully recyclable materials such as glass for which the increase of the average recycled content is directly linked to the availability of more, better-quality collected glass. IV.

…of the average recycled content is directly linked to the availability of more, better-quality collected glass. IV. Additional measures for consideration to ensure the safe recycling of packaging materials into food contact applications: FEVE supports policy initiatives that set rules to ensure the safe recycling of packaging materials into food contact applications. The success of the circular economy will depend on a market for secondary raw materials that competes in terms of cost, quality and safety with virgin raw materials. In that context, emphasis should be made on closed loop recycling for food contact materials, to increase the safety of the recycled materials that enter into contact with food and policy options relating to the use of hazardous substances in packaging should be considered in the revised Packaging and Packaging Waste Directive. *** I.

…hazardous substances in packaging should be considered in the revised Packaging and Packaging Waste Directive. *** I. Waste prevention measures The European Commission notes that “despite an overall trend towards light weighting across a wider range of packaging formats in the last three decades, there has been an overall increase in packaging waste generated” and the generation of packaging waste reached a record high in 2017. It will therefore consider measures to reduce over-packaging and packaging waste. 1. Member State level packaging waste generation reduction targets or limits While we fully share the European Commission’s objective to reduce over-packaging and packaging waste, FEVE does not support Member State level packaging waste generation reduction targets or limits relative to population or Gross Domestic Product (GDP).

…level packaging waste generation reduction targets or limits relative to population or Gross Domestic Product (GDP). • Glass packaging waste generation has remained stable: While overall, the quantity of packaging waste generated has indeed been increasing (9% growth in tonnage between 2007 and 20171), the glass packaging waste tonnage has remained stable thanks in a large part to light weighting and reuse. Glass bottles and jars have seen a 35% reduction in unit weight since 1990, well above the all packaging average of 26% decrease in unit weight. In addition, by collecting and using recycled glass multiple times in a closed loop, the glass industry significantly reduces the use of other virgin raw materials. Glass recycling has increased by more than 139% in the last 20 years and 76% of glass is collected to be recycled into a bottle closed loop in Europe today.

…than 139% in the last 20 years and 76% of glass is collected to be recycled into a bottle closed loop in Europe today. Despite the growth in glass packaging, normalised comparison of GDP versus waste generation between 2010 and 2017 (normalised to 2010) shows that for glass packaging the rate of increase in waste generation was below that of the rate of increase in GDP, inferring, unlike other materials, that a level of decoupling occurred (see Annex for more details). The normalised comparison of population versus waste generation between 2010 and 2017 (normalised to 2010) highlights that 1 Eunomia Background Paper to Packaging Waste Prevention workshop, p.7 December 2020 3 in all cases the rate of generation of waste was higher than that of population growth, but less so for glass packaging (see Annex for more details).

…of waste was higher than that of population growth, but less so for glass packaging (see Annex for more details). • Switching to a lighter alternative material does not constitute waste prevention: In the Background Paper on Packaging Waste Prevention, Eunomia notes that Permanent Materials – glass and metals – which can be infinitely recycled without losing their properties have been to some extent substituted by other materials and “difficult to recycle packaging”2. There must be an approach to ensure that all packaging reduce their environmental impact for their own material. Switching to lighter materials from heavier materials will not necessarily reduce environmental impacts but could result in fact in increased adverse consequences and volumes of units of unrecyclable/unreusable packaging.

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…1 March 2023 European Container Glass industry Position Proposal for a Packaging and Packaging Waste Regulation By 2050 the container glass industry aims to achieve a major revolution, starting now, in the way we produce glass that is fit for a circular and climate-neutral economy. The container glass industry is strategic to the European economy because it services the essential European food, beverage and pharmaceutical sectors as well as cosmetics and perfumery. The industry serves these sectors in domestic markets and is an enabler for the export of high-end products across the world, which in turn delivers wealth to our economies through trade. Products likely to be packed in glass contributed €250 billion to EU external trade in 2019. The European Container Glass manufacturing is a genuine circular model, which perfectly fits with the EU’s ambition to build a circular economy.

…manufacturing is a genuine circular model, which perfectly fits with the EU’s ambition to build a circular economy. We are proud to work with a material that is fully reusable and infinitely recyclable as well as inert to keep products safe and secure. Our members work with their European and global customers to right-weight glass bottles, jars and flacons to deliver fit-for-purpose packaging. FEVE supports the objectives of the proposal for a Packaging & Packaging Waste Regulation to ensure a well- functioning internal market, tackle the negative environmental and health impacts from packaging and packaging waste and promote the circularity of packaging. We welcome the European Commission’s ambition to further promote the circularity of packaging.

…of packaging. We welcome the European Commission’s ambition to further promote the circularity of packaging. We consider however that some of the proposed measures would have strong repercussions on EU consumers and industry in Europe and abroad, without contributing to achieving the objectives of the Regulation. You will find below a summary of our position, which is then further explained in this document. Packaging waste Prevention: • We support material-specific waste reduction targets (as opposed to the proposed overall waste reduction targets) to ensure all packaging materials contribute individually, equally and fairly to waste reduction. • Packaging performance criteria must acknowledge ‘product presentation’ to minimise the weight of packaging while allowing packaging design to provide for product identification by the end user or consumer.

…weight of packaging while allowing packaging design to provide for product identification by the end user or consumer. This would maintain the ability of brands to differentiate, to make products stand out on the shelf and to appeal to consumers. The packaging minimisation criteria should be consistent with intellectual property rights, such as trademarks, industrial design rights, geographical indications, which are recognised by and protected under EU laws. • Reuse targets are acknowledged as an important waste prevention measure, but it is paramount to ensure that reuse can be implemented in a safe, economically viable and environmentally sustainable way that would bring tangible benefits compared to recyclable one-way packaging. Recyclability: The recyclability requirements in the proposal are comprehensive and a very good basis.

…packaging. Recyclability: The recyclability requirements in the proposal are comprehensive and a very good basis. We would welcome more ambition in the Regulation with regards to closed-loop recycling, high-quality recycling, ‘recycled at scale’ and the timing for the implementation of the recyclability criteria. Separate collection: The Regulation should emphasise the importance of separate collection as a prerequisite to guaranteeing high-quality recycling processes and to the fulfilling of the recyclability criteria. Derogation for substances in glass packaging: We welcome the reassertion of Decision 2001/171/EC of 19 February 2001 establishing the conditions for a derogation for glass packaging in relation to the heavy metal concentration levels to encourage recycling and ensure the uptake of recycled glass. Ref.

…relation to the heavy metal concentration levels to encourage recycling and ensure the uptake of recycled glass. Ref. Ares(2023)2799454 - 20/04/2023 2 Deposit return schemes (DRS) for one-way glass packaging: We welcome that the proposal does not include glass packaging in the scope of the mandatory Deposit Return Schemes (DRS) for single-use packaging, therefore acknowledging that DRS are not the best solution to improve the collection for recycling rate of one- way glass packaging and would put at risk the well-functioning existing glass collection systems in the EU (bottle banks and kerbside collection). Recycled content: We welcome that no Recycled Content targets are set on glass packaging. Introducing mandatory targets on recycled content has been conceived as a market driver for materials that do not have well-functioning secondary raw material markets.

…has been conceived as a market driver for materials that do not have well-functioning secondary raw material markets. This approach is not effective for fully recyclable materials such as glass for which demand of recycled material largely exceeds supply. Packaging Forum: Packaging experts should be involved in the development of highly technical secondary legislation, and we recommend the creation of a Packaging Forum. *** I. PACKAGING WASTE PREVENTION a.

…secondary legislation, and we recommend the creation of a Packaging Forum. *** I. PACKAGING WASTE PREVENTION a. Packaging Waste reduction targets per capita at Member State level need to be material- specific (Article 38) • It is important to underline that “Packaging put on the market” is used as a proxy for “Packaging Waste Generated”, meaning that the highly ambitious reduction targets proposed (projected reduction of 19% in 2030, 29% in 2035 and 37% in 2040 in real terms) will promote reuse and lightweighting of packaging but may also limit the availability of packaging that is essential to deliver products to end consumers. • The Commissions aims to reduce the overall amount of packaging put on the market and to minimise the environmental impact of packaging.

…aims to reduce the overall amount of packaging put on the market and to minimise the environmental impact of packaging. The generation of glass packaging waste per capita, however, has remained stable over the past decade and is expected to remain relatively stable according to the European Commission’s figures. This is unlike the waste generation per capita of other packaging materials that has been subjected to a constant increase and is foreseen to significantly grow. • We are concerned by the setting of packaging waste reduction targets that are not material-specific. We commend the vision and the intention to reduce waste, but it should focus on materials that create the biggest waste challenges. The best way to achieve this objective is to switch as much packaging as possible to materials that can be reused and infinitely recycled in a closed loop.

…is to switch as much packaging as possible to materials that can be reused and infinitely recycled in a closed loop. Unfortunately, the current proposal might lead to the exact opposite as it incentivizes the wrong behaviour. This will cause severe market distortions, providing incentives to shift from heavier but circular (glass in particular) to lighter but difficult to recycle or reuse packaging materials. This would not necessarily reduce environmental impacts but could result in fact in increased adverse environmental consequences. This is highlighted by the European Commission in its impact assessment “Light-weighting of packaging has been accompanied by a shift to materials with a worse environmental footprint, particularly from metal and glass to plastic and paper/board”1.

…to materials with a worse environmental footprint, particularly from metal and glass to plastic and paper/board”1. • The PPWR Impact Assessment shows that the proposed overall reduction targets will not ensure that all packaging materials contribute individually, equally and fairly to waste reduction. 1 PPWR Impact Assessment report (SWD(2022) 384) – Part 1, p.10 3 The following graph shows the reduction in packaging waste generation in 2030 compared to the 2018 baseline, as a result of a waste reduction target of 4% compared to 2018 (based on figures in the Impact Assessment) • We consider it critical that any packaging waste reduction targets would be material-specific to ensure that all packaging reduce the volumes and units of packaging they put on the market (effort sharing).

…to ensure that all packaging reduce the volumes and units of packaging they put on the market (effort sharing). Waste prevention through reduction at source by material (as per the CEN standard EN 13428) should remain a key guiding principle whereby “the substitution of one packaging material by another is not a basis for source reduction”. • Leaving ample room for Member States to choose their own waste reduction measures (waste prevention and/or reuse targets) to achieve the waste reduction targets would result in divergent provisions and market barriers. Member States should not be allowed to deviate from the requirements of Article 4 of the proposed Regulation (Free movement) when putting forward measures aimed at preventing packaging waste generation.

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