Eastman Chemical Company

Eastman feedback to European Commission consultation on PPWR proposal April 2023 Eastman welcomes the opportunity to provide feedback on the European Commission’s proposal for the revision of the Packaging and Packaging Waste Regulation (PPWR). We fully support the effort of the Commission to harmonise the rules regarding packaging and packaging waste to avoid distortion of the Single Market and to accelerate the circular economy for plastic packaging. Eastman is very pleased with the ambitious targets in the proposal that are in line with the waste hierarchy, namely reduce, reuse, and recycle (3R), in particular, the ambition for all packaging to be recyclable and the introduction of the recycled content targets.

…in particular, the ambition for all packaging to be recyclable and the introduction of the recycled content targets. In situations where the 3R concept is not applicable, we believe that compostable or biodegradable plastics provide a significantly more sustainable solution than landfill or incineration. In order to achieve those targets and to ensure that materials on the market are used in the economy as long as possible (circular economy for materials), certain enabling conditions are necessary. Below we outline our proposal towards recycling technologies, recyclability criteria, scope and methodology for calculating the recycled content, as well as additionally emphasizing the necessity to implement the appropriate sorting technologies in the Member States.

…well as additionally emphasizing the necessity to implement the appropriate sorting technologies in the Member States. Recycling For the definition of recycling, the proposal refers to the Waste Framework Directive, which already defines what recycling is, namely waste to products, materials and substances. We fully support this definition and welcome the reference to high-quality recycling in the PPWR proposal, which will ensure that valuable materials are kept in a circular loop.

…to high-quality recycling in the PPWR proposal, which will ensure that valuable materials are kept in a circular loop. Only by the combined use of all recycling technologies - mechanical, physical, and chemical recycling the EU can make sure that: - the amount of plastic waste that ends up in landfills, that is incinerated or winds up in our environment is kept to the minimum, - the amount of waste for reprocessing into new products, materials or substances whether for the original purpose or other purposes is maximised, - the recycling targets can be met, and - that there is sufficient supply of recycled plastics/secondary raw materials. Recyclability Eastman fully supports the goal that all packaging placed on the market is recyclable by 2030. However, to achieve this, investments are needed to ensure the right infrastructure is in place to collect, sort and recycle plastic waste.

…this, investments are needed to ensure the right infrastructure is in place to collect, sort and recycle plastic waste. This requires creating appropriate conditions and especially ensuring legal certainty, predictability, and openness to innovate followed by timely investments and roll-out of that infrastructure. It is therefore essential that the “state-of-the-art” processes (as mentioned in Articles 3 (31 & 32) cover existing as well as developing innovative future technologies to collect, sort and recycle. It should not hinder the scaling up of those technologies that are currently under development, or the development of new technologies that could provide more efficient and sustainable solutions. As packaging evolves so will recycling and sorting technologies, as they will become more effective and optimized with better yields over time. Ref.

…recycling and sorting technologies, as they will become more effective and optimized with better yields over time. Ref. Ares(2023)2890792 - 24/04/2023 Therefore, when developing the design for recyclability criteria in a delegated act, the Commission should consider future proof criteria and cover emerging and innovative technologies that will be available by 2030 to help making packaging recyclable. Example: Currently, new technologies are being developed to aid sorting – e.g. digital watermarking will help with more granular sorting of waste, something not possible with existing technologies, consequently increasing recycling of packaging waste.

…of waste, something not possible with existing technologies, consequently increasing recycling of packaging waste. The practical result of such new sorting technologies can be seen in the example of small cosmetic packaging (nail polish, lipstick, etc.), which at present often is not sorted because the outdated technologies being used are unable to divert these articles to recycling streams. Therefore, they end up with mixed waste in landfills or incineration. With new and innovative sorting technologies, both hardware and digital identification solutions, which are being developed, these small pieces of packaging can be sorted and sent to recycling so a true circularity can be created, avoiding that packaging sizes need to be increased or valuable resources incinerated.

…true circularity can be created, avoiding that packaging sizes need to be increased or valuable resources incinerated. Also, new recycling technologies are being developed to increase the quality of the recycled materials so true circularity can be created and the EU’s dependency on natural resources can be reduced significantly. Example: In 2022 Eastman initiated its investment in a molecular recycling facility (chemical recycling via depolymerization) in France.

Eastman initiated its investment in a molecular recycling facility (chemical recycling via depolymerization) in France. Our recycling technology will have the capability to recycle almost any kind of polyester-rich waste (mixed hard-to-recycle plastic waste including polyester-rich textiles) an infinite number of times into high-quality (food grade) secondary raw materials, which will help to reduce the amount of primary raw materials used in products and to provide a solution to those materials that cannot mechanically be recycled and end up in incineration or landfill. Recycled content: Scope of plastic waste Plastic waste is not only generated by plastic packaging for consumer use.

Recycled content: Scope of plastic waste Plastic waste is not only generated by plastic packaging for consumer use. To tackle the plastic waste issue in the EU and to cut our dependency on natural resources, it is essential that all plastic waste is recycled and that we keep valuable materials in a circular loop and ensure a sufficient supply of secondary raw materials. There are advanced technologies, like the Eastman molecular recycling technology, that can recycle plastic waste coming from different waste streams to produce high-quality secondary materials. Therefore, plastic waste that counts towards recycled content should include all plastic waste and not be limited to only post-consumer plastic waste and be aligned with the already existing definitions (e.g. ISO 14021). There is immense value in using post-industrial waste and pre-consumer waste as recycling feedstocks.

(e.g. ISO 14021). There is immense value in using post-industrial waste and pre-consumer waste as recycling feedstocks. From the 53.6 Mt of total plastic production in the EU on average only 9.1 Mt enters recycling facilities of which 5,5 Mt is actually recovered and put back into production1. Therefore, it is critical to recycle all plastic waste through advanced methods rather than see plastics landfilled or incinerated, or, worse, see them end up in our environment. Therefore, all plastic waste should be recycled, and all plastic waste must contribute towards the recycled content targets to ensure a sufficient supply of secondary raw materials. Recycled content: Sorting technologies To guarantee a certain output of secondary raw materials it is essential to have continuously sufficient volumes of feedstock.

…a certain output of secondary raw materials it is essential to have continuously sufficient volumes of feedstock. Therefore, all plastic packaging should be collected without introducing too complex at-home sorting processes that put an unnecessary burden on consumers and risk losing valuable material. Investments in enhanced sorting technologies will help to sort all the collected 1 Source: Plastics Europe. The Circular Economy for Plastics - A European Overview. 2022. Data 2020 EU27+3. packaging appropriately. Moreover, to ensure that waste within Europe can be recycled in a sustainable and economically viable way, and to bring recent and newly developed technologies at scale, it is essential that Member States take a cooperative role when dealing with waste management and eliminate waste shipment barriers within the EU.

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