Kotkamills Oy

Kotkamills position on Review of the requirements for packaging and other measures to prevent packaging waste - Ares(2020)3041578 Kotkamills is made of three separate but united business lines working together as a forerunner of the circular economy. Kotkamills Wood produces high quality timber products and deliver raw materials as a by-product for other businesses. Absorbex Oy is a world leading producer of saturating base kraft utilising saw dust and recycled fibre as a raw material. The Consumer Boards businesses serve the consumer packaging industry with plastic free AEGLE and ISLA products which are designed for easy recycling. To provide excellent protection for food products, the properties of AEGLE and ISLA boards can be enhanced for high grease and liquid resistance, with water-based, aqueous, dispersion barriers.

…and ISLA boards can be enhanced for high grease and liquid resistance, with water-based, aqueous, dispersion barriers. Environmentally-sound food packaging and disposable cups, which meet all necessary food and safety requirements, are therefore a conscious, sustainable choice for the food industry. Kotkamills warmly welcomes the Commission’s ambitious Green Deal and its targets for reducing emissions, promoting safe and sustainable chemicals, European Forest Strategy and further developing the circular economy. By creating a comprehensive and clear guideline for Circular Economy, the Commission released its Circular Economy Action Plan in spring of 2020, which included high ambitions for packaging and packaging waste. We believe packaging plays a major part in modern society and is heavily dependent on feed stocks that are renewable, easily recyclable and/or biodegradable.

…in modern society and is heavily dependent on feed stocks that are renewable, easily recyclable and/or biodegradable. As part of the Commission’s circularity drive, the essential requirements for packaging, listed in Annex II of Directive 94/62/EC, are currently being reviewed. In order to ensure the bio-based economy continues to play an important role in producing sustainable, circular packaging in Europe, Kotkamills would like to highlight the following recommendations for improving the essential requirements of the Packaging and Packaging Waste Directive: • Create clear, standard-based and technology-neutral definitions for biodegradability and compostability of packages.

…clear, standard-based and technology-neutral definitions for biodegradability and compostability of packages. We are pleased to see this is recognised by the recent Eunomia report on the effectiveness of the requirements of the PPWD as a main area that needs strengthening, and that they push for the consideration of compostable packaging in certain applications; • Create clear and predictable standards for what is considered recyclable and taking into account recycled fibres and their benefits; • Clear definitions between words plastic and polymer. Sustainable and safe chemicals also play a major role in packaging. Actions against plastics are extremely welcomed, but it cannot be replaced by materials that create unsustainable or potentially hazardous impacts to human health.

…but it cannot be replaced by materials that create unsustainable or potentially hazardous impacts to human health. Therefore, we also wish to highlight the following: • Fluorinated chemicals have unknown impacts to human and animal health. We therefore advocate for the introduction of regulatory measures to reduce the use of fluorinated chemicals within the PPWD or during the upcoming revision of the Food Contact Materials Ref. Ares(2020)4137178 - 06/08/2020 regulation. We welcome efforts by countries like Denmark to restrict their use and encourage the EU to make this Union-wide. Saila Kettunen +358 40 831 4763 Business Unit Director Päivi Suutari +35840 501 8319 Barrier Boards Development Director For more information, visit www.kotkamills.com

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