Styrenics Circular Solutions

…1 Proposal for a Packaging and Packaging Waste Regulation – Recycling of XPS packaging shows that a ‘negative list’ would be an obstacle to realising the circular economy Brussels, April 2023 The EU co-legislators are currently discussing the above-mentioned (PPWR) proposal of the European Commission (EC). We fully support its objectives, including preventing or reducing adverse impacts on the environment, and in particular increasing recycling and the use of recycled materials while reducing other forms of recovery and disposal – after all options to prevent waste have been exhausted. To these ends, our industry has been working towards all packaging being economically recyclable by 2030 or earlier. An unofficial leaked draft of the proposal included a pre-determined “negative list” with disparate “characteristics” purportedly preventing or inhibiting recycling.

…a pre-determined “negative list” with disparate “characteristics” purportedly preventing or inhibiting recycling. The EC had not formally and comprehensively consulted on this list, and its original source and logic have remained unclear. The EC has observed that "[t]here is currently no evidence that these packaging design features/ materials will not become recyclable by 2030 as considerable efforts are being made by industry to enable this" (impact assessment, part 2, p. 469). We welcome that, after receiving evidence in response to the leak, the EC decided not to include such a list in its proposal – for good reason, as also the example of extruded polystyrene (XPS) shows. XPS is commonly used to produce foamed food trays for raw meat, fish and tofu.

…of extruded polystyrene (XPS) shows. XPS is commonly used to produce foamed food trays for raw meat, fish and tofu. Its blanket inclusion in a negative list would discriminate against a material that is recyclable, already recycled in practice and generally sustainable (please see below) – without sufficient justification and proper process. The mere assumptions apparently underlying the negative list are clearly outdated in light of recent progress. This progress is part of the increasing recycling of PS in general. It starts with the design for recycling, which is underpinned by RecyClass guidelines for multiple key PS packaging formats. Tests are ongoing to develop a guideline for XPS food trays this year. As other styrenics, PS and XPS can be efficiently sorted with existing technology.

…for XPS food trays this year. As other styrenics, PS and XPS can be efficiently sorted with existing technology. McKinsey found in a survey of mechanical recyclers across Europe in 2020 that 33% of them process PS (figure 2). In 2022, the Joint Research Centre (JRC) of the EC documented a midrange recycling rate of 40% for PS (and expanded PS; p. 21). As national examples, about two thirds of the PS household packaging waste is already sorted for recycling in Germany, according to a report produced in 2021 for the Federal Environment Agency (UBA; p. 132). French producer responsibility organisation (PRO) Citeo announced the establishment of a recycling channel for PS household packaging waste in December 2022. For the Netherlands, a 2021 report for the municipal waste association NVRD observes that PS can be assessed as well recyclable when its chemical recycling starts in 2023 (p. 23).

NVRD observes that PS can be assessed as well recyclable when its chemical recycling starts in 2023 (p. 23). XPS food trays are already, or will be, separately collected at scale for recycling. For example, the French Ministry of Ecological Transition anticipates achieving 100% recyclability in the meat packaging sector by 2025, also based on increasing PS recycling (p. 16). Corepla, the consortium responsible for the recovery of plastic packaging in Italy, has started collecting and sorting XPS food trays (next to PS) for recycling this year, after demonstrating the their closed-loop recyclability in 2022. Spanish PRO Ecoembes also separately collects yoghurt pots and PS food trays with a view to recycling.

…in 2022. Spanish PRO Ecoembes also separately collects yoghurt pots and PS food trays with a view to recycling. Belgium has included XPS trays in its separate collection for recycling in the ’extended blue bag’, and shows just how economical the recycling of PS and XPS is, by demanding the second lowest fee for them among all plastic packaging in 2023 (after transparent colourless PET bottles), based on the so-called net cost principle. Swedish Plastic Recycling will start collecting and sorting all household plastic packaging waste for recycling, including foamed PS, in mid-2023 to 2025. In Portugal, PS and XPS packaging are also separately collected. Austria will include PS yoghurt pots and XPS trays in its separate collection for recycling from 2023 and has just broken ground for the matching sorting capacity.

…in its separate collection for recycling from 2023 and has just broken ground for the matching sorting capacity. Ireland has also included typical XPS applications like meat trays in its separate collection. Ref. Ares(2023)2883511 - 24/04/2023 2 Furthermore, XPS food trays have already been commercialised with up to 50% post-consumer recycled content. Their – indispensable – safety has been demonstrated and recently corroborated in a peer-reviewed study. This is facilitated by the intrinsic properties of PS, which make it very insensitive to processing (e.g. extrusion), allowing for many mechanical recycling loops, and ‘low diffusion’, which has been confirmed by a peer-reviewed study and means that it absorbs and releases little contaminant during use and recycling.

…confirmed by a peer-reviewed study and means that it absorbs and releases little contaminant during use and recycling. The new EU Regulation 2022/1616 allows the use of safe recycled PS as food contact material (FCM) produced with so-called novel recycling technologies, after completing a notification and while complying with stringent monitoring and reporting obligations. In light of all this, pre-determining a negative list based on assumptions and without independent technical analysis and proper consultation would inadvertently contradict the general regime under the PPWR to ensure recyclability, the beneficial effects of the ongoing standardisation work that the EC has mandated, until August 2025, including for PS trays, as well as broader EU policy.

…standardisation work that the EC has mandated, until August 2025, including for PS trays, as well as broader EU policy. Even if the PPWR in theory allowed rebutting presumption of non-recyclability of a such negative list, its chilling effects in practice would jeopardise all the already ongoing work and investments in design, collection, sorting and recycling, inadvertently leading to less recycling as a self-fulfilling prophecy. For similar reasons, over 60 associations from the packaging value chain have opposed it. Moreover, singling-out XPS would lead to regrettable substitution. A 2019 peer-reviewed life-cycle analysis (LCA) by Fraunhofer found that mono-material XPS trays have the lowest environmental impact compared to viable alternatives – even without considering the significant, more recent progress with their recycling.

…compared to viable alternatives – even without considering the significant, more recent progress with their recycling. Therefore, we welcome that the ENVI Rapporteur has not proposed such a negative list in her draft report, and call on all co-legislators to refrain from introducing any such list. We appreciate that the EC has publicly explained the compelling reasons against including it in its proposal (at 53:00) and ask the EC to continue defending its right decision, if necessary. Rather, the general rules should apply without discrimination. The PPWR should provide the EC with a clear timeframe for its delegated acts, which gives packaging producers and users a reasonable transition period, whilst ensuring that packaging is recyclable as quickly as possible.

…and users a reasonable transition period, whilst ensuring that packaging is recyclable as quickly as possible. The signal sent by the general regime of the PPWR will already have a positive effect by encouraging ongoing and further increasing recycling efforts. Ken Huestebeck Policy Director* Avenue des Arts 6-9, 1210 Brussels – Belgium Phone: +32 2 313 39 30 [email protected] Styrenics Circular Solutions (SCS) is the value chain initiative to realise the circular economy for styrenics. The initiative engages the entire value chain in the development and industrialisation of new recycling technologies and solutions. It aims to strengthen the sustainability of styrenic products while improving resource efficiency within the circular economy. Transparency Register no: 198696432927-14 *Providing services through K. BV

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