PETCORE EUROPE

PETCORE Europe Position Paper on: Reducing Packaging Waste – Review of Rules We as PETCORE Europe, representing the complete PET value chain in Europe, fully support the Commission’s strive to reduce packaging waste. Moreover, we believe that setting ambitious yet reachable and measurable targets paves the way to substantially reducing the environmental impact of packaging in Europe. The Packaging and Packaging Waste Directive acts in that spirit and pushes forward recycling goals largely shared by us. Hence, PETCORE Europe welcomes the opportunity to contribute to the current revision of Directive 94/62/EC. In doing so, we would like to stress the importance of the following points as essential elements in the review of packaging rules:

…we would like to stress the importance of the following points as essential elements in the review of packaging rules: 1. A Harmonized Set of Rules on Packaging These allow for long-term planning investments related to packaging and avoid uncoordinated national measures which pose obstacles to the free movement of goods. The review of the Essential Requirements is necessary to ensure they are in line with: the Plastics Strategy, the Circular Economy Action Plan and the EU Green Deal, the European Plastics Pact and the Circular Plastics Alliance. Furthermore, Extended Producer Responsibility (EPR) schemes should be made uniform. 2. A Strong Competitive Market for Secondary Materials A flexible market-based, industrial approach to recycling will ensure the competitiveness of secondary materials from recycled packaging to virgin feedstock. Waste is to become a new feedstock.

…competitiveness of secondary materials from recycled packaging to virgin feedstock. Waste is to become a new feedstock. 3. Packaging Must Be Seen as an Integral Part of the Packed Product In reviewing the rule on packaging the eventual functionality of the product must not be overseen. PET still possesses essential virtues in terms of life cycle assessment (LCA), shelf life, food safety and weight. In fact, in comparison with other materials, PET often outperforms other packaging solutions when it comes to greenhouse gases (Imperial College Study, Examining Material Evidence: The Carbon Fingerprint)

…it comes to greenhouse gases (Imperial College Study, Examining Material Evidence: The Carbon Fingerprint) 4. Re-usable and Biodegradable Packaging are not necessarily the Solution The well-researched LCA of these types of plastics is not always advantageous for the environment compared to single-use alternatives (including rPET). The harmonised market requires packaging that can be handled as a recycle resource at the destination. This is how the balance between reuse and recycle must be considered. Biodegradable plastics have niche markets but are not the panacea for scale.

…reuse and recycle must be considered. Biodegradable plastics have niche markets but are not the panacea for scale. 5. Overregulation Can Impede the Fluidity of the Market. Without impeding on a necessary commonly agreeable definition of ‘design for recycling’, there is no need for overregulation. Overregulation limits and can ultimately stop alternatives that are the preferred option. In other words, regulation must not be at the expense of innovation. Ref. Ares(2021)145442 - 07/01/2021 6. We already Made Great Progress Our industry is already the champion of recyclability in the plastics family but also in other packaging including glass (ex: we have an recycling overcapacity of 250 000 tons per year that will accommodate growth). Collection and sorting is however, the bottleneck to already increase dramatically the circularity of PET in the market.

…and sorting is however, the bottleneck to already increase dramatically the circularity of PET in the market. 7. Science-Based Criteria should be Used to Establish the Environmental Footprint We as an industry through third party auditable data can provide this information. This is vital considering that the European market gets increasingly flooded by cheap Asian products making poorly credible environmental claims. This should be monitored in line with the Circular Plastics Alliance work. 8. Collection and Sorting Schemes Petcore Europe fully supports a circular life and usage of PET. Hence efficient collection and sorting schemes and high-quality sorting facilities should be technologically reinforced so as to increase the level of collection.

…and high-quality sorting facilities should be technologically reinforced so as to increase the level of collection. 9. Promote Recycling (Mechanically and Chemically) Mechanical and chemical recycling ensures the lowest carbon footprint in the packaging industry. Moreover, chemical recycling has the potential to complement mechanical recycling. 10. Design for Recycling We need standardized guidelines for recycling managed by value chain experts in partnership with the Commission as already initiated through the CPA. 11. Definitions Overpackaging, circularity, recyclability, reuse, compostability, biodegradability, secondary raw materials and pre-consumer waste should be clearly defined.

…reuse, compostability, biodegradability, secondary raw materials and pre-consumer waste should be clearly defined. 12. Promote Deposit Return Schemes (DRS) The EU should promote DRS for single-used PET bottles or if necessary for recycled refillable PET bottles as it was implemented in Northern Europe and Germany 10 years ago. This will ensure a 90% collection rate with the best LCA score of all packaging.

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