UNESDA

Page 1 of 6 UNESDA submission to the European Commission public consultation on reducing packaging waste – review of rules Overview of UNESDA UNESDA - Soft Drinks Europe is the Brussels-based trade association for the non-alcoholic beverages sector, representing European producers of soft drinks including carbonates, still drinks (e.g. ice teas), energy drinks and fruit-based drinks. The membership of UNESDA comprises 24 national beverages associations and 9 companies with operations in several member states. The EU soft drinks sector is rooted in the European economy and society. It employs 1.7 million people throughout its €185 billion value chain with 424 soft drinks production and bottling plants across the EU. UNESDA fully supports the input provided to this consultation by its umbrella association FoodDrinkEurope. In this present submission, UNESDA places emphasis on some of the…

UNESDA places emphasis on some of the key aspects of major importance and relevance to the EU soft drinks sector. 1. Taking realistic and resourceful measures on waste prevention In the consultation on reducing packaging waste, the Commission makes a number of proposals as to appropriate policy measures to tackle packaging waste in the long term. The input below addresses a number of those proposals and elaborates the soft drinks industry’s vision on circular packaging. Waste as a resource UNESDA members have always been supportive of reducing packaging waste and have therefore already taken several actions to that effect. UNESDA considers it is crucial to continue protecting the very principles of circular economy, meaning that a packaging that is easily recyclable, sorted, collected and recycled, must be considered as a full and legitimate part of that circular thinking.

…recyclable, sorted, collected and recycled, must be considered as a full and legitimate part of that circular thinking. UNESDA shares the Commission’s perspective that too much packaging is not collected and recycled at the moment1, and we believe the expected results of the recently agreed requirements for beverage containers in the SUP Directive which, properly implemented, could lead to even higher recycling rates. This is why we favour avoiding packaging where possible, and when it has to be used, packaging waste must be considered a resource (product, packaging): a beverage container that is designed to have the least environmental footprint and is recycled back to a beverage container or upcycled differently, is a resource because it prevents the use of virgin materials, in line with the Green Deal objectives of improving resources management.

…it prevents the use of virgin materials, in line with the Green Deal objectives of improving resources management. We share the goal of the Commission to reduce litter and marine litter, and we believe this can be achieved through circularity, by collecting more than 90% of beverage packaging as well as boosting the uptake of recycled content in beverage bottles. We would not however support specific targets linked to consumption reduction or sales reduction, which would contradict directly the fact that packaging waste can and should be considered a resource for circular economic models. 1 According to recent reports, for example from Eunomia, there is about 12% recycled content on average in PET bottles around Europe. Ref. Ares(2020)7791869 - 19/12/2020 Page 2 of 6 Packaging has functionalities Our industry uses packaging as a way to safely deliver its products to consumers.

…2 of 6 Packaging has functionalities Our industry uses packaging as a way to safely deliver its products to consumers. UNESDA calls on the Commission to recognise as central to the functionality of packaging: that packaging serves a safety and hygiene purpose, but also has other roles to play. For example, packaging allows consumer information to reach consumers as required by EU and national legislation. UNESDA believes overpackaging should have one clear and prescriptive definition. Multipacks should not automatically fall under the ‘overpackaging’ category failing to consider their functionality. Multipacks are needed for product integrity during transport and distribution, to facilitate consumer experience, and to respect the recommended portion control measures that respect EU dietary standards.

…consumer experience, and to respect the recommended portion control measures that respect EU dietary standards. Underpackaging is the other extreme that the revised Essential Requirements will have to avoid. There are no absolute references to define what should be the “right” amount of packaging and for a good reason: food and beverage packaging can only be assessed in relation to the product it contains therefore overpackaging and underpackaging should be defined as packaging that does not meet the functionalities expressed in the essential requirements. UNESDA considers it is crucial to ensure minimum common requirements are respected across Europe to promote the use of only circular packaging. This will better help the sector pivot for innovative and circular solutions.

…the use of only circular packaging. This will better help the sector pivot for innovative and circular solutions. Our members are also trying to find alternative delivery systems such as ‘in bulk’ soft drinks and the kind, but bringing such changes at scale require a major transition of business practices, consumer acceptance, as well as clear supporting public policies. Innovation is key UNESDA calls on the Commission to ensure that the revision of the essential requirements for packaging can also leave room for the exploration of innovative design and new packaging solutions – in full respect of the objectives of reducing the environmental footprint of packaging. While having different objectives, the Directive will have to adapt to new packaging, new end-of-waste management options and ensure that it will be relevant for the next 10 years and beyond.

…packaging, new end-of-waste management options and ensure that it will be relevant for the next 10 years and beyond. In practical terms, this also means for EU authorities to take action to unleash recycling innovation by validating pending authorisations for mechanical recycling and providing a clear regulatory framework for enhanced recycling and other innovative solutions (e.g. enzymatic recycling) to allow all players to move to the next level. Fiscal instruments must not fragment the EU market UNESDA continues to believe that further fiscal measures – such as taxes on plastic packaging – are not the most efficient tool to prevent waste and to drive the innovation and investments needed to meet the intended policy objectives of the Green Deal - especially not at a time when European industry is trying to recover from a significant economic recession caused by the COVID-19 pandemic.

…time when European industry is trying to recover from a significant economic recession caused by the COVID-19 pandemic. UNESDA’s perspective is that taxation must be predictable, transparent, non-discriminatory, and designed in a way that limits substitution or distortion of competition. The plastic packaging tax, as proposed at EU level, should be harmonized so as to respect the Single Market. Fundamentally, we disagree that such a levy will be dispersed into the general budget or recovery fund, while we believe that it should be earmarked for the necessary investments in infrastructure to collect (e.g. DRS and EPR schemes) and recycle more plastic packaging.

…the necessary investments in infrastructure to collect (e.g. DRS and EPR schemes) and recycle more plastic packaging. Even if the rate of the levy differs from one country to another, we believe design elements and thresholds should be the same in all EU countries in order Page 3 of 6 to avoid fragmentation of the EU single market, and support the creation of a well-functioning secondary raw material market in Europe. As a matter of principle, a packaging tax should not be levied on recycled content. Deposit-return schemes are a way to prevent waste by leading to closed-loop recycling We also believe collection should continue to be considered central in transforming waste into a resources.

…recycling We also believe collection should continue to be considered central in transforming waste into a resources. In the case of beverage packaging, UNESDA considers well-designed deposit-return schemes (DRS) an efficient recovery scheme for reaching the European collection targets for beverage bottles and for safeguarding the quality of recycled PET that our industries need. In order to ensure their efficiency, we call for the European Commission to develop EU guidelines, by 2022, for minimum requirements for the functioning of new DRS around Europe and its cost-efficient implementation. 2. Making the recyclable choice the rewarding choice Recyclability is a condition of circularity UNESDA strongly commends the Commission’s goal of making all packaging recyclable or reusable by 2030. Our members have been working for years to increase the use of recyclable packaging.

…recyclable or reusable by 2030. Our members have been working for years to increase the use of recyclable packaging. In 2020, more than 90% of the primary packaging used by the soft drinks industry is recyclable. Only a few packaging formats are still striving for recyclability (e.g. pouches). UNESDA supports exploring measures that aim to strengthen the definition of recyclability and enforce it, as well as ensuring incentives through eco-modulation for recyclability, but invite the Commission to build on existing achievements for PET recyclability in particular: UNESDA is a founding member of the European PET Bottle Platform (EPBP), which provides ambitious guidelines to ensure PET recyclability.

27 → 12

originalus šaltinis (PDF) ↗

Page 1 of 4 UNESDA SUBMISSION TO THE CONSULTATION ON THE INCEPTION IMPACT ASSESSMENT ON REDUCING PACKAGING WASTE – REVIEW OF RULES Overview of UNESDA UNESDA - Soft Drinks Europe is the Brussels-based trade association representing the non-alcoholic beverages sector, representing European producers of soft drinks including carbonates, still drinks (e.g. ice teas), energy drinks and fruit-based drinks. The membership of UNESDA comprises 24 national beverages associations and 9 companies with operations in several member states. The EU soft drinks sector is rooted in the European economy and society throughout its €185 billion value chain - employing 1.7 million people throughout its value chain, and with 424 soft drinks production and bottling plants. UNESDA fully supports the input to this consultation provided by its umbrella association FoodDrinkEurope.

…plants. UNESDA fully supports the input to this consultation provided by its umbrella association FoodDrinkEurope. In this present submission, UNESDA places emphasis on some of the key aspects of major importance and relevance to the EU soft drinks sector. Making packaging more circular The EU soft drinks sector is delivering beverages to all EU consumers in different formats, using different packaging (aluminum, glass, plastics, carton beverage). Packaging is a means to an end: storing, transporting and delivering our beverages in a safe and convenient way for the right consumption circumstance. Our industry has long been supporting sustainability and circularity objectives. We agree more needs to be done: UNESDA members want to actively contribute in making beverage packaging in general more sustainable.

…needs to be done: UNESDA members want to actively contribute in making beverage packaging in general more sustainable. UNESDA members want more packaging collected and recycled or refilled and not discarded or left to blight our environment. This is why our industry committed to making its packaging recyclable, collected and recycled, and using recycled content to a minimum of 25% by 2025, with some of our members have already taken even more ambitious commitments. We very much welcome the reference in the inception impact assessment to multistakeholder initiatives such as the Circular Plastics Alliance as we believe achieving a circular economy is a complex task, where a number of different factors must be taken into account, requiring the full mobilisation of industry, governments, consumers, academia and civil society.

…be taken into account, requiring the full mobilisation of industry, governments, consumers, academia and civil society. Ensuring positive environmental impact of new requirements UNESDA supports the review of the essential requirements for reuse and high quality recycling of packaging, hence the need to support sustainable packaging that is recyclable, recycled and using recycled content, which considerably reduce the environmental footprint of beverage containers. We believe the impact assessment should look at science-based criteria to establish those requirements (such as lifecycle analysis) in order to avoid unintended environmental consequences.

…to establish those requirements (such as lifecycle analysis) in order to avoid unintended environmental consequences. UNESDA is committed to using more reusable packaging where it makes environmental and economic sense: any objective on reusable packaging is conditional on having in place a collection scheme like DRS, should be accompanied by a long transition phase to accommodate a systemic change that will be needed, Ref. Ares(2020)4085658 - 03/08/2020 Page 2 of 4 as it is particularly complex in supply chains. Packaging sustainability is affected by a number of factors and we are focused to make all packaging circular and sustainable and we therefore need to have a holistic approach of various packaging formats, that can be complementary to promote more sustainable packaging.

…have a holistic approach of various packaging formats, that can be complementary to promote more sustainable packaging. Reuse, repair and recycling are different tools that each contribute, when optimised, to achieving circularity of the EU economy. Optimising recyclability, collection, recycling and building a competitive secondary raw materials market We fully support the assessment of the Commission that in order to boost the uptake of recycled content, there should be a competitive secondary raw materials market in Europe. Efficient collection schemes and high-quality sorting facilities to increase collection of all beverage containers are needed to ensure the availability of food-grade quality rPET and continue to successfully recycle aluminium and glass in a sustainable way.

…availability of food-grade quality rPET and continue to successfully recycle aluminium and glass in a sustainable way. We believe it is crucial indeed that producers are encouraged to strive for recyclability, that collection systems are optimised, in order to increase recycled rates of all packaging. Indeed, to support this agenda, efficient collection schemes to avoid littering and increase collection of all beverage containers will be crucial. Deposit return schemes - where consumers return their packaging to collection points - can be an effective way to reach collection and recycling targets with the right conditions in place, and we believe that the Commission should develop guidance on the matter to ensure the implementation and proper functioning of DRS across Europe.

…should develop guidance on the matter to ensure the implementation and proper functioning of DRS across Europe. To this date, the beverage industry is the only sector with mandatory collection and recycled material use targets. However, the availability of food-grade quality rPET is not sufficient. Many other sectors compete for this material too. This is why we believe beverage containers should be dedicated to closed loop recycling, not only to ensure the beverage sector can reach its mandatory targets, but also to avoid downcycling and that high quality material continue being used for food-grade purposes. We also believe that exports of high-quality material outside of Europe (e.g. China) is detrimental to further use of recycled material within the EU market.

…material outside of Europe (e.g. China) is detrimental to further use of recycled material within the EU market. We call on the Commission to develop guidance to promote the circularity of materials especially with regards to restricting recycling of foodgrade PET into foodgrade rPET to secure adequate supply without compromising safety standards for the food and beverage sectors. This will not only improve the availability of secondary raw material but will inevitably impact positively the separate collection. We also believe that incentivising a stronger uptake of recycled content should come with long-term perspectives and legal certainty for economic operators: indeed, investing in recycling innovations, infrastructures, networks, require long-term planning.

…economic operators: indeed, investing in recycling innovations, infrastructures, networks, require long-term planning. We absolutely share the vision of the European Union to promote sustainable packaging that uses resources wisely, has increased amount of recycled material and its life-cycle serves the goal of climate neutrality. But to achieve that, it needs to be clear that sustainable packaging can be part and contribute positively to circularity and that it should not be banned, hence the need for legal certainty and long-term vision. Reducing packaging waste generation As producers, we have always been supportive of reducing raw material usage, waste, and that reducing CO2 emissions is of paramount importance.

…been supportive of reducing raw material usage, waste, and that reducing CO2 emissions is of paramount importance. While we share the Commission’s perspective that too much packaging is not recycled at the moment, we believe that all aspects of the issue must be taken into consideration, including reducing food Page 3 of 4 waste and increasing the shelf lives of food and drink products, as well as food safety, supply chain constraints, etc. This is why we believe than rather than strive for absolute targets of reducing packaging waste, it is also about truly considering all waste (product, packaging) and waste as a resource. Drinks must be delivered with a fit-for-purpose packaging. Overpackaging should have one clear definition.

…a resource. Drinks must be delivered with a fit-for-purpose packaging. Overpackaging should have one clear definition. Multipacks should not be considered overpackaging automatically, their functionality and the fact that they are needed for transport and for consumer experience should also be taken into account. We also believe a holistic approach should be considered when looking at packaging ratios, as promoting bigger packaging could be detrimental to helping consumers managing their diets via smaller portions. Underpackaging is the other extreme that the revised Essential Requirements will have to avoid. There are no absolute references to define what should be right amount of packaging: packaging can only be assessed in relation to the product it contains and the function it serves, whilst ensuring safety and hygiene for the consumer.

17 → 12

originalus šaltinis (PDF) ↗

Introduction The European soft drinks sector is committed to accelerating the transition to a circular economy by reducing packaging and packaging waste.The European Commission’s proposal for a Packaging and Packaging Waste Regulation (PPWR) represents a key opportunity to unlock some of the necessary enablers to make this ambition a reality. The PPWR has the potent ial to: 1. Improve the collection of beverage packaging across the EU 2. Support the increased use of recycled content in beverage packaging & promote high - quality and closed - loop recycling 3. Ensure the complementarity of reusa ble and recycling solutions with the development of key enablers Ref. Ares(2023)2889243 - 24/04/2023 1.

…of reusa ble and recycling solutions with the development of key enablers Ref. Ares(2023)2889243 - 24/04/2023 1. Improving the collection of beverage packaging across the EUPackaging sustainability starts with full recyclability and high collection rates.For beverage packaging, Deposit and Re turn Systems (DRS) have a key role to play in achieving high collection and high -quality recycling in the EU. UNESDA therefore very much welcomes the proposal for a wider roll -out of DRS in Europe (Art. 44) as well as the development of minimum requirements (Annex X) to ensure those systems are set up and run in the most effective and cost - efficient way.

(Annex X) to ensure those systems are set up and run in the most effective and cost - efficient way. However, we believe that some elements of the proposal could be improved.1.a Completing & correcting the list of minimum requirements for well -designed Deposit and Return Systems (Annex X):The DRS minimum requirements (Annex X) should ensure that: • Beverage producers financing the DRS as part of their producer obligation to collect their packaging waste have a priori ty access to the food - grade feedstock for recycling issued from the packaging material they put on the market and that was collected via the system. Such mechanism would support high -quality recycling, avoid downcycling of PET bottles into non - food applications, and encourage all sectors to invest in their own circularity rather than to free - ride on the beverage circular system.

…encourage all sectors to invest in their own circularity rather than to free - ride on the beverage circular system. • The system should be led by the industry financing and participating in the system, in a not - for -profit structure. • The revenues coming for the sales of the collected materials and unredeemed deposits stay in the system to cover both setup and operational costs. This is key to ensure that DRS revenues are not allocated to other initiatives, to the detriment of the func tioning of the DRS itself. • Awareness raising campaigns are foreseen in the costs of the system. However, each DRS operator should be free to adapt the amount spent based on local needs and depending on the maturity of the DRS .

DRS operator should be free to adapt the amount spent based on local needs and depending on the maturity of the DRS . A more comprehensive list of our suggested amendments to Article 11 and Annex X can be found in the annex to this document.Furthermore, to protect existing well - functioning scheme s , it is important to differentiate between mandatory criteria all DRS should comply with (priority access, governance by the beverage industry, revenues staying in the system) and those which should remain voluntary or shaped according to the local conte xt if the system has not been set up that way from the onset. For existing DRS, making some of those changes could be costly or disruptive to the systems while not bringing a positive impact on the collection rates or the quality of the recycling.

…disruptive to the systems while not bringing a positive impact on the collection rates or the quality of the recycling. 1.b Avoiding consumer confusion through clear sor ting instructions (Art 11): • Member States should have the possibility to exempt packaging covered by a DRS from the mandatory “material composition” label (Art. 11. 1). For packaging covered by a DRS, the only relevant information for consumers to be able to best dispose of their packaging is the label or marking related to the DRS itself. The overlap of several labels risks confusing consumers, leading to reduced collection rates of packaging covered by a DRS. For example, it would be the case if consumers start disposing of their DRS -packaging in their general plastic waste bin at home because one of the labels on the packaging says “plastic”.

DRS -packaging in their general plastic waste bin at home because one of the labels on the packaging says “plastic”. • Member States should have the possibility to exempt packaging covered by an existing DRS from the harmonized “DRS” label (Art. 11.1). In Member States where national labels or markings denoting participation in the system have been used for many years and are well - understood by consumers, modifying or adding a new DRS label risks confusing consumers. Therefore, the choice to use an EU harmonized label or any national mean of information to the consumer should be left to the discretion of the national DRS operator. 2. Supporting the increased use of recycled content in beverage packaging & promoting hig h -quality recycling Packaging sustainability is also about ensuring that the recyclable materials being collected are recycled, preferably in a closed - loop.

…is also about ensuring that the recyclable materials being collected are recycled, preferably in a closed - loop. UNESDA welcomes the Commission’s ambition to increase the part of recycled content in packaging by setting new recycled content targets for various types of packaging (Art.7). However, a pre - condition to this ambition is the creation of a well - functioning market for recycled materials that: • gives the sectors covered by the scope of the targets a fair access to sufficient recycled materials to meet the targets • promotes high -quality recycling and avoids downcycling 2.a Defining & encouraging high - quality re cycling: The PPWR proposal states that Member States shall ensure that systems are set up to provide for the return and separate collection of all packaging waste in a way that facilitates its preparation for re - use and high -quality recycling (Art. 43.1).

…of all packaging waste in a way that facilitates its preparation for re - use and high -quality recycling (Art. 43.1). However, the proposal does not include any definition of high -quality recycling or any measure that would guarantee that high -quality recycled materials suitable for food -grade applications are used in priority in food -grade applications. This means that high -quality materials (complying with EU food safety requirements) can be downcycled and used in applications which do not require the same level of quality.

EU food safety requirements) can be downcycled and used in applications which do not require the same level of quality. We therefore propose: • As a first step, to define high -quality recycling in Article 3 as “any rec overy operation, as laid down in Article 3 point (17) of Directive 2008/98/EC, which ensures that the distinct quality of the waste material collected is preserved or recovered during such recovery operation so it allows further recyclability and can be re -used in the same way and for a similar application, with minimal loss of quantity, quality or function”. • Then, to amend Art. 43.1 to mandate Member States to ensure that a system is set up to give priority to high -quality recycling.

…amend Art. 43.1 to mandate Member States to ensure that a system is set up to give priority to high -quality recycling. The rational for def ining the quality of recycling has been outlined in the 2023 EU JRC Report “Towards a better definition and calculation of recycling ” 1 which states that “A definition of high -quality recycling could help developing policies focused on improving the quality of recycling outputs by the entire recycling chain, ultimately ensuring a greater level of resource circularity.” 1Towards a better definition and calculation of recycling, JRC, 2023, page 77, 7.1 2.b Supporting closed - lo op recycling of packaging collected via DRS: The PPWR proposal also states that DRS will contr ibute to the increase of the supply of good quality secondary raw material suitable for closed -loop recycling and reduce beverage containers litter.

…of good quality secondary raw material suitable for closed -loop recycling and reduce beverage containers litter. However, the text does not include in the DRS minimum requirements listed in Annex X any priority right for beverage producers to the necessary food - grade feedstock for recycling to ensure closed - loop (bottle - to -bottle) recycling. As a result, food -grade recycled content obtained from the beverage packaging collected via the DRS can be sold for use in non -food applications and break the beverage packaging recycling loop. We propose to include in the DRS minimum requirements in Annex X a priority right which would guarantee that beverage packaging collected via the DRS is recycled and used again in prio rity in new beverage packaging in a closed -loop recycling system.

22 → 12

originalus šaltinis (PDF) ↗