Stora Enso Oyj

Stora Enso contributes to making the EU and world carbon neutral in following ways: by capturing, or sequestrating, carbon dioxide in growing trees by storage of carbon in harvested wood products by substitution, when bio-based products and bioenergy replace other products that are fossil-based by becoming the first forest products company to have its climate targets approved by the Science Based Targets initiative in 2017 In 2019, our total climate impact, including avoided emissions by product substitution and forest sequestration, was 12 million tonnes of CO2. In addition to that we also operate at the heart of the bioeconomy and contributes to a circular economy with our renewable and recyclable products Supporting the circular economy Stora Enso is the renewable materials company providing solutions in transition to circular bioeconomy.

…economy Stora Enso is the renewable materials company providing solutions in transition to circular bioeconomy. We contribute to tackling climate change by managing our forests sustainably, ensuring we never harvest more trees than we grow while safeguarding biodiversity. We also deliver products that store carbon and providing low carbon alternatives to fossil-based or other non-renewable products to maximize carbon sequestration. Stora Enso contributes to a circular economy with our recyclable products derived from renewable raw materials. Stora Enso fully supports the EU Commission’s climate ambitions; we need to reduce our emissions by at least 55% by 2030. The forest industry plays a key role in this green transition and tackling climate change. Stora Enso also welcomes and supports the EU’s ambitions to transition to a circular economy.

…tackling climate change. Stora Enso also welcomes and supports the EU’s ambitions to transition to a circular economy. Avoid unintended consequences Packaging is an essential part of modern life. Packaging protects the packaged goods, enables the transport of good, prolongs the lifespan of perishable goods, and allows for communicating vital information about the packaged good to consumers. However, packaging needs to be properly designed and managed to ensure that it does not contribute to other environmental issues, such as increased littering and residual waste. The revision of the Packaging and Packaging Waste Directive should support the proper management of packaging. We support the ambition to make all packaging reusable and recyclable by 2030. The revision of the directive should be centred on supporting packaging circularity.

…reusable and recyclable by 2030. The revision of the directive should be centred on supporting packaging circularity. Packaging performs many essential roles, so a general packaging reduction target would be inappropriate. It is not targeted enough, and could result in unintended consequences, such as increasing food waste. It would not benefit the ultimate climate and circular economy ambitions to reduce packaging waste while increasing food waste. It would run counter to the Commission ambition in the Farm to Fork Strategy to halve food waste at retail and consumer level by 2030. Instead, the question becomes what type of packaging should be used and selecting the optimal packaging. The focus should be on reducing non-recoverable packaging formats and excessive, unnecessary packaging. Measures to reduce over-packaging are welcome to reduce excessive material usage.

…and excessive, unnecessary packaging. Measures to reduce over-packaging are welcome to reduce excessive material usage. There should be robust definition of excessive over-packaging that is rooted in the packaging functionality. Yet, the measures cannot be overly prescriptive. Specific packaging/product ratios would be extremely administratively burdensome and complex, as there are different needs for different types of products. As material producers, we develop different solutions, how the goods are packed is up to packers, and there are other factors apart from the packaging itself that influence how goods are packaged. The approach to excessive over-packaging should be flexible enough to allow for innovation, developing new concepts and further optimisation. It should be noted that some packaging optimisation tools already exist.

…new concepts and further optimisation. It should be noted that some packaging optimisation tools already exist. When packaging is necessary, recyclable packaging made of renewable material should be the preferred option, because it helps society move towards a circular low carbon economy. The focus should be on packaging waste that cannot be recovered, because it ends up as residual waste, and the raw materials cannot be recovered. Policy should act as an enabler to achieve this. Revision of the Packaging and Packaging Waste Directive Consultation response Ref. Ares(2020)7795486 - 19/12/2020 2/4 Part of the bioeconomy, Stora Enso is a leading global provider of renewable solutions in packaging, biomaterials, wooden construction and paper. We employ some 25 000 people in more than 30 countries and our shares are listed on the Helsinki and Stockholm stock exchanges.

…some 25 000 people in more than 30 countries and our shares are listed on the Helsinki and Stockholm stock exchanges. Harmonisation of recycling standards In order to improve the recyclability of packaging in the EU, there should be a harmonisation of recycling standards across the EU. There should be harmonised recyclability guidelines, to give clarity on what is recyclable across the EU, and a harmonised recyclability testing method to demonstrate recyclability. Currently, recycling systems differ across countries. This makes it difficult to ensure that packaging put on the market will actually be recycled, and means that there are inefficiencies in the recycling systems because something that is technically recyclable might not be recycled in practice due to lack of recycling infrastructure in that particular market.

…recyclable might not be recycled in practice due to lack of recycling infrastructure in that particular market. Harmonisation of recyclability criteria would remove these inefficiencies and make it easier to ship material for recycling to other member states for recycling. Industry needs a clear and enforceable definition of recyclability. This means that there needs to be a clear, unambiguous definition of “recyclable”. We would welcome that the Commission, in collaboration with industry, would seek to define recyclability. The definition should be aligned with the definition in ISO 14021:2016.

…industry, would seek to define recyclability. The definition should be aligned with the definition in ISO 14021:2016. Recyclable packaging “can be diverted from the waste stream through available processes and programs and can be collected, processed and returned to use in the form of raw materials or products”.1 This is less bureaucratically and administrative burdensome than the recycling rate approach, at least until there is granular enough information on the recycling rates of individual packaging formats. This is also supported by the study conducted by the consulting firm Eunomia, which was tasked by the EU Commission to review the Essential 1 ISO 14021:2016, p.15; ISO:18601: 2013, p. 3. 2 ”Effectiveness of the essential requirements for packaging and packaging waste and proposals for reinforcement,” Eunomia, Requirements.

…the essential requirements for packaging and packaging waste and proposals for reinforcement,” Eunomia, Requirements. In their study “Effectiveness of the Essential Requirements for Packaging and Packaging Waste and Proposals for Reinforcement (2020)”, Eunomia noted that the recycling rate approach “would clearly require data on the amounts placed on the market and recycled of a much more granular level of categorisation than currently exists”.2 The qualitative definition is useful in creating a common understanding of recyclability, but may leave too much room for interpretation to be an efficient tool on its own for industry. As such, we recommend that this should be complemented by the harmonised recyclability guidelines and recycling testing method. It is important that the recyclability guidelines are industry driven.

…guidelines and recycling testing method. It is important that the recyclability guidelines are industry driven. 4evergreen, a fibre-based packaging alliance, initiated a process for developing harmonised European recyclability assessment method for fibre-based packaging. 4evergreen is also working on value chain circular design guidelines and value chain guidelines for collection and sorting systems to support the recycling of all types of fibre-based packaging. We as an industry would welcome playing a role in further development of recyclability guidelines and testing methods, in collaboration with 4evergreen and the Commission. The alliance aims to drive the recycling of fibre-based packaging in Europe. The harmonisation of the recycling guidelines should be based on best practices. There is clear evidence of where paper and board collection, sorting and recycling works.

…be based on best practices. There is clear evidence of where paper and board collection, sorting and recycling works. According to Eurostat data, the paper and board packaging recycling rate in Finland was 116% in 2018, 77.2% in Sweden, 86% in Germany and 95.6% in Belgium 2020, p. 151, https://op.europa.eu/en/publication-detail/- /publication/05a3dace-8378-11ea-bf12-01aa75ed71a1. 3/4 Part of the bioeconomy, Stora Enso is a leading global provider of renewable solutions in packaging, biomaterials, wooden construction and paper. We employ some 25 000 people in more than 30 countries and our shares are listed on the Helsinki and Stockholm stock exchanges. (these are examples, not an exhaustive list).3 This shows that there are functioning recycling systems that achieve high recycling rate for paper and board packaging.

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[Type here] Stora Enso is a renewable materials company. We are one of the largest suppliers of renewable materials used in fiber-based packaging (e.g., cereal boxes, milk cartons, transport packaging, food trays, etc.). We are also amongst the largest recyclers of fiber-based packaging in Europe, and thus produce packaging materials and solutions based on both fresh and recycled fiber. As producer and material supplier of various packaging formats across the value chain and in different markets, we are convinced that to address resource scarcity and avoid the increase in waste generation and greenhouse gas emissions, the Packaging and Packaging Waste Regulation (PPWR) should encourage and accelerate the shift towards low-emission, renewable and circular packaging.

(PPWR) should encourage and accelerate the shift towards low-emission, renewable and circular packaging. Given our extensive expertise in different packaging materials and packaging products manufacturing, using both virgin and recycled fibers to make both disposable and reusable packaging, we would like to offer some recommendations to make the PPWR more effective and ambitious. Renewable, bio-based feedstock can help phase out finite fossil-based materials Stora Enso considers the move towards renewable and circular packaging essential in achieving the European Green Deal’s objectives. Circularity must go hand in hand with phasing out fossil fuels and feedstocks. This means we need a circular economy based on renewable raw material, i.e., a circular bioeconomy, to achieve the green transition.

…need a circular economy based on renewable raw material, i.e., a circular bioeconomy, to achieve the green transition. Despite the ambition declared in the Green Deal, the Commission’s PPWR proposal does not fully capitalise on the opportunity to push biobased materials, which can facilitate the transition towards a circular bioeconomy and the achievement of the EU sustainability goals. Instead, some of the PPWR provisions may even lead to a shift from fibre-based packaging, which often has a lower climate impact1, to less sustainable solutions2, such as fossil-based packaging (i.e., plastics), or more energy-intensive materials (e.g., glass or aluminium). 1 Beverage carton: fit for the future – A recent LCA study commissioned by Stora Enso confirms that beverage cartons are an ideal packaging solution also for the future.

…study commissioned by Stora Enso confirms that beverage cartons are an ideal packaging solution also for the future. The study explores the scientific evidence that points toward beverage carton’s benefits in comparison with alternative packaging forms. 2 Commission Staff Working Document Impact Assessment Report Accompanying the document Proposal for a Regulation of the European Parliament and Council on packaging and packaging waste, amending Regulation (EU) 2019/1020, and repealing Directive 94/62/EC Annex 10 Mass Flows Stora Enso Recommendations: A. The PPWR should promote the use of circular, renewable materials to move away from today’s linear fossil-based economy. B. The PPWR should create ambitious mandatory separate waste collection targets. This would facilitate efficient and effective collection, sorting, and recycling.

…separate waste collection targets. This would facilitate efficient and effective collection, sorting, and recycling. High collection targets are necessary to generate the necessary inflow of secondary raw material to scale up recycling infrastructure. This would prevent the loss of valuable material (as litter or in less efficient processes such as energy recovery) and keep the materials and thereby, the embodied carbon in the loop for as long as possible. C. Rules on recyclability assessment must be clear and innovation-proof. The definition of criteria for ‘Design for Recycling’ (DfR) and ‘recycled at scale’ must be clear and granular. Therefore, a recognised standardisation body equipped with the necessary technical know-how, such as the CEN, should set the criteria.

…standardisation body equipped with the necessary technical know-how, such as the CEN, should set the criteria. Granularity is needed to define the recyclability at scale of specific packaging formats under the packaging categories, as their potential for recyclability must be assessed based on their use, collection, and recycling capacity. To stimulate investments in innovative and low-emission circular packaging, accuracy, predictability, and transparency in the DfR standardisation process is vital. D. The exemption for cardboard packaging included in the Commission’s proposal must be maintained for transport and grouped packaging. The PPWR should ensure that rules on reuse and packaging reduction will neither result in an overall increase of waste nor in increased production and use of fossil-based packaging, especially where renewable alternatives are available and perform better.

…production and use of fossil-based packaging, especially where renewable alternatives are available and perform better. If recyclable, corrugated transport packaging is replaced by reusable plastic packaging, millions of new plastic boxes need to be produced and placed on the EU market to achieve the high reuse target in PPWR. PPWR: Circularity and Renewability for Future-Proof Packaging Stora Enso contributes to making the EU and world carbon neutral in following ways: by capturing, or sequestrating, carbon dioxide in growing trees by storage of carbon in harvested wood products by substitution, when bio-based products and bioenergy replace other products that are fossil-based Ref. Ares(2023)2798202 - 20/04/2023 [Type here] Ambitious separate waste collection targets are necessary to recycle more and better We cannot recycle what is not collected.

…separate waste collection targets are necessary to recycle more and better We cannot recycle what is not collected. Ambitious recycling targets and increased use of secondary raw materials require high collection rates of post-consumer packaging waste. This is essential to scale up recycling infrastructures and avoid the loss of valuable material, in less efficient processes such as energy recovery, or worse, litter. Therefore, the PPWR must include a 90% mandatory separate waste collection target. Separate waste collection and subsequent recycling work well and trigger environmental benefits in many countries3.

Separate waste collection and subsequent recycling work well and trigger environmental benefits in many countries3. For example, the significant recycling rate of beverage cartons means substantial savings of GHG emissions (for beverage cartons this means ca 190k tonnes to 340k tonnes GHG reduction per year4); a contribution to the overall paper recycling rate and to Member States’ recycling targets, thus contributing to EU circularity objectives. Mandatory waste collection targets can incentivise investments in sorting and recycling infrastructure. Operators would benefit from predictability in the volume of waste that is collected and directed to the recycling lines. This would limit the externalities (e.g., waste quality and contamination) and unpredictability (e.g., waste volumes) that often hinder business scalability, development, and innovation.

…and unpredictability (e.g., waste volumes) that often hinder business scalability, development, and innovation. Rules on recyclability assessment must be clear and innovation-proof The PPWR proposal establishes that all packaging will have to be recyclable in order to be placed on the EU market. Future delegated acts will define how to judge whether packaging is recyclable. They will establish the ‘design for recycling (DfR)’ criteria as well as the methodology to assess if it is recyclable ‘at scale’. DfR criteria will have to be met by 2030 and will be vital to define the sustainability of packaging. To be considered recycled at scale, packaging will have to be collected, sorted and recycled, covering at least 75 % of the Union population by 20355. Considering their complexity, the creation of EU-wide DfR criteria should be mandated to CEN, or similar standardising bodies.

…their complexity, the creation of EU-wide DfR criteria should be mandated to CEN, or similar standardising bodies. These have the technical expertise that is needed for the creation of 3 In Belgium, where a separate waste collection target exists for beverage cartons, their recycling rate is approximately 90%. 4 Roland Berger study, 2022 5 Proposal for a revision of EU legislation on Packaging and Packaging Waste, Art. 3 para 32 6 Proposal for a revision of EU legislation on Packaging and Packaging Waste 7 Among others, the following studies highlight that corrugated cardboard outperforms reusable alternatives: − FEFCO LCA comparing corrugated boxes to RPCs: − Carbon footprint of cardboard boxes outperforms plastic boxes when moving tomatoes internationally predictable, science-based, and effective standards that can foster innovation in packaging design.

…internationally predictable, science-based, and effective standards that can foster innovation in packaging design. When setting recyclability criteria, an appropriate level of granularity must be ensured. Where needed, both DfR and recyclability ‘at scale’ criteria should be created for specific packaging formats under the broader categories in Table 1 Annex II of PPWR6 (e.g., under the recycled ‘at scale’ assessment, beverage cartons must be assessed separately from other metallised or plastic-laminated packaging). This would ensure that the different levels of circularity of each packaging format (e.g., use destinations, levels of collection, sorting, and recycling) are reflected when assessing their recyclability at scale.

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