Swedish Forest Industries Federation

Swedish Forest Industries Federation / P.O. Box 55525 / SE-102 04 Stockholm / +46 8 762 72 60 / www.forestindustries.se Concerning the review of the requirements for packaging and other measures to prevent packaging waste Circularity is part of our DNA The Swedish Forest Industries Federation (SFIF) represents the Swedish forest industries, which refine sustainably sourced wood resources to bio-based products, such as pulp, paper, board, packaging material, sawn timber, refined wood products and advanced biofuels. Among SFIF members are some of the largest private forest holdings in Europe. Circularity is part of the DNA of the forest-based industries in two ways. In a large loop, carbon dioxide from the atmosphere is sequestrated in growing forests, thereby storing carbon in wood and wood-based products.

…dioxide from the atmosphere is sequestrated in growing forests, thereby storing carbon in wood and wood-based products. When these products reach end-of-life and are incinerated, carbon dioxide is released, which can then once again be sequestered. In a somewhat smaller loop, products are recycled, and the recycled fibers are used as raw material for new products. More than 70 percent of all paper and board in Europe is today recycled and for Sweden the corresponding number is above 80 percent. This high level has been developed over decades and the recycling operations are well-integrated in the forest-based industries. Acknowledge the high level of circularity of renewable fiber-based materials. Secure that obstacles are not created for such materials, when introducing policy targeted at other types of materials lagging behind on circularity.

…for such materials, when introducing policy targeted at other types of materials lagging behind on circularity. Mandatory recycled content risks destroying already well-functioning recycling markets Introducing mandatory recycled content for a product to be sustainable might sound appealing from a policy standpoint. However, if applied on already well-functioning recycling markets, it risks destroying such markets. To exemplify, in the European paper and board recycling system, market players have found their niches. A producer in north Europe will run mainly on fresh fibers, due to closeness to forests. A producer in mid or south Europe is more likely to run on recycled fibers, as availability is higher close to large metropolitan areas. As mentioned before, both types of fibers are needed to satisfy overall customer demands.

…to large metropolitan areas. As mentioned before, both types of fibers are needed to satisfy overall customer demands. If a mandatory recycled content would be imposed on a North European paper or board producer, that producer would have to transport recycled fibers from central Europe thereby increasing emissions. The producer would most likely also have to change his production process resulting in increased cost. Recycled fibers would be pulled away from markets already using it and these markets would have to import fresh fibers, also that increasing emissions and costs. In addition, by using fresh or recycled fibers or a combination of the two, specific product requirements, such safety and strength properties, can be fulfilled. The overarching objective with imposing a mandatory recycled content is to develop and build secondary raw materials markets.

…objective with imposing a mandatory recycled content is to develop and build secondary raw materials markets. That intention has merits, but as described above, it risks striking negatively, if imposed in the same way for all value chains. Instead, this policy tool should be focused to product value chains that today have none or low recycling. Refrain from introducing a mandatory recycled content for a product to be sustainable, as there is no one-size-fits-all solution. Ref. Ares(2020)7883385 - 22/12/2020

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Swedish Forest Industries Federations’ (SFIF) position on the framework for Packaging and Packaging Waste Regulation (PPWR) Summary Swedish Forest Industries Federation (SFIF) welcomes the European Commission´s objective to set revamped harmonised rules on packaging and packaging waste with the aim of putting an end to wasteful packaging and boosting its reuse and re­ cycling. In the framework of the European Green Deal and the Circular Economy Action Plan, it is crucial to ensure that products placed on the European market contribute to reach the climate neutrality by 2050 objective. The proposal is ambitious. We propose some additional improvements to safeguard that relevant environmental performance is achieved.

…is ambitious. We propose some additional improvements to safeguard that relevant environmental performance is achieved. 1. Acknowledge the renewable materials’ contribution to climate neutrality. Renewable materials can help phasing out products made of fossil finite resources. It is important, whenever possible, to incentivise products made from renewable – sustainably managed – resources. 2. Recyclability and re-use of packaging are complementary solutions. Evaluations need to be based on the full life-cycle impact of all packaging products and solutions that achieve the best environmental outcome. Reuse and circularity targets must be based on scientific and material-specific data.

…the best environmental outcome. Reuse and circularity targets must be based on scientific and material-specific data. 3. Packaging bans and restrictions on specific packaging need a thorough assessment. The proposed ban of reducing packaging for fruit and vegetables (less than 1,5 kg) risks leading to increased waste of packed goods in the distribution chain, thus inducing an increased environmental and social burden. Furthermore, the hygiene and safety must not be jeopardised. 4. Mandatory recycled content for plastic packa­ ging should be applied to packaging that has plastics as predominant material. The market supply of high-quality plastic needs to be ensured before quota obligations are introduced on all packaging containing plastic. POSITION PAPER SWEDISH FOREST INDUSTRIES 1/3 January 2023 | SFIF’s position on the framework for Packaging and Packaging Waste Regulation (PPWR) 5.

INDUSTRIES 1/3 January 2023 | SFIF’s position on the framework for Packaging and Packaging Waste Regulation (PPWR) 5. Design for Recycling guideline should be drawn up by European Committee for Standardisation (CEN). CEN is an established standardisation body and has published a considerable number of standards related to recycling. Background The Circular Economy Action Plan (CEAP) was published in March 2020 and one of the objectives was to reinforce the essential requirements for packaging in view of making all packaging reusable or recyclable by 2030. The proposal of the framework for packaging and packing waste regulation (PPWR) is a follow up of the CEAP.

…by 2030. The proposal of the framework for packaging and packing waste regulation (PPWR) is a follow up of the CEAP. PPWR is a revision of the current Packaging Waste Directive (PPWD) and aims to address: • the increasing generation of packaging waste • hinders to packaging recycling and re-use • the low quality of recycled plastic packaging which leads to lack of plastics as secondary raw materials The overarching objectives of the proposal are to reduce the negative environmental impacts of packaging and packaging waste, while improving the functioning of the internal market. The proposal contains a range of measures related to the Waste hierarchy´s highest steps.

…of the internal market. The proposal contains a range of measures related to the Waste hierarchy´s highest steps. • Member States will be required to reduce packa­ ging waste (per capita) by 2030, 2035 and 2040 • Minimum reuse and refill targets to achieve by 2030 • Recycling targets for plastic, aluminum, glass, and paper and board packages by 2025 The Commission proposes measures to be further developed through delegated acts, implementing acts, standardisation and guidelines. All packaging is reusable or recyclable by 2030 Ref. Ares(2023)667407 - 30/01/2023 POSITION PAPER SWEDISH FOREST INDUSTRIES 2/3 January 2023 | SFIF’s position on the framework for Packaging and Packaging Waste Regulation (PPWR)

INDUSTRIES 2/3 January 2023 | SFIF’s position on the framework for Packaging and Packaging Waste Regulation (PPWR) 1. Acknowledge the renewable materials’ contribution to climate neutrality. Packaging is an essential part of daily life. The function of packaging such as product protection, ensuring safety and hygiene and as an information carrier contributes to sustainability and circularity. As the aim of the proposed Regulation is to use our resources more efficiently, it is important, whenever possible, to incentivise products made from renewable – sustainably managed – resources. Renewable materials can help phasing out products made of fossil finite resources. Renewable materials from sustainable sources are truly circular as they are not only recyclable in the short perspective, but also replenished and recovered repeatedly. The EU has the opportunity to support the development of…

…that Europe’s dependency on fossil resources must be reduced if we are to reach climate neutrality no later than 2050. 2. Recyclability and re-use of packaging are complementary solutions. A circular society needs a smart use of resources. Recycling and reuse of packaging are both needed from a system perspective. SFIF would like to emphasize that the reuse and circularity targets must be based on scientific and material-specific data. These must clearly show the environmen­ tal benefits in consideration of the externalities and logistics involved (e.g., socio-economic and geographical aspects), hygiene aspects and the importance of high return and rotation rates, as well as low wastage. An example is the current range of transport packaging where both reusable and recyclable packaging are complemen­ tary to achieve sustainable logistic chains.

…packaging where both reusable and recyclable packaging are complemen­ tary to achieve sustainable logistic chains. Therefore, legislation on multiple use should be preceded by independent comparisons from a system and life cycle perspective to avoid environ­ mentally undesired impacts. This means that the future legislation needs to provide optimal 1 Circular Economy Action Plan, European Commission (2020) 2 Waste Framework Directive (2008/98/EC), article 4.2. 3 Directive (EU) 2019/904, Directive about reduction of the impact of certain plastic products in the environment. requirements for different packaging solutions based on their environmental benefit, remaining technology and material neutral. SFIF emphasizes the urge to evaluate the full life-cycle impact of all packaging products and solutions that achieve the best environmental outcome.

…the full life-cycle impact of all packaging products and solutions that achieve the best environmental outcome. This means that devi­ ation from the waste hierarchy must remain possible when justified by a life cycle assessment (LCA), and in line with Waste Framework Directive2. 3. Packaging bans and restrictions on specific packaging need a thorough assessment. Any possible bans or restrictions on specific packaging types should be duly justified by impact assessments and science-based facts. The environ- mental impact of the packaging is generally a very small percentage in relation to the environmental impact of the packed product. In the Commission proposal, several packaging types are banned. Among others, SFIF emphasizes that a general ban or focus on reducing packaging for fruit and vegeta­ bles (less than 1,5 kg) needs to be further assessed.

…general ban or focus on reducing packaging for fruit and vegeta­ bles (less than 1,5 kg) needs to be further assessed. The proposed ban risks leading to increased food waste in the distribution chain, thus inducing an increased environmental and social burden. In addition, the hygiene and safety must not be jeopardised. Furthermore, the requirements to be exempted from the ban needs to be clear. Both the type of packaging and the products falling under the scope of the bans as well as those that can be exempted, need to be easily and clearly identifiable. To this end both the ban and the exemption should be detailed after consulting the relevant stakeholders (e.g., producers, transporters, wholesalers and retailers).

…be detailed after consulting the relevant stakeholders (e.g., producers, transporters, wholesalers and retailers). Further to the above, there are extensive research and development activities within our industry to develop renewable and recyclable packaging that contributes to reduce CO2 emissions. We aim at providing alternatives to fossil-based packaging that can improve resource efficiency and circularity. Therefore, SFIF urges a reconsideration of the bans on packaging in HORECA sector that overlaps with the bans and restrictions triggered by the ongoing implementation of the measures set out by the Single Use Plastic Directive3. Position by SFIF: Main arguments POSITION PAPER SWEDISH FOREST INDUSTRIES 4. Mandatory recycled content for plastic packaging should be applied to packaging that has plastics as predominant material.

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…2025-12-22 Swedish Forest Industries Federation (SFIF) supports the proposed exemption for the packaging formats pallet wrappings and straps from the 100% reuse requirements established in Article 29(2) and (3) of Regulation (EU) 2025/40. However, the pallet wrapping and films remain within the scope of Article 29(1) with 40% reuse target for the total transport packaging format. In many cases within our industry, most of the transport packaging consists primarily of pallet wrappings/films, straps. The remaining reuse target would disproportionately fall on pallet wrappings/films and straps, which can represent a significant share of a company’s transport packaging and, in practice, necessitate substantial operational changes.

…a significant share of a company’s transport packaging and, in practice, necessitate substantial operational changes. In this context, we strongly advocate for the following amendment to the draft Delegated Decision to guarantee legal certainty and deliver tangible, meaningful relief for economic operators: Amendment Draft Article 1 Exemption concerning pallet wrappings and straps Economic operators that use pallet wrappings or straps for stabilisation and protection of products put on pallets during transport are exempted from the 100% reuse requirements of these packaging formats established in Article 29(1), Article 29(2) and (3) of Regulation (EU) 2025/40.

…of these packaging formats established in Article 29(1), Article 29(2) and (3) of Regulation (EU) 2025/40. Article 1 Exemption concerning pallet wrappings and straps Economic operators that use pallet wrappings or straps for stabilisation and protection of products put on pallets during transport are exempted from the 100% reuse requirements of these packaging formats established in Article 29(2) and (3) of Regulation (EU) 2025/40. In addition, SFIF endorses the material-neutral approach for the packaging types in the proposal, recognising that the market provides strapping and pallet wrappings in a range of materials, including metal, plastic, and innovative fiber-based alternatives. These packaging types, regardless of material, share similar technical challenges regarding the initial investments required to develop automated solutions for reuse.

…share similar technical challenges regarding the initial investments required to develop automated solutions for reuse. Furthermore, we welcome that this proposal helps reduce the administrative burden for economic operators and makes effective use of the well-functioning collection systems currently in place for straps and pallet wrappings within EU. SFIF supports the contributions submitted by CEPI (Confederation of European Paper Industries) in this consultation. Ref. Ares(2025)11500953 - 22/12/2025

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