Amazon Europe Core SARL

…1 Amazon position on the revision of the EU Packaging and Packaging Waste Directive As a consumer-obsessed company that is committed to sustainability, we see it as part of our mission to optimize the overall customer experience by setting a high bar for the selection and use of our own outbound e-commerce packaging, and by collaborating with vendors and sellers worldwide to invent sustainable packaging that delights customers, eliminates waste, and ensures products arrive undamaged to our customers’ doorsteps. Amazon drives outbound packaging waste reduction by using machine learning to select the least wasteful type of packaging for each product we ship. We have used this tool to reduce the weight of our outbound packaging by more than 33% over the past 5 years, eliminating over 900,000 tons of packaging material.

…of our outbound packaging by more than 33% over the past 5 years, eliminating over 900,000 tons of packaging material. We share this knowledge with vendors and sellers through our Frustration-Free Packaging (FFP) Program, which encourages them to package their products in easy-to-open packaging that is 100% recyclable and, where safe to do so, ships without any additional Amazon packaging. In addition to our work on our outbound packaging, we also promote sustainability in the product packaging of our own Amazon devices and private label products e.g. by eliminating plastic packaging materials whenever possible and encouraging the use of wood-based fiber packaging based on recycled or sourced from certified responsibly managed sources.

…the use of wood-based fiber packaging based on recycled or sourced from certified responsibly managed sources. Amazon welcomes the Commission’s intention to review the Packaging and Packaging Waste Directive to ensure a well-functioning and harmonized application of rules throughout the European Single Market. While we look forward to contributing to the development of a revised Directive and subsequent secondary legislation, we would like to supplement our response to the public consultation by encouraging the Commission to consider the following points: 1. Ensure harmonization of packaging rules across the single market to prevent market fragmentation and create a level playing-field, in line with Art. 114 TFEU The scoping study conducted ahead of the current review of the Directive found that essential requirements are not sufficiently implemented or precise.

…of the current review of the Directive found that essential requirements are not sufficiently implemented or precise. We have witnessed an uneven application of the PPWD rules, whereby some Member States do not fully implement the provisions of the PPWD while others go above and beyond PPWD requirements. Such divergence causes fragmentation of the European Single Market, creates an uneven playing-field for companies, and prevents the economies of scale that can accelerate R&D and investment in new packaging technologies, materials and practices. Amazon therefore encourages the Commission to ensure the integrity of the European Single Market through the review of the PPWD, as facilitated by its legal basis in Article 114 TFEU.

…of the European Single Market through the review of the PPWD, as facilitated by its legal basis in Article 114 TFEU. We are pleased that the Commission recognizes the necessity of striving towards full harmonization of rules on packaging and packaging waste and addressing the obstacles caused by diverging national measures. In the interest of the free movement of goods, we encourage the Commission to center its work on this broad objective. This can be achieved through the design of well-considered, clearly defined, and enforceable requirements and tools which must be applied uniformly in all Member States. The following paragraphs offer further considerations to this effect. 2.

…be applied uniformly in all Member States. The following paragraphs offer further considerations to this effect. 2. Specific requirements for e-commerce outbound packaging must take account of cutting-edge technologies and methodologies, and avoid unintended waste generation We note that the Commission is looking into measures specifically targeting over-packaging in e- commerce, including through potentially setting proportion or void space limits on outbound packaging used for e-commerce. Amazon’s Frustration Free Packaging (FFP) program has been an effective tool Ref. Ares(2021)148983 - 07/01/2021 2 to reduce the amount of packaging used while maintaining adequate protection for products.

- 07/01/2021 2 to reduce the amount of packaging used while maintaining adequate protection for products. We welcome the Commission’s consideration of using to Amazon’s FFP certification guidelines as for a reference for future measures and look forward to discussing this further through workshops and bilateral exchanges. In this context, e-commerce packaging should be defined as the secondary outbound packaging that e-commerce marketplaces add to the original packaging supplied by vendors and sellers, or when primary packaging also serves as outbound packaging. At scale, e-commerce marketplaces do not control decisions on packaging designs, materials or recycled content in the packaging provided by vendors and sellers. Responsibility for primary product packaging should rest with the vendors and sellers who make these decisions.

Responsibility for primary product packaging should rest with the vendors and sellers who make these decisions. Additionally, we would like to underline that the primary function of packaging is to protect the product, which in nearly all cases have a higher embodied carbon value than the packaging, and that any measure to address packaging proportions must account for the needs of fragile products. This is not least the case for the primary product packaging itself, when outbound shipment packaging is reduced or even eliminated, as is the case for packaging that certifies as Ships in Own Container (SIOC) under our Frustration Free Packaging guidelines – which requires a 17-drop and vibration test to ensure sufficient product protection.

Free Packaging guidelines – which requires a 17-drop and vibration test to ensure sufficient product protection. Amazon utilizes advanced technologies such as machine learning tools to ensure the right balance between cubic efficiency, weight and product protection. It is therefore crucial that any rules on packaging proportions or design are not too generalized and thereby risk compromising product protection or penalizing companies that already employ stringent packaging design principles to optimize their product packaging for the relevant distribution environment. While we strive towards being able to ship products in their own primary packaging (SIOC), it is important to also consider that not all products sold through Amazon or other e-commerce marketplaces come in primary packaging that is optimized for e-commerce.

…sold through Amazon or other e-commerce marketplaces come in primary packaging that is optimized for e-commerce. Consequently, there is still a need to use secondary outbound packaging to ensure that the product arrives safely to customers. For these products, the introduction of requirements that are too strict on the proportion of sealed air in outbound packaging would create the need for customized packaging, which in turn would lead to waste generated on the manufacturing or fulfilment floor as packaging is cut to measure, rather than using a packaging suite that is nested together to reduce waste in manufacturing.

…is cut to measure, rather than using a packaging suite that is nested together to reduce waste in manufacturing. Two e-commerce specific solutions that allowed Amazon to reduce our packaging weight per shipment by 33% in the last 5 years are the substitution of corrugated boxes by flexible packaging for items that are not fragile, and the shipment of multiple products in a single container (rigid or flexible). This was enabled by machine learning, which identifies the necessary protection for each product. We encourage the Commission to consider the need for system-level and innovation friendly measures for e-commerce to enable the continued development of such tools and methodologies by the e- commerce sector. Figure 1: The main pillars of Amazon's Frustration Free Packaging Programme 3 3.

…by the e- commerce sector. Figure 1: The main pillars of Amazon's Frustration Free Packaging Programme 3 3. Develop an EU-wide recyclability e-label to help customers improve recycling rates Improved recyclability of packaging only matters if consumers are aware of what can be recycled, how, and where. Amazon therefore supports the Commission’s intention to assess the feasibility of an EU- wide label that facilitates the correct separation of packaging waste at source, as set out in the Circular Economy Action Plan. We already participate in voluntary schemes to promote common approaches across companies where they exist, such as the On Pack Recycling Label (OPRL) in the UK.

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March 2023 1 Amazon position on the proposed Packaging and Packaging Waste Regulation We are committed to building a sustainable business for our customers and the environment. We know customers care about the packaging used to ship their Amazon orders. Customers want their orders to be delivered in right-sized and easily recyclable packaging that ensures the product arrives in good condition, as well as minimizes its impact on the environment. At Amazon, we care deeply about our packaging achieving both goals, and we have teams of scientists and other experts who are constantly working to reinvent how products can be shipped for the good of customers and the planet. Our north star goal is achieving efficient reduction of packaging by eliminating the need for all additional packaging from Amazon. An important new development in our packaging reduction journey is automation.

…all additional packaging from Amazon. An important new development in our packaging reduction journey is automation. We are testing new technologies that create bespoke paper-based packaging for each individual customer order, ensuring that packaging fits the contents. Build-on-demand technologies that create a unique package for each customer order have the potential to help us eliminate excessive packaging altogether. By inventing new ways to package products using less material, excessive packaging should increasingly be the exception, and, in the future, packaged goods should arrive on our customers’ doorsteps in packaging that is a perfect fit. With this vision in mind, we have reduced the weight of the packaging per shipment by 38% and eliminated the use of more than 1.5 million tons of packaging materials since 2015.

…packaging per shipment by 38% and eliminated the use of more than 1.5 million tons of packaging materials since 2015. In Europe, we switched from single-use plastic delivery bags to curbside recyclable paper delivery bags and cardboard envelopes for orders shipped from fulfillment centers. We also replaced all single-use air pillows with curbside recyclable paper material to protect goods during shipping. We, thus, endorse the European Commission’s proposal for a Packaging and Packaging Waste Regulation (PPWR) and its goal to tackle the challenges related to packaging waste and overpackaging, and we are very supportive of the European Union’s (EU) vision for transforming the EU economy from a linear to a circular one. Policy Recommendations

European Union’s (EU) vision for transforming the EU economy from a linear to a circular one. Policy Recommendations 1. Incentivize packaging designed for e-commerce • EU legislation should include regulatory enablers and relevant incentives for companies selling through e-commerce to use packaging specifically designed for e-commerce (i.e., sales packaging that does not require an additional e-commerce box or envelope to be shipped) as a way to prevent packaging waste.

…does not require an additional e-commerce box or envelope to be shipped) as a way to prevent packaging waste. 2. Excessive packaging and 40% empty space ratio • Compliance with the 40% empty space ratio for e-commerce packaging should be met on average of all e-commerce shipments by an economic operator, i.e., at company level and not per unit of packaging. • To achieve a realistic transition and implementation of the 40% empty space ratio requirement, timeline for compliance should be clarified in the proposal and set for 2030. • A clear empty space ratio calculation methodology should be set in a separate legislation, e.g. in a delegated or implementing act, in open consultation with the industry. • Exemptions from the 40% empty space ratio requirement should be provided to small packaging types, as well as to reusable e-commerce packaging, in line with the performance criteria under…

…packaging, in line with the performance criteria under Annex IV. Ref. Ares(2023)2717525 - 17/04/2023 March 2023 2 3. Extended Producer Responsibility (EPR) for online marketplaces • EPR obligations for online marketplaces under Article 40 shall introduce the possibility of a “pay-on- behalf” EPR model, already implemented in France in 2022, that would allow providers of online marketplaces to submit EPR reports and pay on behalf of producers. • A simplified and centralized EPR register should be set up at EU level, together with a common data standard for national EPR registers. • Compliance of online marketplaces with Article 40 para. 3 of the PPWR should be set at least 18 months after entry into force of the PPWR.

…marketplaces with Article 40 para. 3 of the PPWR should be set at least 18 months after entry into force of the PPWR. 4. Reuse targets for e-commerce and transport packaging • Compliance with the 10% reuse target for transport packaging via e-commerce (Art. 26 para. 8) should be reached either through the use of reusable packaging or by using packaging designed for e-commerce, i.e., sales packaging that does not require an additional e-commerce box, envelope, or bag. • The 2040 reuse target should be set after the European Commission conducts a separate impact assessment. Also, a clear timeline for such assessment should be included in the proposal. • The target for reusable transport packaging under paras. 12 and 13 of Article 26 shall apply to specifically enumerated types of transport packaging and shall be set at 80% if the target applies as soon as the PPWR enters into force or,…

…should count towards meeting the 10% target for such packaging by 2030 and the 30% target by 2040 (Art. 26 para. 9). 5. Sustainability requirements Recyclability • A clear timeline should be included in the proposal for the European Commission to deliver the design for recycling (DfR) criteria. • To maintain legal certainty and in case the DfR criteria are not delivered by the European Commission in a timely manner, i.e., before 2030, industry DfR guidelines should apply instead. • The definition of recycling “at scale” must be clarified. • The timeline for compliance with recyclability and “recycled at scale” requirements should be clarified and be flexible. Recycled Content • Compliance with all recycled content targets should be met on average of all plastic packaging sold in the EU by an economic operator, i.e., at company level and not per unit of packaging. • Recyclate that…

“innovative packaging” should be amended to include a reference to compostable, biodegradable and bio-based material. 6. Deposit Return Systems (DRS) • Introduction of DRS must be accompanied by maximum harmonization of requirements. This includes recognition of cross-border applicability of take-back requirements (e.g., a bottle can be returned in another country than that where it was sold). • To facilitate compliance, a central Scheme Administrator and a register of compliant products are needed. • No VAT should apply to the deposit of DRS. This means that rates should remain flat. March 2023 3 I. Incentivize packaging designed for e-commerce as a waste minimisation measure At Amazon we support the Commission’s proposal to tackle excessive packaging in online sales.

…minimisation measure At Amazon we support the Commission’s proposal to tackle excessive packaging in online sales. We believe this review offers a unique opportunity to properly take into consideration the growing reality of online trade and encourage its benefits when setting measures for packaging waste reduction. Packaging designed for e-commerce is packaging specifically tailored to the needs of the online trade and the e-commerce landscape where sellers supply their products within packaging that is already robust enough to withstand logistics and transport and does not require any secondary packaging. All that is needed from logistics operators in the supply chain is a delivery label and the product can be shipped as-is, with no additional (secondary) packaging materials.

…chain is a delivery label and the product can be shipped as-is, with no additional (secondary) packaging materials. The logic behind this concept is very straightforward; why should we use two units of packaging when the products could be delivered in one and with the same level of protection and functionality? At Amazon we have implemented the concept of packaging designed for e-commerce by developing two different programs: i) our “Ships In Own Container” (SIOC) solution – in this case, sellers provide their products to us in packaging that can be shipped as-is. All that is, then, needed from Amazon is a delivery label and the product can be shipped with no additional packaging materials; ii) our “Frustration Free Packaging” (FFP) programme, our flagship programme designed to reinvent the packaging experience.

…our “Frustration Free Packaging” (FFP) programme, our flagship programme designed to reinvent the packaging experience. FFP encourages sellers to package their products in more sustainable packaging that is easy-to-open, 100% recyclable and ready to ship to customers without additional Amazon boxes. When packaging is designed for e-commerce, it contributes to packaging minimization (for instance reducing the need of space for branding), elimination of secondary packaging, and carbon emission reduction as weight of packaged goods being transported is reduced and a higher number of goods can fit within one truck. With the growth in e-commerce deliveries, packaging designed for e-commerce should be encouraged as a way of contributing to tackling packaging waste.

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