Dow

Dow _____________________________________________________________________________ December 21, 2020 Dow’s response to review of the Packaging and Packaging Waste Directive (PPWD) consultation accompanying document to the PPWD questionnaire. The European Commission’s ‘Green Deal’ sets a clear direction of travel: Europe will become carbon neutral by 2050 and will accelerate the circular economy for plastics packaging. At Dow, we understand the gravity and the urgency and recognize the cost of inaction, so we will continue to accelerate our efforts to contribute meaningfully to these goals. This is why our mission is to be the leading producer of circular plastics with the lowest CO2 footprint, reinforced by challenging public commitments, supported by significant investments and partnerships across plastics manufacture, new low C02 feedstocks and chemical recycling.

…by significant investments and partnerships across plastics manufacture, new low C02 feedstocks and chemical recycling. The review of the Packaging and Packaging Waste Directive (PPWD) presents a critical milestone in achieving our shared ambitions for packaging to be reusable or recyclable in a cost-effective manner by 2030. This will require an enabling, harmonized and enforceable regulatory framework, to further accelerate innovation in reusable1 and recyclable packaging solutions, packaging waste reduction, boost the uptake of recycled content in packaging and the development of necessary sorting and recycling infrastructure to achieve recycling targets – all, whilst maintaining packaging functionality, consumer safety, product integrity and enabling the proper functioning of the Single Market. At Dow we share the EC and stakeholder urgency and bias to act.

…enabling the proper functioning of the Single Market. At Dow we share the EC and stakeholder urgency and bias to act. We call for a revision of the PPWD that is future proofed to support innovation across packaging design (mono-materials), sorting (including digital watermarking), recycling (physical and chemical) and provides a stable and predictable regulatory framework for years to come, without the need for another early revision that would further reduce industry’s ability to build the solid investment cases needed to implement the projects needed to deliver the desired outcomes.

…ability to build the solid investment cases needed to implement the projects needed to deliver the desired outcomes. Policy that imposes restrictions on specific packaging formats, material choices and that curtails specific recycling technologies based on what is scalable today will risk stifling innovation, partnerships and investments in the EU, creating a competitive disadvantage at a time when the Circular Economy Action Plan bears the promise of positioning EU industry as a frontrunner in developing, testing and demonstrating circular solutions. We stress that the PPWD plays an important role in achieving the EU Green Deal’s objectives not only in the area of the Circular Economy but also in achieving climate neutrality by 2050.

Green Deal’s objectives not only in the area of the Circular Economy but also in achieving climate neutrality by 2050. It is vital that the PPWD pays due consideration to the significant GHG savings that are demonstrably being achieved via light weight, resource efficient films and flexible packaging. Recent, very significant value chain investments, innovation as well as alignment on design for recyclability guidelines supported by verifying recycling trial results, has enabled these formats to be recycled in practice. Sufficient time should be given to allow market actors to transition to these recyclable formats, to reflect additional innovation and investments in waste infrastructure so the overall GHG savings the resource efficiency and functional benefits of films and flexibles can be further optimized. 1.

…overall GHG savings the resource efficiency and functional benefits of films and flexibles can be further optimized. 1. Packaging Waste Prevention We are concerned that essential packaging for fresh fruit and vegetables, meat, ready meals, dried foodstuffs etc., is potentially being considered as “unnecessary” packaging in the context of efforts to prevent packaging waste. Packaging provides essential functions – protecting consumer health and ensuring food safety, protecting product integrity and increasing product shelf-life to avoid food waste (and associated GHG emissions), enabling legally required 1 Boundary conditions suggested under reuse heading Ref.

(and associated GHG emissions), enabling legally required 1 Boundary conditions suggested under reuse heading Ref. Ares(2020)7875857 - 22/12/2020 Dow _____________________________________________________________________________ December 21, 2020 consumer information and acceptance of the packaged good, facilitating the safe and efficient handling and transport of goods across the retail supply chain. These critical functionalities must not be comprised. Additionally, any proposed packaging waste reduction targets must be clearly defined and linked to relevant metrics in Member States/ brand owner (kg / capita, weight / pack,), considering the economic growth profile of the population and should be applied across all packaging markets and materials in a fair and equitable manner.

…of the population and should be applied across all packaging markets and materials in a fair and equitable manner. To address packaging waste reduction and in the context of the Green Deal’s objectives on carbon neutrality, a ‘whole product’ lifecycle approach to packaging reduction is necessary, where climate impacts and environmental considerations are assessed throughout the lifecycle of pack and product together and all functionalities are given due consideration. Undesirable trade-offs, leading to counterproductive environmental and consumer impacts must be avoided - especially an unintended negative climate impact of packaged goods through the generation of food waste, damaged goods and/or substitution to less climate-friendly materials.

…goods through the generation of food waste, damaged goods and/or substitution to less climate-friendly materials. What may appear to be “non-essential” packaging or unnecessary plastic wrapping around food products is in fact often a highly engineered product that delivers unique barrier properties with the least amount of material to ensure food stays fresher for longer and avoids unnecessary food loss along the retail supply chain2. This packaging must also be recyclable. It is critically important that a scientific, LCA evidence-based impact assessment is undertaken prior to restricting so called “non-essential” packaging, especially food packaging to avoid unaccounted for environmental impacts.

…so called “non-essential” packaging, especially food packaging to avoid unaccounted for environmental impacts. These assessments must consider the pack and product and must include, consumer health and safety, product integrity, and the full environmental burdens associated with product losses in transport, retail and crucially within the home, due to damage and spoilage. This is of critical importance for carbon intensive products such as meat and dairy products. We remain committed to continue to optimize the amount of packaging placed on the market that is the most resource efficient and is recyclable, without undermining packaging functionalities, which do not lead to undesirable consequences.

…and is recyclable, without undermining packaging functionalities, which do not lead to undesirable consequences. Within the framework of an assessment on reducing packaging waste, it is also essential to develop clear definitions of “over-packaging” and “under-packaging” to help prevent negative consequences on product safety, integrity and food losses. We ask to prevent packaging waste from being landfilled by significantly accelerating the landfill ban and to severely restrict the incineration of plastics packaging. We have pledged through investments and partnerships to accelerate chemical recycling, as a complementary technology to mechanical recycling. We believe chemical recycling can accelerate plastics circularity, help Member States achieve recycling rates, and to supply recycled content into sensitive applications such as food contact applications.

…achieve recycling rates, and to supply recycled content into sensitive applications such as food contact applications. We have already undertaken scenario LCAs and we remain committed to answer any questions from stakeholders on the environmental, social, and economic impacts of this recycling technology. 2. Reuse Reusable packaging clearly has a role in the circular economy. Due to its versatility and durability, reusable plastic packaging is already widespread in industrial, consumer and commercial applications3.

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