McDonald’s Global Franchising Limited

McDonald’s feedback submission to the consultation on the PPWR Executive Summary McDonald’s supports the overall goals of the European Green Deal- in particular that of achieving a circular economy. It is for this reason that we have grown increasingly concerned over the last few months about the proposal on the Packaging and Packaging Waste Regulation (PPWR). We are especially worried about the unintended consequences for the environment, the economy, food safety and consumers. McDonald’s welcomes the revision of the EU Packaging and Packaging Waste Directive (94/62/EC) and the overall ambition in the proposed PPWR. However, we believe that the current proposal will not ensure a just and fair transition for European citizens, nor would it deliver on the Green Deal and Circular Economy Action Plan.

…and fair transition for European citizens, nor would it deliver on the Green Deal and Circular Economy Action Plan. Several independent studies clearly show recyclable fibre-based foodservice packaging has the greater potential to benefit the environment, economy, food safety and consumers than reusable foodservice packaging. These are detailed reports, conducted by independent experts and commissioned by leading companies like McDonald’s and industry associations who share the EU’s climate goals. As such, we believe any law should take into account the specific needs of the complex Informal Eating Out (IEO) business sector, and focus on the right foodservice packaging solutions for Europe. We believe this means allowing a mix of solutions.

…and focus on the right foodservice packaging solutions for Europe. We believe this means allowing a mix of solutions. Our concrete recommendations to ensure that the PPWR allows packaging to perform its core functionalities (protecting, containing and delivering products safely) while ensuring food affordability and security, the best overall environmental performance, and being suited to sector-specific business models, include: ● The EU should pause, reflect and conduct a full impact assessment study before moving ahead. Moreover, Member States should not unilaterally introduce legislation - this will further complicate an already complex sector, and will have a negative, fragmentary impact on the single market.

…will further complicate an already complex sector, and will have a negative, fragmentary impact on the single market. In that regard, the proposal should also remain a Regulation and not shift to a Directive – as varying implementation of the law will be detrimental to having a harmonised EU-single market, which is key to ensure Europe remains competitive. ● There needs to be equivalence of treatment in legislation between recycled and recyclable (fibre-based) single-use packaging and reusable tableware for dine-in. Ref. Ares(2023)2892315 - 24/04/2023 ● Reusable models should not be implemented for takeaway and delivery, given that single use is demonstrably better for the environment, economy, food safety and consumers.

…and delivery, given that single use is demonstrably better for the environment, economy, food safety and consumers. ● The EU should promote the creation of large-scale recycling infrastructures to increase the circularity of packaging materials as well as foster innovation in materials. Introduction: McDonald’s commitment to packaging waste reduction McDonald’s is one of the biggest actors of the Informal Eating Out (IEO) Sector in the world, with 6,409 McDonald’s restaurants in the EU. Together with our franchisees we employ nearly 300,000 people across Europe, and feed millions of EU citizens daily. At McDonald’s, we care deeply about our impact on the world. Our purpose is To Feed and Foster local Communities. We are always striving to use our influence and scale to make a positive impact on the planet and in communities we serve across Europe and globally.

…our influence and scale to make a positive impact on the planet and in communities we serve across Europe and globally. We are on a journey to help implement and accelerate solutions to keep waste out of nature and valuable materials in use. In the EU our packaging is primarily sourced from European fibre packaging suppliers and we have set goals to source 100% of our primary guest packaging (fibre and plastic) from renewable, recycled or certified sources. For now, 92.8% (by weight) of McDonald’s food packaging in Europe is wood fibre and 99.4% of that fibre packaging comes from recycled or certified sources. We are focused on implementing global and local solutions to expand reduction and recycling of guest packaging by the end of 2025, and we believe recycling has an important role to play in creating truly circular packaging systems and in reducing waste.

…we believe recycling has an important role to play in creating truly circular packaging systems and in reducing waste. Throughout Europe our packaging is designed to be collected and processed in paper recycling systems. We support the overall goals of the EU Green Deal and are on a journey to help implement and accelerate solutions to keep waste out of nature and valuable materials in use. Europe has historically fallen short of achieving circularity by adopting legislation that does not fully consider sector-specific business models, operational requirements, and consumer needs and well-being.

…not fully consider sector-specific business models, operational requirements, and consumer needs and well-being. While packaging and packaging waste are big issues at stake when it comes to Europe’s transformation towards circularity, we at McDonald's believe that it is necessary for the European Commission to take a step back and assess the sector-specific needs to make sure there is a level-playing field for all stakeholders that does not negatively impact the environment and European consumers. Specificities of the IEO Sector The IEO sector plays a key role in the European economy, employing hundreds of thousands of Europeans and generating billions of Euros a year.

…key role in the European economy, employing hundreds of thousands of Europeans and generating billions of Euros a year. The sector has a unique set of business, operational, and consumer characteristics: it is highly fragmented, with small and medium enterprises (SMEs), the majority of whom are not exempt from the legislation, making up more than two-thirds of the sector, and with more than 320,000 individual business owners. IEO consumers also have a very different set of demands compared to those in the broader restaurant sector: they expect speed, affordability (the average price of an IEO meal in the EU is approximately €4), and above all convenience. Take--away consumption accounts for more than 70 percent of sector revenue, and this figure continues to grow.

Take--away consumption accounts for more than 70 percent of sector revenue, and this figure continues to grow. These unique characteristics mean that adopting effective circularity solutions at scale presents multiple challenges, including identifying an effective mix of circularity solutions for a sector dominated by SMEs with packaging that must meet food-grade standards and safety requirements. In some European regions, underdeveloped waste infrastructure to collect, sort, and effectively dispose of waste presents limitations. Other regions have built well-functioning collection and recycling systems achieving significant recycling rates – this is notably the case for Italy.

…collection and recycling systems achieving significant recycling rates – this is notably the case for Italy. The IEO sector is also categorised by consumer behaviours that are difficult to influence and change (particularly in takeaway and delivery, where visibility into, and control over, consumer behaviour is highly limited). Estimates suggest that a reusable cup needs to be reused between 50 and 100 times to make it environmentally preferable to a single-use cup from a plastic waste generation point of view.1 Yet, early pilots are showing that return rates for reusable options have been very low, which significantly impacts reuse rates. In France, for instance, where reusables are available for dine-in only and should not leave the restaurant, McDonald’s is seeing a loss rate of around 15% due to customers taking the items from the restaurant.

…the restaurant, McDonald’s is seeing a loss rate of around 15% due to customers taking the items from the restaurant. Because of this we are not currently achieving the desired reuse rate, or a positive environmental outcome. In Germany, despite customers paying a deposit of 2€ per reusable item, 70% of reusables are not being returned to the restaurant. The impact of the current PPWR proposal Based on independent data and our experience with reusables in France and Germany, we are concerned that the bans and reduction targets on single use (fibre-based) packaging in the proposed PPWR will likely be counter-productive to the overall EU Green Deal objectives and will be damaging for the economy, environment, food safety and consumers.

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