The Finnish Packaging Association

Review of the Packaging and Packaging Waste Directive EUROPEN accompanying document to the Public Consultation questionnaire December 2020 Striving for an ambitious and coherent legislative review Packaging of the future will have to be reusable or recyclable in an economically viable way, support the EU climate goals and, at the same time, continue to provide safe and sustainable products to consumers. The review of the Packaging and Packaging Waste Directive (PPWD) can represent a real milestone in the process of moving towards a sustainable packaging value chain in Europe. The regulatory framework must be fit for purpose to effectively prevent packaging from becoming waste, by boosting recyclable and reusable solutions while preserving packaging functionalities.

…from becoming waste, by boosting recyclable and reusable solutions while preserving packaging functionalities. • Recognising the purpose of packaging There are good reasons for products to be packaged: to protect products’ integrity and consumers’ health and safety, to increase products’ shelf-life, to reduce product losses, to facilitate transport, efficient handling and distribution, to promote the packaged product and to provide information and convenience to consumers. The policy measures to further drive the sustainability of the packaging value chain must ensure these functionalities are not undermined. • Coherence with the EU environmental and climate objectives Pursuing the EU Green Deal’s objectives requires embracing a life-cycle approach to circularity, where climate and environmental performance is assessed throughout the entire life-cycle of packaging and product.

…where climate and environmental performance is assessed throughout the entire life-cycle of packaging and product. A thorough impact assessment of unavoidable and potential trade-offs, resulting in unintended consequences or negative impacts (environmental, economic and social impacts), will be necessary to ensure that these are minimized or prevented. • Future-proofing of legislation to support innovation Future targets, definitions and design requirements need to provide sufficient visibility to drive investments into new packaging solutions, reuse schemes and waste management technologies. Rather than imposing bans or restrictions on specific packaging materials or formats, policies should strive to ensure that they can become reusable and recyclable in the immediate future. • Single Market for packaging and for secondary raw materials.

…become reusable and recyclable in the immediate future. • Single Market for packaging and for secondary raw materials. The review must address barriers and bottlenecks resulting from insufficient harmonisation and weak enforcement of existing EU provisions at national level. Key provisions must be clearly defined in the legislative text for maximum harmonisation across the Member States and enforcement mechanisms must be strengthened to oversee their effective implementation. Ref. Ares(2021)106955 - 06/01/2021 1. WASTE PREVENTION The overarching goal of any future policy measures addressing packaging waste prevention must be threefold: 1. Optimise the amount of packaging put on the market without undermining packaging functionalities and avoiding undesired trade-offs in other life-cycle stages (e.g. climate impact, food waste).

…functionalities and avoiding undesired trade-offs in other life-cycle stages (e.g. climate impact, food waste). 2. Prevent waste generation and loss of resources due to landfilling, and incineration by maximising packaging reuse and recycling;

…generation and loss of resources due to landfilling, and incineration by maximising packaging reuse and recycling; 3. Reduce the overall EU environmental footprint, with a particular focus on resource use, GHGs emissions. Defining overpackaging and underpackaging Both overpackaging and underpackaging need to be clearly defined to effectively address waste prevention by eliminating unnecessary (i.e. not functional) packaging whilst preventing negative consequences on product safety and integrity. Overpackaging should be defined as packaging which is not functional, i.e. it is not essential to fulfil the functionalities of packaging foreseen by the Essential Requirements. Underpackaging should be defined as packaging which is sub-optimal, i.e. it does not guarantee the fulfilment of packaging functionalities foreseen by the Essential Requirements. Reduce the overall EU climate and…

…and the savings guaranteed through packaging use. The same consideration applies for other environmental impacts. 2. REUSE Reusable packaging systems have an important role to play in a circular economy. Well-designed systems can concretely contribute to resources and material savings while reducing the climate and overall environmental impact of packaging. Upscaling reuse models needs a systemic change of business models and supply chain transformation. Reuse targets alone will not drive such systemic change. Reuse models’ design and management Careful management and design are essential to reap the environmental benefits (including GHG emissions reductions) linked to an increase in reusable packaging, while avoiding unintended consequences such as increased GHG emissions, energy and water consumption, complex logistics, cleaning, food and health safety, and others.

…increased GHG emissions, energy and water consumption, complex logistics, cleaning, food and health safety, and others. Accurate science-based impact assessments, including from a life-cycle perspective, need to accompany the introduction of reuse systems. In this context it is crucial to compare benefits and impacts of single-use and multiple use packaging for the same product categories. Societal and demographic developments also have implications for the effective deployment of reuse systems, which should be part of feasibility assessments. A major issue to assess the environmental impact of business-to-consumer (B2C) reuse systems is data availability/quality. Without digital traceability of number of refills and transport distances, this is very hard to evaluate.

Without digital traceability of number of refills and transport distances, this is very hard to evaluate. Unique coding/serialization for packaging that enables complete track and tracing, including refill cycles, would be necessary to assess the climate and environmental footprint of reuse systems. Reuse must include refill/recharge done both at home and in the shops. This will allow developing refill practices, which contributes to the reduction of material used, and ultimately to the reduction of GHG emissions and other environmental impacts. Requirements for reuse and refill Reuse and refill should comply with the same regulatory requirements that exist for the introduction on the market of any packaged product. The number of rotations of the packaging is not infinite, hence also reusable packaging should be recyclable at the end of its life cycle.

…of the packaging is not infinite, hence also reusable packaging should be recyclable at the end of its life cycle. As the environmental benefits of reuse are strongly dependent on the number of times that the packaging is actually reused, appropriate consideration must be given to the minimum number of rotations that reusable packaging can endure. For example, a pragmatic approach could be envisaged to test the minimum number of rotations per packaging type. From niche to large scale reuse models To bring significant positive environmental outcomes, B2C reusable packaging should be designed to be deployable at the level of the large distribution. This requires convenient collection infrastructure, including for on-the-go- consumption, something which is missing largely from today’s Extended Producer Responsibility (EPR) and Deposit- Refund Schemes (DRS) systems.

…which is missing largely from today’s Extended Producer Responsibility (EPR) and Deposit- Refund Schemes (DRS) systems. Besides the thorough assessment of overall environmental impact, the financial and logistics implications of establishing a take-back infrastructure and storage of empties need to be factored in. For beverages in particular, reuse models (through refillable bottles) in a B2C setting must rely on a DRS. When these are considered, they should fulfill a number of conditions: - Efficient, cost-effective and accountable, - Strong environmental outcomes, - Shared financial responsibility, - Convenient for consumers, - Long-term financial sustainability, - Allow producers to secure material for closed loop recycling. 3. ESSENTIAL REQUIREMENTS The Essential Requirements (ER) for packaging must be strengthened, harmonised and properly enforced across the EU.

Essential Requirements (ER) for packaging must be strengthened, harmonised and properly enforced across the EU. They need to be ambitious to enable the transition towards the policy goals of the New Circular Economy Action Plan and the 2050 EU climate neutrality objective of the European Green Deal. While helping advance packaging sustainability, changes to the ER must preserve packaging’s functionalities, enable innovation and prevent restrictions to the free circulation of packaging and packaged goods in the Single Market. Defining recyclability A clear, harmonised and actionable definition of recyclability is key for the successful revision of the ER and implementation of the PPWD. It must be forward looking and not be based only on what is feasible today.

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