European Fruit Juice Association

• Page 1 of 3 AIJN - EUROPEAN FRUIT JUICE ASSOCIATION Rue de la Loi 221 box 5, B-1040 Brussels | T: +32 (0)2 235 06 20 | E: [email protected] VAT N° BE0455 760 537 Brussels, March 2023 Position Paper on the Proposal for a Packaging and Packaging Waste Regulation AIJN – the association representing the European fruit juice industry – fully supports the EU’s objective and ambitions to address the challenges regarding packaging and packaging waste. Further, the sector believes that the PPWR can play a decisive role in driving greater circularity of its packaging. The future enforcement of the revised PPWR will undoubtedly have an enormous impact on the entire fruit juice value chain. AIJN, its member associations and companies operating in the fruit juices and nectars industry would thus like to harmoniously draw attention to the fact that the Commission’s Proposal has not recognised fruit…

…increase the sector’s risks of food loss, food safety and increase the potential negative impacts on the environment. 1. Mandatory re-use targets are not a feasible solution for microbiologically sensitive products Concerns from the sector arise not from the level or the existence of the proposed re-use targets, but from the very nature of fruit juices and nectars. Indeed, the role of their packaging is crucial to present an effective barrier against oxygen, light, loss of aromas, and entry of microorganisms. Unlike soft drinks and natural mineral waters, with which fruit juices and nectars currently find themselves with in the “non- alcoholic beverages” category, fruit juices and nectars are more microbiologically sensitive and easily fermentable.1 They require specific sterilisation/pasteurisation processes to ensure a longer shelf life.

…and easily fermentable.1 They require specific sterilisation/pasteurisation processes to ensure a longer shelf life. Regarding the storage period, packaging plays an especially crucial role because producers are not allowed to add any preservatives to fruit juices and nectars.2 In consequence, in inappropriate packaging, there would inevitably be more spoilage, food waste, and risk to consumer safety.3 These requirements apply to all microbiologically sensitive products, of which liquid milk is an example of, and they are already exempted from the present targets.

…sensitive products, of which liquid milk is an example of, and they are already exempted from the present targets. This explains why the sector’s current packaging mix is made up of, on a European level: 60% aseptic cartons, 31% plastic, 8% glass, and 1% other (such as aseptic pouches and cans),4 similar to the liquid milk’s packaging mix.5 Thus, an objectively low proportion of reusable packaging is motivated by the specific requirements of final products, and logistics which make re-use systems difficult to put in place. 1 “Juice processing and preservation” in Fruit juices: extraction, composition, quality and analysis, ed. by G. Rajauria & B. Tiwari. 2018. Page 5.

…in Fruit juices: extraction, composition, quality and analysis, ed. by G. Rajauria & B. Tiwari. 2018. Page 5. 2 Directive 2012/12/EU of the European Parliament and of the Council of 19 April 2012 amending Council Directive 2001/112/EC relating to fruit juices and certain similar products intended for human consumption 3 “Pathogens and spoilage microorganisms in fruit juice: an overview”, B. de Cássica Martins Salomão, in Fruit juices: extraction, composition, quality and analysis, ed. by G. Rajauria & B. Tiwari. 2018. Page 291. 4 “Liquid Fruit Market Report”, in AIJN Global Market Report, 2018. Page 7. 5 “Table IV-1: Composition of the representative product for liquid milk” in Product Environmental Footprint Category Rules for Dairy Products. April 2018. Pages 151-152. Ref.

…for liquid milk” in Product Environmental Footprint Category Rules for Dairy Products. April 2018. Pages 151-152. Ref. Ares(2023)2843956 - 21/04/2023 • Page 2 of 3 AIJN - EUROPEAN FRUIT JUICE ASSOCIATION Rue de la Loi 221 box 5, B-1040 Brussels | T: +32 (0)2 235 06 20 | E: [email protected] VAT N° BE0455 760 537

ASSOCIATION Rue de la Loi 221 box 5, B-1040 Brussels | T: +32 (0)2 235 06 20 | E: [email protected] VAT N° BE0455 760 537 2. Due to these characteristics, there is no technical alternative to reusable packaging except refillable glass Indeed, because of the products’ characteristics, there are serious limitations for setting up re-use systems and in the choices for reusable packaging. The only returnable packaging, technically feasible for fruit juices and nectars today, is returnable glass. Therefore, complying with the proposed targets of achieving 10% and then 25% reusable packaging use, means companies need to move exclusively to glass packaging. This lack of choice is especially difficult because it entails investments solely in glass packaging and glass bottling lines, along with washing stations (in-house or outsourced). Furthermore, unlike other non-alcoholic and non-sensitive…

…the trials industry has conducted for the past 15 years, in Germany for instance, currently this is still the case. 3. Lack of environmental benefits for mandatory re-use requirements Following a thorough analysis of the European Commission’s Proposal, Annex and Impact Assessment, there is no evident environmental study on the consequences of installing reusable packaging and re- use lines. There is also no proof of the undeniable benefits that re-use would bring when compared to other packaging solutions, and methods of dealing with packaging waste. Cleaning reusable packaging from fruit juice is not comparable with the non-alcoholic beverages they are categorised with. The process automatically demands more washing cycles, water, and cleaning agents as fruit juice and nectar residues - solidified pulp due to a loss of moisture - cling to the bottles’ interior. Reconditioning the…

…on the environment and go against the fruit juice sector’s ongoing commitments to reaching net-zero emissions by 2050. 4. Increase packaging circularity with complementary re-use and recycling measures Re-use where it makes sense: The European fruit juices and nectars industry welcomes the needed changes and ambitions from this Proposal, but calls on legislators to make them feasible. Re-use is one of the many directions to deliver on its objectives, but only if it is a complementary measure to other solutions, such as recycling. A top-down, one-size-fits-all approach for re-use fails to take into account Member State specificities as well as past investments from industry, both in collection and recycling.

…into account Member State specificities as well as past investments from industry, both in collection and recycling. This is all the more important as the sector is small compared to other non-alcoholic beverage industries, 6 “Analyse de 10 dispositifs de réemploi-réutilisation d’emballages ménagers en verre : évaluation environnementale, économique et sociale”, Rapport de l’ADEME, Octobre 2018. Pages 63, 64, and 81.

…en verre : évaluation environnementale, économique et sociale”, Rapport de l’ADEME, Octobre 2018. Pages 63, 64, and 81. • Page 3 of 3 AIJN - EUROPEAN FRUIT JUICE ASSOCIATION Rue de la Loi 221 box 5, B-1040 Brussels | T: +32 (0)2 235 06 20 | E: [email protected] VAT N° BE0455 760 537 representing in 2021 6,9% of the beverage market in the EU (8,5 bn litres in market volume out of 123,9 bn litres).7 While the industry is not against re-use systems and reusable packaging, it asks only that it be implemented by actors where it makes sense, on a case-by-case basis, enabling both economic and environmental benefits. Ambitious recycling measurers coupled with mandatory collection targets: The industry fully supports higher recycling rates and requirements for packaging. A pre-condition to recycling packaging is that it be collected.

…recycling rates and requirements for packaging. A pre-condition to recycling packaging is that it be collected. To ensure that every beverage packaging can reach the recycled at scale target by 2035, the sector defends a mandatory 90% separate collection rate at Member State level. Linked to this, the Proposal’s wide roll-out of DRS in Europe for certain beverage packaging is welcome, as well as the development of minimum requirements to ensure those systems are set up and run in the most effective and efficient way. As DRS systems are today the only system capable of delivering over 90% separate collection rates, the sector would like to go further by considering that, should a 90% separate collection target not be reached by Member States, a DRS system for the specific beverage packaging that is not collected should be mandatorily set up.

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