Plastics Europe

Rethinking Packaging: An overview of the key principles that should guide the revision of the Packaging and Packaging Waste Directive and the Essential Requirements for packaging This paper forms part of PlasticsEurope’s response to the European Commission’s public consultation to inform the review of the requirements for packaging and other measures to prevent packaging waste. It should be read as part of our questionnaire response. Key messages  PlasticsEurope welcomes the revision of the Packaging & Packaging Waste Directive as a critical moment to harness the power of the internal market to lead to an increase in packaging reuse and recycling, optimisation of design, and material use (e.g.

…internal market to lead to an increase in packaging reuse and recycling, optimisation of design, and material use (e.g. amounts and types of feedstock);  We support policy options to: identify areas where packaging is critical; define ‘recyclability’ using a qualitative statement; and provide guidance on effective and safe reuse and recycling systems by reference to a CEN standard and best available technologies;  The revised EU harmonised framework for packaging should ensure strong enforcement, the respect of the single market principles and a clear, consistent and evidence based legal framework to support industry’s circularity and carbon-neutrality transition. Introduction PlasticsEurope, the association of European plastics producers, supports the sustainable growth strategy as outlined in the European Green Deal, and the decoupling of economic growth from resource use.

…growth strategy as outlined in the European Green Deal, and the decoupling of economic growth from resource use. We support the ambition set out in the EU Circular Economy Action Plan (CEAP) 2.0 for all packaging to be reusable or recyclable by 2030 in a viable and cost efficient manner. We therefore welcome the forthcoming revision of the EU’s Packaging & Packaging Waste Directive (PPWD) to make it fit for the purpose of achieving this ambitious and necessary targets. Objectives of the PPWD revision Our members are committed to playing their part by continuing to find and implement the solutions and new business models to achieve plastic packaging circularity challenges faced by the plastics packaging value chain.

…new business models to achieve plastic packaging circularity challenges faced by the plastics packaging value chain. At the same time, we call for the adoption of effective and harmonised rules which will support the role of plastic packaging as an enabler of circularity and a low CO2 future. In our view, this requires an approach encompassing the products’ full lifecycle including measures guiding the design phase, clearer labelling, harmonised and improved collection and sorting, and development of new sorting and recycling technologies together with accompanying end markets for recycled materials all underpinned by Life Cycle considerations.

…together with accompanying end markets for recycled materials all underpinned by Life Cycle considerations. This must be accompanied by effective and workable Extended Producer Responsibility (EPR) systems and a clear investment framework for supporting innovation and the development of the required infrastructure to meet the Circular Economy Goals for recycling. From our perspective, the PPWD legislative revision should stimulate new packaging design choices including volume and weight reduction, reuse and recyclability as well as the progressive increase in the use of recyclates. Waste Prevention Ref.

…reduction, reuse and recyclability as well as the progressive increase in the use of recyclates. Waste Prevention Ref. Ares(2021)139328 - 07/01/2021 December 2020 Key issues While we agree that there is ample room to improve the sustainability of packaging, we urge the Commission to look at the prevention of packaging waste at the same time as ensuring the best protection of the packed goods as the key drivers for new packaging requirements. Successful achievement of the Green Deal’s climate targets requires consideration of the significant savings provided by light weight plastic packaging in terms of material use, reduced transport emissions while at the same time ensuring excellent functionality, e.g. safety, hygiene, shelf-life extension, etc. We therefore believe that the amounts (i.e.

…excellent functionality, e.g. safety, hygiene, shelf-life extension, etc. We therefore believe that the amounts (i.e. weight) of packaging placed on the market as well as the type of materials, material combination or polymer used should not be seen in isolation from the packed product. If prevention is seen instead through the lens of the packaged product’s life cycle, changes to the PPWD could achieve even greater GHG savings. Thus, life cycle assessment or robust scientific findings should determine which type of material, material or polymer combination or no material should be used to achieve the required functionality and in order to avoid regrettable burden shift. Policy options PlasticsEurope supports the Commission’s objectives to: - limit the volume and weight of packaging necessary to perform its function.

…supports the Commission’s objectives to: - limit the volume and weight of packaging necessary to perform its function. This could be achieved through the harmonised definition of under and over-packaging; and - secure a transition to reusable and recyclable packaging solutions ensuring that such measures do not result in unintended adverse effects on the environment and human health. A holistic approach may support this goal, by assessing the overall environmental footprint of the packaging together with the packaged goods. In our view, this critical assessment should also look at other legal requirements such as those on function, hygiene, safety and legally required information.

…also look at other legal requirements such as those on function, hygiene, safety and legally required information. This granular approach which looks at the packaging together with the goods to be packed helps identifying the cases where packaging could be avoided and goods could be sold loose, or also where size prescription could represent an effective and viable solution. Such specific assessments would prevent possible unintended and regrettable environmental consequences. For packaging to serve waste prevention goals, an EU harmonised internal market conformity assessment and consistent and effective market surveillance mechanisms are indispensable. Once packaging is compliant with the essential requirements and compliance is assessed in consistent ways, then its market access and free circulation should be ensured, preventing undue hindrances.

…in consistent ways, then its market access and free circulation should be ensured, preventing undue hindrances. Reuse Key issues In the CEAP 2.0, the Commission notes its intention to drive design for reuse of packaging as this can support a reduction in packaging waste generation and could lead to decreased GHG emissions. We support the reuse of packaging where this triggers waste prevention and is overall environmentally beneficial and meets hygiene standards. December 2020 Thanks to its versatility and durability, reusable plastic packaging is already widespread in industrial, consumer and commercial applications1. Nevertheless, the possibility and the benefit of choosing reusable packaging should be considered on a case-by-case basis taking into account the nature of both the packaging and the packed product and in view of environmental, hygiene and consumer safety requirements.

…of both the packaging and the packed product and in view of environmental, hygiene and consumer safety requirements. Policy options PlasticsEurope supports the adoption of a harmonised definition of effective reuse systems through reference to a European standard. The same degree of rigor should be applied into the definition of reuse and refillable as for recyclable packaging. We recommend that the Commission carries out careful analysis to identify where reusable systems may reduce overall packaging waste without having unintended consequences such as net increases in GHG emissions or damage to or losses of packaged goods, safety, hygiene etc. Reuse should be defined on the basis of a dynamic approach that allows innovative solutions and adaptation over time with a view to optimising the environmental footprint of packaging that is suitable for multiple rotations.

…over time with a view to optimising the environmental footprint of packaging that is suitable for multiple rotations. Recycling – Definition of recyclability and use of recyclates We recognise the challenges to be overcome in order to make all plastics packaging reusable or recyclable by 2030. We understand the need for these ambitious goals and our members are taking steps, in collaboration with the rest of the plastics packaging value chain, to meet these targets and ensure that this equates to environmental benefits and resource savings. Key issues In the CEAP 2.0, the Commission emphasises its intention to consider measures to drive design for the reuse and recyclability of packaging, including by defining what is meant by ‘recyclable’. It also states that the incorporation of recycled content in packaging is a key step to optimise the use of natural resources and cut emissions.

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July 2020 REPLY TO THE CONSULTATION ON THE INCEPTION STUDY ON REVIEW OF THE REQUIREMENTS FOR PACKAGING AND OTHER MEASURES TO PREVENT PACKAGING WASTE PlasticsEurope welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to review the rules regulating the placing on the market of packaging with a view to make packaging increasingly sustainable and circular, and minimize waste to preserve the planet’s resources (materials, food, water, energy, etc.). We applaud the EU Commission for its efforts and at the same time would like to emphasize that we are committed to doing more to boost our positive impact on waste prevention and resource savings.

…to emphasize that we are committed to doing more to boost our positive impact on waste prevention and resource savings. To this end and in order to achieve these pivotal objectives, we ask that future policy developments ensure a well-functioning internal market through fully harmonized rules and requirements at EU level, which should: - enable circularity and sustainability while allowing operators to maintain the plastics essential functionalities - which ultimately provide for environmental benefits; and - ensure the possibility to guarantee compliance with all the relevant rules on consumer health and safety.

…and - ensure the possibility to guarantee compliance with all the relevant rules on consumer health and safety. To this end we kindly ask the Commission to bear in mind that since the entry into force of the currently applicable essential requirements (ER), the plastic industry has achieved remarkable progress in the packaging sector regarding circularity, sustainability and waste prevention. Currently, plastic packaging uses far less raw materials for its production and is more and more recycled at the end of its life (reaching an average recycling rate of 42% in Europe in 2018); at the same time, packaging still protects goods from damage during transport and other logistic phases. The light weight of plastic packaging helps to reduce transportation energy, decrease emissions and lower shipping costs (which would otherwise increase following the success of e- commerce).

…decrease emissions and lower shipping costs (which would otherwise increase following the success of e- commerce). When it comes to food, packaging increases shelf life – thus maximizing the resource efficiency of packed goods throughout their life. The protecting and preserving properties of packaging ultimately help prevent waste and preserve resources. For these reasons plastics have represented an ideal packaging material for all sorts of commercial and industrial users. In addition, plastics have helped manufacturers comply with fundamental design requirements for consumer protection, product safety and hygiene. Nevertheless, PlasticsEurope is committed to further improve and aims at being a key enabler in the transition towards a new environmental and economic model.

…to further improve and aims at being a key enabler in the transition towards a new environmental and economic model. We are supportive of a better integration of the end-of-life phase in product design in order to create circularity at source. Recycling and reuse are intrinsic to a circular economy model and must be promoted to the extent they represent the most resource efficient end-of-life management measures. Ref. Ares(2020)4123241 - 05/08/2020 PlasticsEurope is therefore supportive of the overarching objective of ensuring that that 100% of packaging by 2030 should be designed to be reusable or recyclable, but also stresses that the combination of the packaging and the content should together ensure primarily waste prevention.

…also stresses that the combination of the packaging and the content should together ensure primarily waste prevention. However, this ambitious goal should: - consider exemptions to such requirements where packaging types would require other end-of-life management solutions for overriding health, safety, environmental and legal reasons; - not preclude further innovations which could improve all the main plastics functionalities (e.g. feedstock use; use performance; end-of-life options), which could ultimately result in noticeable environmental benefits. In this context, the definition of “recyclability” plays a crucial role in identifying the conditions that have to be fulfilled for a packaging to meet possible future revised ER. This definition has to be fit for purpose by: - reflecting the current and viable future developments in waste management; - allow innovation (e.g.

…for purpose by: - reflecting the current and viable future developments in waste management; - allow innovation (e.g. improvement of and/or deployment of new recycling technologies); and - ensure a level-playing field between recycling technologies and between materials. In particular, a too prescriptive or quantified definition would unduly discriminate different types of packaging and materials for reasons that are beyond the control of the manufacturer. Such reasons include existence of appropriate collection schemes or of recycling facilities. We therefore support a recyclability assessment made at EU level, which also takes into account the evolution of packaging design, material innovation, collection, sorting, recycling technologies, etc.

…into account the evolution of packaging design, material innovation, collection, sorting, recycling technologies, etc. A similar holistic approach should be followed to ensure a decisive and really environmentally beneficial reduction of waste and packaging waste, assessing the combination “packaging material – packaged goods”. This means that measures that could affect specific packaging formats, material choices or packaging reduction should be fully and thoroughly assessed - including on health and safety aspects - and such conditions should equally apply regardless of the material type considered. This will help in optimizing the overall environmental and societal benefits of packaging applications, making sure that the future packaging rules will trigger effective benefits and prevent adverse undesired consequences (e.g.

…sure that the future packaging rules will trigger effective benefits and prevent adverse undesired consequences (e.g. measures aimed at addressing one issue does not harm other sustainability objectives). We therefore call the European Commission to scrupulously assess the impacts of the policy scenarios it will envisage and to continuously consult the plastic industry and more generically the packaging value chains in order to draft legal requirements that are effective, manageable and dynamic. This will guarantee the achievement of the desired sustainability and circularity targets, and still allow the industry to support a much needed economic recovery.

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