Kaneka Europe Holding Company N.V.

…page 1 Date: 5th of January 2021 Re: Kaneka’s Response to Public Consultation to inform the review of the requirements for packaging and other measures to prevent packaging waste. Founded in 1949 and headquartered in Osaka and Tokyo, Kaneka Corporation produces chemical intermediates such as chemicals, functional plastics, foamed plastics and products,… for a variety of applications including packaging. Kaneka employs more than 10,000 people worldwide and has been active in the EU since 1970 through Kaneka Belgium and has currently an extensive network within the EU through Kaneka Europe Holding. As a sustainable company, Kaneka is committed to addressing the environmental challenges of our planet, contributing to the circular economy and to a better quality of life for our societies.

…challenges of our planet, contributing to the circular economy and to a better quality of life for our societies. For this reason, we want to express our appreciation to the EU Commission for its openness and transparency. This public consultation is of great importance to industry to create legal certainty with a view to promote further research and innovation by reviewing the requirements for packaging and packaging waste; as a condition for the realization of the objectives as set within the “New circular economy action” and the “The European Green Deal” Within this later, it is stated that new technologies, sustainable solutions and disruptive innovation are critical to achieve the objectives of the European Green Deal.

…sustainable solutions and disruptive innovation are critical to achieve the objectives of the European Green Deal. Through innovative fermentation processes, Kaneka develops and produces natural polymer structures (such as Kaneka Biodegradable Polymer PHBHTM, a PHA (Polyhydroxyalkanoate)) suitable for advanced packaging applications, which are biobased, recyclable and biodegradable in open environment in case of leakage; as requested. In this respect, we would like to highlight some additional points, strengthening our position within the above referenced questionnaire related to review the essential requirements for packaging.

…our position within the above referenced questionnaire related to review the essential requirements for packaging. Definition Recyclability: Within The Green Deal, it is mentioned that the Commission will develop requirements to ensure that all packaging in the EU market is reusable or recycleable in an economically viable manner by 2030” Organic recyclable packaging plays undeniable a role for packaging which are difficult to be recycled in a mechanical or chemical way (f.e. due to organic contamination,…) and which can contribute to the collection of bio-waste in respect to quantity and quality of the compost/digestate. The study on “Effectiveness of the Essential Requirements for Packaging and Packaging Waste and proposals for Reinforcement” as worked-out by Eunomia recognized the need for a proper definition for recyclable packaging.

…for Reinforcement” as worked-out by Eunomia recognized the need for a proper definition for recyclable packaging. Unfortunately, organic recycling is not well addressed within this discussion. For this reason, we propose to keep a proper definition for recycleable packaging including organic recycling, f.e. in line with Art 3 (17) of the Waste Framework Directive, which is Ref. Ares(2021)113232 - 06/01/2021 page 2 Recycling means any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes.

…waste materials are reprocessed into products, materials or substances whether for the original or other purposes. It includes the reprocessing of organic material but does not include energy recovery and the reprocessing into materials that are to be used as fuels or for backfilling operations Harmonized requirements for Biodegradable y and Compostable Packaging As expressed in the plastic strategy, the EU commission will propose harmonized rules for defining and labelling compostable and biodegradable plastics. We strongly support this initiative by the Commission in order to ensure that consumers are provided with clear and correct information.

…this initiative by the Commission in order to ensure that consumers are provided with clear and correct information. Replacing conventional packaging one-to-one with organic-recyclable packaging is not always better and more sustainable and that is why we support as Kaneka the waste hierarchy Nevertheless, there are situations where organic recyclable packaging has a clear added value, both for the consumer, the collector, as well as the processing sector. The added value of organic recyclable packaging is most obvious in case at the end-of-life there is a clear link with bio-waste; such as products mixed-up with bio- waste and/or a considerable likelihood of ending up in the bio-waste. We clearly agree to set clear criteria for the use of compostable packaging however, a priory restricting the type of packaging that can be designed for composting would definitely hamper innovations.

…a priory restricting the type of packaging that can be designed for composting would definitely hamper innovations. Within this discussion, we would clearly request the EU commission also to set-out harmonized rules including home-compostable packaging in addition to industrial compostable packaging. On top of that, we would like to request the EU commission to realize an assessment of the scientific and technical progress concerning criteria or a standard for biodegradability in the marine environment applicable to single use products (which may or may not be packaging) as within the scope of the directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment. Bioeconomy: Within the new Circular Economy Action Plan, the importance of the bioeconomy has been stressed.

Bioeconomy: Within the new Circular Economy Action Plan, the importance of the bioeconomy has been stressed. In order to further stimulate these innovations and to realize a “low carbon economy”, we would recommend the EU Commission to promote the use of bio-based and renewable resources for the manufacturing of packaging which helps achieve Greenhouse Gas emission neutral society, equivalent to the promotion of recycled content. ____________________________

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…page 1 In respect to the revision of the packaging and packaging waste directive, we are delighted to see the proposal of the EU Commission to regulate compostable packaging’s across Europe, according to well-defined criteria to ensure the environmental benefits of these innovative materials. We are supportive to set the packaging’s as tea or coffee bags and single serve units, sticky labels attached to fruit and vegetables and very lightweight plastic carriers bags to be mandatory compostable and to set acts to further extend the list in order not to hamper innovations. In addition, we would like to request the legislators to: (1) Develop harmonized standards or criteria on anaerobic digestion and home- compostability to have the requirements on compostable packaging aligned with current and future bio-waste treatment facilities.

…to have the requirements on compostable packaging aligned with current and future bio-waste treatment facilities. (2) Not hamper innovations and be more supportive towards innovative plastic packaging being not persistent in nature in case of leakage. (3) Set mandatory target for plastic packaging including both recycled as bio-based content. (1) As of today, bio-waste treatment within the EU member states is still very fragmented, whereby technologies as anaerobic digestion is supported within the “Farm to Fork Strategy” and home-composting encouraged within the “Waste Framework Directive”. To ensure compostable packaging enters the organic waste management stream across Europe, we urgently request to have the standards aligned by developing harmonized standards on compostable packaging covering anaerobic digestion and home-composting conditions.

…developing harmonized standards on compostable packaging covering anaerobic digestion and home-composting conditions. (2) The environmental benefit of biodegradable packaging should be considered as well related to the persistency in nature of the packagings and related microplastics, when unintentionally or accidentally leak. While “biodegradability in open environment” as such is neither to be promoted nor endorsed as is the case with any kind of waste, “no promotion/endorsement policy” alone could address unintentional/accidental leakage of packaging waste into the sea, where marine biodegradability plays an important role. Industry is looking into substitutions to fossil based materials and packaging that are biobased, recyclable and marine- biodegradable, as also requested within the EU Commission Bioeconomy strategy (2018).

…biobased, recyclable and marine- biodegradable, as also requested within the EU Commission Bioeconomy strategy (2018). In order not to hamper such innovations, sufficient time and innovative new recycling technologies, which includes composting, need to be foreseen when placing such packaging on the market (such as for non-reusable take-away food and beverage packaging). Ref. Ares(2023)2238631 - 28/03/2023 page 2 (3) Mandatory targets for a minimum recycled content in plastic packaging, recovered from post- consumer plastic waste, is proposed, to create a market for post-consumer plastic waste. In parallel, within the EU Policy framework on biobased, biodegradable and compostable plastics, the use of organic waste and by-products as feedstock for biobased plastics is prioritized.

…and compostable plastics, the use of organic waste and by-products as feedstock for biobased plastics is prioritized. In order to stimulate a circular and fossil-free economy, we would like to request mandatory targets for biobased and renewable resources equivalent to the promotion of recycled plastic content. Founded in 1949 and headquartered in Osaka and Tokyo, Kaneka Corporation produces chemical intermediates such as chemicals, functional plastics, foamed plastics and products,… for a variety of applications including packaging. Kaneka employs more than 10,000 people worldwide and has been active in the EU since 1970 through Kaneka Belgium and has currently an extensive network within the EU through Kaneka Europe Holding.

…since 1970 through Kaneka Belgium and has currently an extensive network within the EU through Kaneka Europe Holding. As a sustainable company, Kaneka is committed to addressing the environmental challenges of our planet, contributing to the circular economy and to a better quality of life for our societies. Through innovative fermentation processes, Kaneka develops and produces natural polymer structures (such as Kaneka Biodegradable Polymer Green PlanetTM, a PHA (Polyhydroxyalkanoate)) suitable for advanced packaging applications, which are biobased, recyclable and biodegradable in open environment in case of leakage.

originalus šaltinis (PDF) ↗