CEPI Eurokraft

…2023-04-21 CEPI Eurokraft feedback on the EC proposal of PPWR CEPI Eurokraft acknowledges the European Commission’s proposal for the Packaging and Packaging Waste Regulation. However, the Regulation should aim to make packaging more circular in a holistic way without giving certain materials a disproportionate market advantage. Material neutrality would be better maintained if the legislation were to consider recycling and reuse as equally viable options for packaging circularity. Additionally, five points further elaborated here below: • Renewable raw materials should be recognised as contributor to climate neutrality. • Market restrictions should be evaluated to ensure they do not increase negative environmental impact and food waste. • Recyclability requirements should be aligned with the Design for Recycling criteria and set recycling rates.

…waste. • Recyclability requirements should be aligned with the Design for Recycling criteria and set recycling rates. A mandatory collection target for all packaging formats is necessary to reach the recyclability requirements. • Reuse targets should be realistic and positive for the environment, society, and economy following science-based policy making. • Mandatory recycled content should be set only for plastic packaging, according to the Circular Economy Action Plan. Renewable raw materials should be recognised as contributor to climate neutrality. As the aim of the proposed Regulation is to use our resources more efficiently, it is important to prioritise products made from renewable raw materials. Renewable materials from sustainable sources are circular as they are not only recyclable in the short perspective, but also replenished and recovered repeatedly.

…are circular as they are not only recyclable in the short perspective, but also replenished and recovered repeatedly. Market restrictions should be evaluated to ensure they do not increase negative environmental impact and food waste. Measures on packaging prevention, including market restrictions, should be meaningful, achievable, and support the overall objectives of the EU Green Deal and Circular Economy. Banning single use packaging for fruits and vegetables (containing less than 1,5kg) and single- use packaging in the HORECA sector, as suggested in points 2, 3 and 4 of Annex V, could be counterproductive for the economy and the environment. Every packaging is created with a purpose to protect, preserve, and promote a product.

…the economy and the environment. Every packaging is created with a purpose to protect, preserve, and promote a product. The loss or damage of a product has a higher environmental impact compared to the savings achieved by reducing the packaging itself, in terms of resources used and emissions created. Ref. Ares(2023)2836365 - 21/04/2023 2023-04-21 For packed food products, packaging only makes up 3-3.5% of the carbon footprint1. Therefore, if the market restrictions result in packaging removal or minimisation, leading to increased bulk packaging, the resulting damaged food will increase food waste and worsen environmental impacts. If reusable systems are implemented instead, then the environmental impact of the water usage required for cleaning processes must also be taken into consideration.

…then the environmental impact of the water usage required for cleaning processes must also be taken into consideration. Additionally, single-use packaging helps ensure that hygiene and food safety standards are met by food packaging. Reusable packaging for fruits and vegetables, on the other hand, brings increasingly complex logistic challenges related to transport, sanitation and storage. If not effectively implemented, these systems can spread contamination, leading to increased food waste and food safety issues. Recyclability requirements should be aligned with the Design for Recycling criteria and set recycling rates. A mandatory collection target for all packaging formats is necessary to reach the recyclability requirements.

…rates. A mandatory collection target for all packaging formats is necessary to reach the recyclability requirements. The PPWR proposal sets clear recyclability requirements and suggests that Design for Recycling criteria are established for specific types of packaging, as listed in Annex II, Table 1. In the case of paper and board, two different types of paper & board packaging are identified: Paper/Cardboard packaging and composite packaging of which the majority is paper/cardboard. However, the recycling rates in Article 46 of the proposal for specific materials are set for paper & cardboard only.

However, the recycling rates in Article 46 of the proposal for specific materials are set for paper & cardboard only. It is recommended using the approach provided by Article 46 also for the assessment of the recyclability requirements (Annex II, Table 1) and for data collection (Annex XII, Table 4), including recycling at a scale where the evaluation is made for all paper & board packaging being recycled at Union level. This will allow for harmonized implementation and assessment across industry sectors and Member States and is also in line with the definition on “recycled at scale” according to Article 3(32).

…sectors and Member States and is also in line with the definition on “recycled at scale” according to Article 3(32). The industry should be involved in the drafting of the Design for Recycling Guidelines (DfR) in a systematic and transparent way through the independent standardisation body, European Committee for Standardisation (CEN), which would allow for open cooperation and exchange of expertise to set ambitious and realistic requirements on packaging recyclability. While the PPWR proposal addresses key issues related to recyclability, it does not regulate an essential step to increase recycling: collection. For recycling rates to improve, separate and effective collection of packaging is a logical prerequisite. The regulation should address the need for efficient collection systems in Member States to facilitate the achievement of the established recycling targets.

…for efficient collection systems in Member States to facilitate the achievement of the established recycling targets. Reuse targets should be realistic and positive for the environment, society, and economy following science-based policy making. The suggested high reuse targets will result in the substitution of paper & board with plastic packaging, for which recycling is already challenging. These risks flooding the market with millions of tons of plastic packaging, giving plastic a disproportionate advantage and increasing 1 guideline_stopwastesavefood_en_220520.pdf (denkstatt.eu) 2023-04-21 the EU’s dependency on imported fossil resources. This ultimately fails to fulfil the main objective of the PPWR proposal and harms the competitiveness of the internal market.

…fails to fulfil the main objective of the PPWR proposal and harms the competitiveness of the internal market. In addition, effective reuse systems can only be achieved with high level of standardization of packaging formats, which ignores innovation and limits competition. Standardized packaging also risks increasing overpackaging, directly contradicting the Commission’s ambition to limit excessive packaging. Reuse systems also require more logistics, transport, washing, etc., which will significantly increase emissions, water and chemical usage and overall environmental impact. Existing studies indicate that reuse has higher environmental impact compared to recyclable packaging for certain studied applications2. Therefore, reuse systems can only be part of the circular solution3.

…for certain studied applications2. Therefore, reuse systems can only be part of the circular solution3. While other studies deny this, the reality shows that reuse systems have not worked in practice4 and do not always provide the expected environmental benefits. Reuse targets that do not consider existing scientific evidence will fail to support the EU’s green ambitions. We therefore recommend that recycling and reuse act as complementary measures following science-based policy making and life cycle thinking. Mandatory recycled content should be set only for plastic packaging, according to the Circular Economy Action Plan.

Mandatory recycled content should be set only for plastic packaging, according to the Circular Economy Action Plan. The Circular Economy Action Plan states that “to increase uptake of recycled plastics and contribute to the more sustainable use of plastics, the Commission will propose mandatory requirements for recycled content and waste reduction measures for key products such as packaging, construction materials and vehicles”. Based on this call to increase the amount of recycled plastic, Article 7 of the PPWR should only establish recycling content requirements for plastic packaging, not the ‘plastic part in packaging’. The current text extends the scope of the requirement beyond plastic packaging to all packaging that uses polymer-based adhesives, varnishes inks and coatings.

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