Natural Mineral Waters Europe aisbl

Page 1 of 5 Natural Mineral Waters Europe’s contribution to European Commission’s public consultation on the Proposal for a Regulation on Packaging and Packaging Waste April 2023 Natural Mineral Waters Europe (NMWE) welcomes the ongoing public consultation on the proposed Regulation on Packaging and Packaging Waste (PPWR). Below we are outlining our main recommendations to make the revised EU packaging legislation a stronger and truly enabling legislative framework for packaging circularity. Key messages: ➢ NMWE members share the ambition to make all their packaging reusable or recyclable in a closed loop. To achieve packaging circularity, they believe in a complementarity of solutions based on environmental benefits and specificities of local contexts.

…they believe in a complementarity of solutions based on environmental benefits and specificities of local contexts. ➢ Our members see the revision of the EU Packaging and Packaging Waste legislation as a unique opportunity to deliver full closed loop circularity for beverage packaging while accompanying companies on their journey with adequate safeguards and enablers. ➢ We support the European Commission’s decision to preserve the internal market and legislate via a Regulation (PPWR) with Article 114 TFEU as its legal basis to ensure the necessary harmonization of measures across Member States. ➢ We agree with the PPWR ‘s ambitions to make all packaging recyclable by 2030 and to boost the collection of PET beverage bottles though the setting up of mandatory deposit return systems (DRS), to be set up with harmonised minimum requirements.

…though the setting up of mandatory deposit return systems (DRS), to be set up with harmonised minimum requirements. ➢ While taking a step forward to packaging recyclability and collection, the proposal falls short of defining high-quality recycling. Neither does it provide for a level-playing field for beverage producers, who are already subjected to mandatory minimum recycled content targets as per Single Use Plastics Directive (SUPD) and are currently facing hurdles in accessing the recycled PET derived from the bottles they put on the market. ➢ We therefore call on co-legislators to secure mandated producers’ access to their recycled material prior to the targets coming into effect.

…co-legislators to secure mandated producers’ access to their recycled material prior to the targets coming into effect. ➢ On reuse, we acknowledge that it has an important role to play in reducing packaging waste; however, distribution options should be assessed on their ability to deliver the best environmental outcome rather than imposed as a one-size-fits-all. Also, reuse targets should not jeopardise investments made by the value chain towards circularity. Flexibility should also be allowed for their attainment. Current EU legislative constraints applicable to natural mineral waters and spring waters, such as the obligation to bottle at source, should also be taken into consideration. Ref.

…waters and spring waters, such as the obligation to bottle at source, should also be taken into consideration. Ref. Ares(2023)2874471 - 24/04/2023 Page 2 of 5 ➢ Established reuse systems and well-functioning reuse markets should be protected and exempted from detailed new regulations if these markets already reach the required reuse targets for the mentioned product categories in other ways. ➢ We acknowledge the importance of harmonizing measures on packaging across the EU market, however, we recommend co-legislators to take due consideration of the SMEs dimension and the very significant investments required to switch production and distribution models. ➢ Lastly, we call on the co-legislators to safeguard clarity for consumers for the disposal of packaging covered by DRS and avoid the overlap of several labels concerning packaging waste management.

…the disposal of packaging covered by DRS and avoid the overlap of several labels concerning packaging waste management. We also recommend considering consumers when addressing grouped packaging restrictions. Remarks on specific measures: • Separate collection via Deposit and Return Systems – the key enabler High collection of beverage bottles is an absolute prerequisite for beverage producers to reach the minimum plastic recycled content (65% by 2040) and reuse targets (25% by 2040) set by the Commission in its proposal. We therefore applaud the Commission’s intention to mandate the setting up of DRS across Europe for PET bottles and aluminium cans and establishing minimum requirements for DRS. Whilst the average EU collection rate for PET bottles is stagnating below 60%, Member States with Deposit and Return Systems (DRS) achieve much higher rates– close to 90% on average.

…below 60%, Member States with Deposit and Return Systems (DRS) achieve much higher rates– close to 90% on average. These systems have the additional benefit of providing high-quality, food-grade recycled material. However, the current deadline established in the PPWR (2029)- just one year before the recycled content target kicks-in for beverage producers- and the possibility for ad hoc exemptions for Member States risks compromising the benefit of the measure. We would suggest bringing the deadline for setting up DRS to 2028. As to minimum requirements, we recommend including those developed jointly by NMWE with Zero Waste Europe and UNESDA. They reflect the best practices of existing DRS. • Recycled content in beverage bottles We welcome the Commission’s ambition to continue and reinforce the path set by the SUPD in terms of recycled content incorporation.

Commission’s ambition to continue and reinforce the path set by the SUPD in terms of recycled content incorporation. Circularity is embedded in our members’ business model as they use fully recyclable packaging materials and have a long track record in packaging sustainability as illustrated by high packaging collection and recycling rates. In order to meet their recycled content obligations under the Single Use Plastics Directive (SUPD) or those proposed in the future PPWR, beverage producers need to have access to a sufficient quantity of affordable high-quality food grade recycled PET. Currently, they are struggling to secure access to the recycled material coming from their recycled bottles.

PET. Currently, they are struggling to secure access to the recycled material coming from their recycled bottles. Indeed, recycled PET is in much demand from other sectors for incorporation into lower grade applications, such as textiles or tires, where it will generally no longer be recyclable, thereby bringing close-loop circularity to an end. To enable high quality recycling in closed loop and avoid downcycling, beverage producers – and any other sector to be made subject to mandatory minimum recycled content targets – should be granted preferential access to a fair share of the recycled materials from the bottles they put on the market. Page 3 of 5 Preferential access would also contribute to a well-functioning secondary material market.

…on the market. Page 3 of 5 Preferential access would also contribute to a well-functioning secondary material market. It would stimulate supply by incentivizing design for recycling and recyclability in those applications that currently are not on a circularity path but rely on recycled material derived from PET bottles. In the context of DRS, this access should be part of the applicable minimum requirements. Ultimately, all packaging should be made recyclable and appropriate collection and recycling streams should be in place, as an integral part of extended producer responsibility. The PPWR should define high-quality recycling and within this definition prioritise recycling into the same application where applicable (closed-loop), to foster a true circular economy.

…prioritise recycling into the same application where applicable (closed-loop), to foster a true circular economy. • Minimum recycled plastic content target The prescription for manufacturers to reach recycled content targets on a per unit basis is unnecessarily limiting and disproportionally disruptive to companies’ operations, while not providing any environmental advantage against reaching the same target calculated per yearly production. We therefore recommend co-legislators to ensure that recycled content targets are set per the producer’s annual EU portfolio. Pre-consumer waste should also be taken into consideration given that such an approach would be in line with the corresponding ISO standard. We also call on the suspension of minimum recycled content target if the supply of material is insufficient due to low collection or leakage of the material into non-circular applications.

…the supply of material is insufficient due to low collection or leakage of the material into non-circular applications. • Reuse targets We acknowledge Commission’s ambition to reduce packaging waste through reuse and refill targets and we share the objective to reduce the impact of packaging on the environment. Our members already offer reusable packaging (essentially in the HoReCa channel) and are ready to increase its share where it makes environmental sense as part of the solutions to reach full circularity. Life cycle analyses demonstrate that the environmental benefit of reuse over closed loop recycling is context-specific whilst the shift to reuse implies very significant investments and operating costs (bottling line, sorting and cleaning of bottles, fleet, reverse logistics, etc.) for manufacturers.

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