Food and Beverage Carton Alliance

General REPLY TO THE CONSULTATION ON THE INCEPTION STUDY ON REVIEW OF THE REQUIREMENTS FOR PACKAGING AND OTHER MEASURES TO PREVENT PACKAGING WASTE ACE supports an ambitious implementation of the Packaging and Packaging Waste Directive, as well as the new Circular Economy Action Plan. This is a unique opportunity to scale up the contributions of a circular economy to climate neutrality by incentivising the use of low carbon and circular packaging. ACE specifically calls for an ambitious implementation of the requirement to ensure the separate collection of packaging waste which is essential to achieve a circular economy, as it increases the volume and the quality of materials available for recycling. With regard to the specific objectives of the revision of the PPWD, • ACE strongly supports the objective of the free movement of packaging and packaged goods across EU Member States.

ACE strongly supports the objective of the free movement of packaging and packaged goods across EU Member States. • ACE believes that mandatory provisions on recycled content should only be considered for products or materials for which the use of recycled materials has proven technical and environmental benefits, is safe for consumers based on EFSA assessment of its suitability in food contact materials, and does not decrease the recyclability of the new product. Paper-based packaging is recycled at a very high rate and the paper recycling value chain is a well-functioning one that does not require incentives for the uptake of recycled materials. Such mandatory requirements would likely be counter- productive as they would disturb the existing paper recycling value chain and would not bring additional environmental benefits.

…as they would disturb the existing paper recycling value chain and would not bring additional environmental benefits. We support voluntary initiatives to increase the uptake of recycled materials. Any mandatory requirement should only apply to those packaging materials whose secondary markets need to be incentivized. ACE believes that the reduction of packaging waste should focus on residual packaging waste, i.e. packaging waste that cannot be recycled or reused (and hence is incinerated or landfilled). Circular packaging that contributes to climate neutrality is part of the solution. Reuse is one of the options to reduce residual waste but not the only one as in some cases reusable options have similar or even higher environmental impacts throughout their life cycle when considering the climate impact compared to single use options.

…environmental impacts throughout their life cycle when considering the climate impact compared to single use options. We believe a new consumption model needs both multi- and single-use packaging as long as it takes into account climate neutrality, sustainable sourcing of raw materials including the impact on biodiversity, resource use, circularity as well as food safety and availability. Measures established for the prevention of packaging waste must be adequate and proportional to the objective pursued and should be focused to minimize overpackaging and residual waste. Date: 15 July 2020. Ref.

…to the objective pursued and should be focused to minimize overpackaging and residual waste. Date: 15 July 2020. Ref. Ares(2020)3915931 - 24/07/2020 * “Beverage cartons are recycled at scale across the EU, however, so based upon this consideration they should be categorised as recyclable packaging” – page 142 of the report “Effectiveness of the Essential Requirements for Packaging and Packaging Waste and Proposals for Reinforcement - Final Report and Appendices“ led by Eunomia, February 2020 Page 2 of 3 ACE has the following views on the options proposed to reach the objectives • We support the revision of the Essential Requirements according to which all packaging placed on the market must be low carbon, reusable or recyclable by 2030.

Requirements according to which all packaging placed on the market must be low carbon, reusable or recyclable by 2030. Requiring all packaging to be reusable or recyclable and provide an enforceable definition of what is ‘recyclable’ is the best option as it will de facto eliminate residual waste and hence allow reaching the objective without unnecessarily impacting functional packaging that is necessary to protect food and beverages, protect health and reduce food waste. This measure can be implemented through pay-as-you throw schemes with high fees for residual waste, strict separate collection of packaging to ensure high quality recycling and a clear definition of “recyclable”. Such a provision would provide a stable legislative framework for sustainable investments to meet climate and circularity targets while supporting resilient food systems.

…for sustainable investments to meet climate and circularity targets while supporting resilient food systems. • Restricting the use of some packaging materials to certain applications in particular when alternative reusable products or systems exist may prove to be difficult to implement and hampers innovation. Regulation should set goals and targets but abstain from being overly prescriptive on the means to meet them. • Reducing the complexity of packaging materials including the number of polymers used does not look at the functionality of the packaging. Some beverages or foods are highly sensitive and hence require to be packed in such a way as to avoid wastage and ensure health & safety.

…foods are highly sensitive and hence require to be packed in such a way as to avoid wastage and ensure health & safety. Beverage cartons are mainly composed of fibres, and include polymers to protect from light, oxygen, leakage and loss of nutritious or other properties and in some cases aluminium to allow for storage without refrigeration. The materials used to make a beverage carton can easily be separated during recycling. Fibres are of good quality and hence are in demand as a valuable secondary raw material, Various project and initiatives are underway to increase the recycling of the polymers and aluminium. Beverage cartons are considered as recyclable and recycled at scale in Europe.* • The uptake of recycled content should be should be driven by favouring a voluntary approach.

…at scale in Europe.* • The uptake of recycled content should be should be driven by favouring a voluntary approach. Prior to consider the possible introduction of mandatory requirements for recycled content in packaging, essential framework conditions need to be in place: o Continuity of the EU Internal Market, full transposition and application of the ‘Net Cost’ principle for packaging Extended Producer Responsibility schemes across all Member States, o Functioning EU approval process for use of recycled materials in Food Contact Materials. Any mandatory requirement to use recycled material should only apply to those packaging materials whose secondary markets need to be incentivized. If any such requirement is imposed, e.g. in fiscal measures or in the PPWD, low- carbon materials such as renewables / bio-based content should be equally treated.

…fiscal measures or in the PPWD, low- carbon materials such as renewables / bio-based content should be equally treated. * “Beverage cartons are recycled at scale across the EU, however, so based upon this consideration they should be categorised as recyclable packaging” – page 142 of the report “Effectiveness of the Essential Requirements for Packaging and Packaging Waste and Proposals for Reinforcement - Final Report and Appendices“ led by Eunomia, February 2020 Page 3 of 3 o Availability of Secondary Raw Materials at competitive prices and of appropriate quality (as established by ‘end-of-waste’ criteria) ensuring consumer and product safety. • Introducing minimum mandatory green procurement criteria and targets could help provided that it is consistent with the above.

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ACE Position Paper - PPWR Brussels, 23 Feb 2023 www.beveragecarton.eu 1 ACE Position Paper: Proposal on Packaging and Packaging Waste Regulation Introduction ACE supports the European Commission’s (EC) vision that by 2030 all packaging should be recyclable and/or reusable. ACE is committed to continue its sustainability journey as demonstrated by the sector’s 2030 Roadmap (www.beveragecarton.eu). Beverage cartons are a sustainable and essential packaging solution allowing the safe transport, storage and use of sensitive products such as milk/dairy, plant-based products, juice and food (respectively beverage cartons pack ca. 75% of milk1 and 59%2 of juice in Europe). Their composition and light-weighted structure allow for easy transport and long shelf life. Beverage cartons are recycled at scale in Europe in around 20 specialised recycling plants in Europe at a rate of over 50%.

…cartons are recycled at scale in Europe in around 20 specialised recycling plants in Europe at a rate of over 50%. Our industry has invested over 200 million euros and plans to invest some additional 120-150 million euros in Europe to support the recycling of all components of beverage cartons.3 Beverage cartons have the lowest carbon footprint in their category of milk and juice as demonstrated by several LCA studies, which included NGOs.4 This is thanks to their light-weight structure of the packaging, their renewability of the main raw materials, their use of renewable energy (95% on average) and their transport and packaging efficiency (about 30% more milk can be packed in a truck using beverage cartons compared to bottles).

…and packaging efficiency (about 30% more milk can be packed in a truck using beverage cartons compared to bottles). The beverage carton industry acknowledges the need to revise the rules on packaging and packaging waste management to align them with the overall objective of the EU Green Deal. We believe that the current PPWR draft contains positive developments, but that additional consideration is needed for some elements. In particular, we believe that critical aspects such as consumers’ health, economic and environmental benefits, roles and responsibilities of the economic operators (e.g., suppliers and manufacturers) and technical feasibility of the measures proposed need to be further examined. The Impact Assessment does not provide robust evidence-based facts for some of these aspects. 1.

…be further examined. The Impact Assessment does not provide robust evidence-based facts for some of these aspects. 1. Enabling conditions for packaging to be recycled at scale – Need for a mandatory collection target. 1 Roland Berger: Impact assessment study of an EU-wide collection for recycling target of beverage cartons (2022) 2 2018 Liquid Fruit Market Report 3 Roland Berger: Impact assessment study of an EU-wide collection for recycling target of beverage cartons (2022) 4 Supporting evidence – Environmental performance of beverage cartons, Circular Analytics, https://www.beveragecarton.eu/news-and-resource-centre/publications/).

…of beverage cartons, Circular Analytics, https://www.beveragecarton.eu/news-and-resource-centre/publications/). ZeroWaste Europe https://zerowasteeurope.eu/wp-content/uploads/2020/12/zwe_reloop_report_reusable- vs-single-use-packaging-a-review-of-environmental- impact_en.pdf.pdf_v2.pdf?utm_source=POLITICO.EU&utm_campaign=edf8c1d17b- EMAIL_CAMPAIGN_2022_10_24_02_44&utm_medium=email&utm_term=0_10959edeb5-edf8c1d17b- 190996081 Ref. Ares(2023)2811353 - 20/04/2023 POSITION PAPER – February 2023 www.beveragecarton.eu 2 Industry needs enabling conditions to ensure beverage cartons are recycled at scale by 2035. The first step to recycling is collection. It would be unjustified to ban packaging if not recycled at scale in 2035 while collection is collective responsibility and a multi-actor effort.

…ban packaging if not recycled at scale in 2035 while collection is collective responsibility and a multi-actor effort. A mandatory collection target for all packaging - including beverage cartons - by 2030 is a critical pre-condition to allow efficient and effective collection, sorting and recycling in Europe. Where such a target exists (e.g. Belgium) beverage carton recycling is at high rates. In the case of beverage cartons, such a target would allow a significant increase in the recycling of beverage cartons that would provide many benefits including5: o Significant savings of GHG emissions contributing to the EU climate neutral ambitions (ca 190 k tons to 340 k tons reduction per year). o A contribution to the overall paper recycling rate and to Member States targets, contributing to the EU circularity objectives and goals.

…the overall paper recycling rate and to Member States targets, contributing to the EU circularity objectives and goals. o A level playing field for all packaging (beverage cartons are discriminated against vis a vis their main competitor (PET) that have a collection target set up in the SUPD). o Increased traceability of recycling of beverage cartons. o A harmonised collection target across the EU. The current situation is quite fragmented – some Member States have a collection target for beverage cartons, while others support an EU-approach to a collection target for used beverage cartons. o An incentive to increase investments in sorting and recycling –predictability of volumes collected would be beneficial and complementary to our industry’s continuous investments on recycling.

…of volumes collected would be beneficial and complementary to our industry’s continuous investments on recycling. o Administrative costs for Member States would be negligible as the responsibility for reporting and aggregating data is with Producers Responsibility Organisations. DRS is a valuable system in countries where the existing selective collection schemes are unable to deliver high collection rates. However, DRS should focus on inclusion of all packaging formats regardless of the content they contain. ACE calls for: • a 90% mandatory collection target for all packaging by 2030 as part of the upcoming Packaging and Packaging Waste Regulation. 2.

…collection target for all packaging by 2030 as part of the upcoming Packaging and Packaging Waste Regulation. 2. Exemption from reuse targets for microbiological sensitive products Juice is a microbiological sensitive product6 that provides consumers with essential vitamins and nutrients and is consumed daily by millions of EU citizens as part of a healthy lifestyle. Fruit juices and nectars, like milk products, are made with raw materials of agricultural origin. This makes them easily fermentable, perishable and sensitive to light and oxygen7. Their microbiological nature makes them more sensitive when compared to soft drinks or water, and packaging performs the crucial role of providing an effective barrier against entry of microorganisms and oxygen, light and loss of aromas.

…crucial role of providing an effective barrier against entry of microorganisms and oxygen, light and loss of aromas. The ‘Council Directive 2001/112/EC 5 Roland Berger study, 2022 - https://www.squareandcircular.eu/ 6 Definition of fruit juice - The fermentable but unfermented product obtained from the edible part of fruit which is sound and ripe, fresh or preserved by chilling or freezing of one or more kinds mixed together having the characteristic colour, flavour and taste typical of the juice of the fruit from which it comes. Annex 1 - Directive 2001/112/EC - https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX%3A02001L0112-20141005 7 “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. POSITION PAPER – February 2023 www.beveragecarton.eu 3 relating to fruit juices and certain similar products intended for human consumption’ does not allow to use of preservatives in juice8. Using non-sterile packaging would result in fruit juices and milk spoiling in a very short time, which would create consumer food safety issues and food waste9. To protect the microbiological sensitiveness of its products, the fruit juice industry largely uses packaging which best protects, transports and preserves its products, especially at ambient temperatures and to ensure a longer shelf life. The only reusable packaging, technically feasible for fruit juices, is glass. All others are unable to protect the product from spoilage.

…technically feasible for fruit juices, is glass. All others are unable to protect the product from spoilage. If mandatory reuse requirements and targets are set for the fruit juice industry, the only alternative will be to use heavy returnable glass bottles. Reusable glass does not offer the same environmental and sustainability attributes and benefits as beverage cartons. The EC Impact Assessment accompanying the PPWR proposal calculates that switching from heavy packaging such as glass towards lighter alternatives would lead to a significant reduction in GHG emissions and water use10. ACE calls for: • microbiological sensitive beverage, such us juice, not to be in the scope of mandatory reuse. Where the infrastructure is in place and the necessary sanitation systems are available some reusable options can emerge as complementary to single use packaging formats. 3.

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POSITION PAPER Brussels, 6 January 2020 www.beveragecarton.eu 1 ACE position paper on the review of the EU requirements for packaging and other measures to prevent packaging waste The packaging sector can and should contribute to achieving the climate neutrality objectives of the European Green Deal by minimising the climate impact of packaging materials, while reducing waste and improving the circularity of packaging solutions. A future-proof Packaging and Packaging Waste Directive (PPWD) should take an outcome-based approach to revising Essential Requirements for packaging, and should mandate that by 2030 all packaging is low-carbon, recyclable or reusable, and that raw materials are responsibly sourced. An outcome-based approach to packaging would avoid potential trade-offs between reusable packaging and their environmental impacts.

…approach to packaging would avoid potential trade-offs between reusable packaging and their environmental impacts. This approach should be underpinned by clear targets, criteria and definitions, thus ensuring a well-functioning EU Internal Market and driving investments in innovative materials and recycling technologies without imposing further restrictions. The revised PPWD should be based on a set of principles and objectives which achieve the following: • Ensure the integrity of the EU Internal Market through clear requirements and harmonised EU legislation that fosters innovation; • Set targets to increase the collection and recycling of packaging, such as beverage cartons, and reduce the generation of residual waste that is not reused or recycled, and therefore landfilled or incinerated.

…reduce the generation of residual waste that is not reused or recycled, and therefore landfilled or incinerated. • Incentivise packaging which is sustainable and indispensable for a resilient European food supply system. • Ensure harmonised implementation by providing clear definitions for the concepts and criteria referred to in the revised legislative text; • Support the EU’s transition towards a strategic autonomy, which reduces dependency on imported materials. • Create a level-playing field through a technology and material-neutral, non-discriminatory approach, in particular for innovative solutions. • Set a stable regulatory framework for industry to invest in sustainable and innovative packaging, which might otherwise be hampered through restrictions on specific packaging materials or formats. Packaging is designed to fulfil specific purposes and functions.

…on specific packaging materials or formats. Packaging is designed to fulfil specific purposes and functions. The revised Essential Requirements must strike the right balance between the functionality of packaging and the objectives of the PPWD to minimise the environmental impact of packaging. They must therefore: Provide a clear and enforceable definition of recyclable packaging, which will eliminate residual waste and allow the achievement of the PPWD’s objectives while safeguarding health of consumers and reducing food waste.

…and allow the achievement of the PPWD’s objectives while safeguarding health of consumers and reducing food waste. Recyclable packaging is that which can be effectively and efficiently separated from the waste stream, collected, sorted and aggregated into defined streams for recycling processes, and recycled at scale through such that it is turned into a secondary raw material, and of a sufficient quality that it can find end markets to replace the use of primary raw material.1 Such a definition would also ensure that recyclable packaging is material and technology-neutral. However, sorting, collection and recycling technologies must be in place for packaging to be recyclable. 1 “Effectiveness of the Essential Requirements for Packaging and Packaging Waste and Proposals for Reinforcement”, Final Report and Appendices, p.

Requirements for Packaging and Packaging Waste and Proposals for Reinforcement”, Final Report and Appendices, p. 131, available at https://op.europa.eu/en/publication-detail/-/publication/05a3dace-8378-11ea-bf12- 01aa75ed71a1. Ref. Ares(2021)145440 - 07/01/2021 POSITION PAPER - January 2021 www.beveragecarton.eu 2 Ensure that packaging design requirements minimise the impact on climate and reduce the carbon footprint of packaging from sourcing to the end-of-life. The revised PPWD should mandate that packaging marketed in Europe after 2030 complies with strict standards on carbon footprint, recyclability and ethical sourcing of raw materials2.

…after 2030 complies with strict standards on carbon footprint, recyclability and ethical sourcing of raw materials2. Using materials with the lowest carbon impact3 or recycled materials helps to substitute fossil- based high-carbon resources and are key to reaching the EU’s climate neutrality goals.4 Incentivise the use of more recycled content in packaging where secondary raw material markets are not yet mature, while safeguarding the quality of materials in contact with food and beverages. Food safety is the highest priority for our industry, therefore all materials used in packaging (be it primary or recycled) need to be fully assessed for their suitability for food contact applications. Recycled content targets should be ambitious but feasible, while remaining open to technological developments in terms of materials and recycling.

…be ambitious but feasible, while remaining open to technological developments in terms of materials and recycling. The market for recycled plastics is very limited today. Mechanical recycling technologies are not available for all types of polymers – particularly those used to protect perishable foods. Currently, there are no existing EFSA approvals on the suitability of recycled content of LDPE / HDPE for food contact materials. Any requirements on recycled content in packaging should result in positive environmental impacts, avoid disturbing well-functioning recycling loops5 and allow for packaging to be further recycled. Take into account all scientific, environmental, health and economic impacts of reusable packaging throughout its life cycle before mandating it through regulation.

…health and economic impacts of reusable packaging throughout its life cycle before mandating it through regulation. As single-use packaging includes packaging formats made from different materials with different environmental assets or littering potential,6 it should not be regulated as one category. When considering reuse systems of packaging, the revised PPWD should take into account the environmental impact of packaging across its entire lifecycle, not only at end-of-life. This includes the sourcing of raw materials, manufacturing and use phases, as well as carbon footprint and recycling rates, in order to avoid unintended consequences and a higher environmental impact overall. Single-use packaging that is recyclable, recycled at scale and made from responsibly-sourced low-carbon materials scores better or equal in terms of climate impact than other reusable packaging systems.

…materials scores better or equal in terms of climate impact than other reusable packaging systems. This is the case for beverage cartons7, whose global warming potential, on 2 Similarly to the approach taken by the European Commission in its proposal for a Regulation concerning batteries and waste batteries, COM(2020) 798 final, available at https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12399- Modernising-the-EU-s-batteries-legislation. 3 Such as sustainably-sourced renewable materials that can be also recycled. 4 Sustainable packaging - The Role of Materials Substitution, Material Economics, available at https://materialeconomics.com/publications/sustainable-packaging. 5 The recycling stream for paper and board packaging is well-functioning today, with a 82.9% recycling rate in 2018, according to Eurostat.

…for paper and board packaging is well-functioning today, with a 82.9% recycling rate in 2018, according to Eurostat. In 2019, across the EU28, 51% of the paperboard used in beverage cartons was recycled, according to average EU figures and in line with current EU recycling rate calculation rules. 6 European Commission Staff Working Document Reducing Marine Litter: action on single use plastics and fishing gear, available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52018SC0254. 7 “Reusable v single-use packaging – A review of environmental impacts”, Zero Waste Europe & Reloop, p. 40, available at https://zerowasteeurope.eu/library/reusable-vs-single-use-packaging-a-review-of-environmental-impact/. POSITION PAPER - January 2021 www.beveragecarton.eu 3 average, yield significantly better results than PET bottles and single-use glass bottles8.

…yield significantly better results than PET bottles and single-use glass bottles8. Beverage cartons have a significantly greater packaging efficiency than single-use and reusable glass bottles. A truck can be loaded with 25% to 41% more milk using beverage cartons compared to glass bottles. Even if the entire European Union achieves a 90% collection rate for PET bottles by 2030, plastic consumption would still be higher than with beverage cartons.9 Beverage cartons have a low littering potential, contribute to Green Deal ambitions and should be incentivised. Restrictions on the use of specific packaging materials or formats deter innovation and risk being counterproductive. Single-use packaging for food and beverages has clear hygienic advantages when it comes to food and consumer safety and is essential for the overall resilience and sustainability of the food system.

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