Health Care Without Harm Europe

HCWH Europe www.noharm-europe.org Page 1 of 3 Consultation response | Packaging and Packaging Waste Regulation Health Care Without Harm (HCWH) Europe welcomes the European Commission's proposed Packaging and Packaging Waste Regulation (PPWR). We cannot afford more delays and need strong and binding legislation on packaging and packaging waste that prioritises prevention and reuse. The targets must be ambitious and the legislation must be enacted without delay during the current parliamentary term. It is crucial that the PPWR addresses packaging waste in the healthcare sector. Nationally, healthcare waste represents approximately 4% of total generated waste and plastic waste audits indicate that nearly half of municipal waste from healthcare is disposable packaging.

…waste and plastic waste audits indicate that nearly half of municipal waste from healthcare is disposable packaging. Considering the scale of packaging waste in the sector , the PPWR must set specific targets for preventing, reusing, and recycling healthcare packaging waste while implementing measures to improve waste management. HCWH Europe is a network of thousands of hospitals, healthcare leaders, and healthcare professionals. We have conducted plastic waste audits in hospitals across Europe and found that nearly half of plastic waste lacks labelling information on the material or plastic type (page 20). This makes recycling difficult or even impossible. Our members are concerned about the amount of packaging, overpackaging, unnecessary packaging, and overuse of plastic in healthcare. Waste represents a large financial and environmental cost for hospitals.

…and overuse of plastic in healthcare. Waste represents a large financial and environmental cost for hospitals. Reducing packaging waste while preserving the quality of the product is therefore very important - not just for the healthcare sector, because this would also enhance public well-being by reducing the associated negative health and environmental impacts. Considering the significant amount of waste generated by the healthcare sector, it is crucial that the PPWR introduces measures to reduce packaging waste in healthcare, helping to achieve overall waste reduction in the EU. While the PPWR proposal is promising, it contains several loopholes and exemptions that could limit its effectiveness in protecting human health and the environment.

…several loopholes and exemptions that could limit its effectiveness in protecting human health and the environment. HCWH Europe is particularly concerned that the proposal does not adequately address the issue of harmful chemicals in packaging that pose a significant health risk. We ask the European Commission to implement the following five recommendations to ensure that the PPWR will make a real difference. Ref. Ares(2023)2872374 - 24/04/2023 HCWH Europe www.noharm-europe.org Page 2 of 3 Recommendations for an impactful PPWR Increase reduction targets for packaging waste Packaging waste reduction targets must be significantly more ambitious to achieve the necessary reductions in waste. HCWH Europe proposes a 15% waste prevention target per capita by 2030 instead of the proposed 5%, with sub-targets for different materials, e.g. plastic, paper, glass, metal packaging.

…2030 instead of the proposed 5%, with sub-targets for different materials, e.g. plastic, paper, glass, metal packaging. These prevention targets should apply to the healthcare sector, where significant reductions in unnecessary packaging can be achieved. Excessive packaging is used in the healthcare sector and beyond, and the current proposal limits the potential for preventing packaging waste. Some of our member hospitals have successfully reduced plastic packaging through collaboration and discussions with suppliers, but not all hospitals have the resources to support such sustainability initiatives. The PPWR must therefore ensure that no unnecessary packaging is used in the healthcare sector. Reducing unnecessary single-use items in the healthcare sector can also complement the reduction of unnecessary packaging.

…unnecessary single-use items in the healthcare sector can also complement the reduction of unnecessary packaging. Increase reuse targets and strengthen reuse systems The ‘Systems for re-use’ definition should include an incentive to return packaging, e.g. a deposit scheme. Reusable packaging will not deliver environmental savings without well-designed reuse systems. Incentives should ensure reusable packaging return rates exceed 90%. The reuse targets proposed in the PPWR, such as transport or beverages, must be significantly increased to achieve meaningful progress. Several Member States already have significant experience with reuse systems for beverages that can be scaled up, and these experiences should be taken into account when setting targets. In addition, reuse targets should be expanded to cover packaging in other sectors, e.g.

…account when setting targets. In addition, reuse targets should be expanded to cover packaging in other sectors, e.g. textiles (such as laundry services), non-perishable foods, cleaning products, personal hygiene products, and milk. The Yorkshire Ambulance Service NHS Trust (UK) replaced 8,000 plastic milk bottles per year with reusable glass bottles at no extra cost. Similarly, the Centre Hospitalier Angouleme (France) has reduced plastic in their maternity food services by purchasing food items in bulk. Other hospitals have reduced packaging in laundry services by replacing single-use plastic bags with reusable options. There is significant potential to reduce waste with reusable and refillable items such as sachets for personal hygiene products, which are used in large quantities in healthcare.

…and refillable items such as sachets for personal hygiene products, which are used in large quantities in healthcare. HCWH Europe www.noharm-europe.org Page 3 of 3 Eliminate hazardous chemicals in packaging to protect human health The current proposal does not effectively protect human health from harmful chemicals and fails to incentivise a phase out of hazardous substances in packaging. The PPWR must restrict substances of concern and very high concern in all packaging present on the EU market and align with REACH regulation. Moreover, it is concerning that the current proposal’s recyclability requirements do not allow for the restriction of substances in packaging based on chemical safety. HCWH Europe strongly advocates for adopting a preventive approach in the PPWR, especially considering the delayed Food Contact Material Regulation.

…for adopting a preventive approach in the PPWR, especially considering the delayed Food Contact Material Regulation. The protection of consumers' health should be ensured by implementing ambitious measures that restrict the use of substances of concern in packaging. The regulation must include strict requirements on chemicals, including mandatory reporting on chemical content and strong mechanisms for phasing out the most harmful substances, such as those proposed in the Chemicals Strategy for Sustainability (i.e chemicals that cause cancers, gene mutations, affect the reproductive or the endocrine system, or are persistent and bioaccumulative. This is essential as the proposed regulation emphasises reuse, recycling, and recycled content.

…and bioaccumulative. This is essential as the proposed regulation emphasises reuse, recycling, and recycled content. Include medical device packaging in recycled content and recyclability targets Packaging for medical devices should not be exempt from recycled content targets. If these requirements apply to contact-sensitive food contact material, the safety of recycled plastic materials used in other contact-sensitive applications shall be ensured by adequate legislation. Similarly, medical device packaging should not be exempt and should be recyclable. There are already recyclable options available for healthcare packaging on the market and healthcare facilities are increasingly demanding more sustainable options for healthcare packaging, such as the Nordic criteria for sustainable packaging for healthcare products.

…options for healthcare packaging, such as the Nordic criteria for sustainable packaging for healthcare products. Strengthen Extended Producer Responsibility The Extended Producer Responsibility requirements should incentivise more circular products and business models. Current public waste management costs are too high. Reducing waste and management costs can improve the allocations of public financial resources to the healthcare sector. The PPWR should include Extended Producer Responsibility schemes with fees that address unsustainable packaging designs and reward sustainable ones. Producers should fully pay for packaging recovery and treatment, which should be achieved through regulation rather than voluntary schemes. In addition, EPR schemes should dedicate a minimum of 10% of their budget to finance infrastructure for reuse systems.

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HCWH Europe Page 1 of 4 Consultation response | Reducing packaging waste Health Care Without Harm (HCWH) Europe welcomes the opportunity to provide feedback on packaging requirements and other measures to prevent packaging waste. In the context of the new Circular Economy Action Plan (CEAP), presented by the Commission on 11 March 2020, this initiative is a promising continuation, recognising key issues and remaining gaps to deliver a more circular economy. The new CEAP encourages both sector- and material-specific initiatives to go beyond material substitution and to incorporate measures to reduce excessive use of packaging alongside reinforcement of existing mandatory packaging requirements.

…measures to reduce excessive use of packaging alongside reinforcement of existing mandatory packaging requirements. There has not been enough focus, however, on the responsibility and ambition of the healthcare sector to contribute to safer and sustainable production and consumption patterns, despite the fact that 85% of healthcare waste is comparable to domestic waste. Healthcare waste audits show that addressing packaging used in the healthcare sector should be prioritised – an audit at the OLVG hospital in the Netherlands for example, has shown that approximately 50% of total plastic waste is disposable packaging. Similarly, plastic waste audits at Aarhus University Hospital in Denmark show that plastic packaging is 18% of the hospital’s municipal waste (by weight) and nearly half the volume of all municipal waste from their operational departments.

…waste (by weight) and nearly half the volume of all municipal waste from their operational departments. In both cases, nearly half of the plastic waste identified did not indicate the plastic type, making it difficult to introduce recycling schemes. Waste represents a large financial and environmental cost for hospitals; reducing packaging waste is of high relevance not only for the healthcare sector, but it would also bring benefits to the public, by making a better use of taxpayer money and reducing negative health and environmental impacts. Considering the large amount of waste generated by the healthcare sector across the EU, introducing measures to reduce packaging waste in healthcare is crucial to achieve overall reductions at an EU level.

…measures to reduce packaging waste in healthcare is crucial to achieve overall reductions at an EU level. We need a transformative agenda to rethink how we deliver products safely to consumers; incremental improvements to recycling rates, which remain the focus of policy makers and the packaging industry, will not deliver such a transformation. Product reuse and waste prevention, with a strong commitment to the waste hierarchy, must be a priority. Ref. Ares(2020)4092899 - 04/08/2020 HCWH Europe Page 2 of 4 HCWH Europe recommends: Encourage and facilitate recycling of all packaging waste from hospitals - the waste industry is often reluctant or unable to recycle hospital waste, despite its cleanliness and recyclability, because of restrictive or unclear regulatory guidelines.

…hospital waste, despite its cleanliness and recyclability, because of restrictive or unclear regulatory guidelines. The European Commission should address these issues when reviewing the requirements for packaging and packaging waste and implement measures for packaging waste reduction in dialogue with both suppliers and healthcare professionals. Waste prevention is key - as a member of a coalition of NGOs working on waste we have developed a short list of recommendations for EU waste prevention policies: 10 priorities to prevent waste. While the proposed investments in the recovery plan focus on investments in recycling, we strongly encourage the Commission to respect the waste hierarchy and prioritise reduction and reuse above recycling. A clear timeline to phase out landfill and incineration for packaging waste is also needed.

…and reuse above recycling. A clear timeline to phase out landfill and incineration for packaging waste is also needed. Leverage public procurement as an instrument to scale-up reuse, reduction, and recyclability. Introduce mandatory requirements for green public procurement, including requirements on packaging. Packaging should first and foremost only be used when strictly necessary with a particular focus on secondary packaging (i.e. dressing packs). The EC should also facilitate an increase in the use of safely reusable materials such as textiles, glass, or aluminium. The Landspítali Hospital in Iceland, for example, replaced the plastic packaging for their laundry with reusable textile alternatives, yielding initial cost savings of €37,600 and a 10-tonne reduction in plastic waste.

…with reusable textile alternatives, yielding initial cost savings of €37,600 and a 10-tonne reduction in plastic waste. There should also be support for introducing deposit return systems - the Barts Health NHS Trust in England uses plastic bottle collection machines that give money back for every empty plastic bottle deposited. They will further install machines at the Newham University and Whipps Cross Hospitals, where 2,000 HDPE bottles are used every month; it is projected that selling these bottles to recyclers will yield an additional £1.7 million in revenue. Include Extended Producer Responsibility schemes with fees to address unsustainable design of packaging and reward sustainable ones. Packaging recovery and treatment should be fully paid for by producers - achieved through regulation rather than voluntary schemes.

…and treatment should be fully paid for by producers - achieved through regulation rather than voluntary schemes. Set ambitious, legally binding measures, targets, and monitoring. There should be measurable milestones for reduction of packaging waste, reduction of overpackaging, and compulsory waste segregation (including the healthcare sector). HCWH Europe Page 3 of 4 Currently, most member states are unlikely to meet the deadline for adopting the new EU waste laws - separate waste collection at the EU level is falling short of the set targets. More stringent measures are needed and recycling will only be possible with appropriate waste segregation in place. Ensure that suitable waste management systems and key infrastructure are in place and improve waste treatment infrastructure to facilitate high quality recycling and composting.

…in place and improve waste treatment infrastructure to facilitate high quality recycling and composting. Ensure that packaging is designed with its circularity in mind - concrete measures are needed to phase-out hazardous chemicals in materials and products to achieve a toxic-free circular economy. Packaging complexity should be reduced and plastic packaging should be made from recyclable monopolymers. Plastic types must be clearly marked on packaging to enable correct waste segregation and any labels added should be compatible and recyclable together with the packaging. Support the development of the European secondary raw material market - introduce progressive criteria for the use of secondary raw materials whilst adopting more stringent standards on the presence of hazardous chemicals in the recycling process.

…raw materials whilst adopting more stringent standards on the presence of hazardous chemicals in the recycling process. We would also welcome economic instruments to tackle the problem of plastic packaging waste and call for more work to be done on developing more sustainable options. Careful consideration for the externalities from packaging waste, - aquatic and soil pollution, biodiversity loss, and toxicity, should be integrated into any calculation of costs and environmental impacts. Life Cycle Analyses and Product Environmental Footprint should be adapted to include these externalities. Protecting patients, staff and public from hazardous substances is a priority for the health sector.

Protecting patients, staff and public from hazardous substances is a priority for the health sector. Materials and items that come into contact with patient and staff food during the supply chain, such as containers for transporting food, machinery to process food, packaging materials, kitchenware and tableware are considered to have adverse effects on our health. Considering the vulnerability of patients and the utmost importance of them having healthy and non-toxic meals, HCWH Europe recommends: Ensure consistency between the reformed Food Contact Materials (FCMs) legislation and other policies related to food, products, and packaging to transition towards food production, distribution, and consumption systems that phase out chemicals, superfluous packaging, and waste. They should build on recent policy decisions and guidelines to move away from disposability and phase out waste (e.g.

They should build on recent policy decisions and guidelines to move away from disposability and phase out waste (e.g. SUP Directive, Circular Economy Action Plan, and the upcoming revisions of the essential requirements for packaging and development of a sustainable products legislation). HCWH Europe Page 4 of 4 Ambitiously reform the EU legislation on FCMs to achieve a high and uniform level of protection for human health and a toxic free circular economy across Europe, notably by ensuring that the EU reformed legislation: ● Regulates all (or most) types of FCMs across the EU, including paper and cardboard - often single-use and in complex multi-layered structures.

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