Detergents Europe

A.I.S.E.’s accompanying document to the European Commission Public Consultation to inform the review of the requirements for packaging and other measures to prevent packaging waste 18 December 2020 ..................................................................................................................................................... A.I.S.E. welcomes the work done by the European Commission via first the EU Plastic strategy and now the Green Deal to address the issue of pollution of the environment posed by plastic waste that is not properly disposed of. In this context, beyond developing its own overall strategy directly contributing to the EU and UN SDGs1, A.I.S.E. supports the revision of the existing requirements for packaging and the consideration of other measures to prevent unmanaged packaging waste.

…the existing requirements for packaging and the consideration of other measures to prevent unmanaged packaging waste. Concerning this matter, the Commission is exploring policy/regulatory action to ensure that by 2030 all plastics packaging placed on the market can be reused or recycled in a cost-effective manner. However, in 2019 A.I.S.E. launched an initiative on plastic packaging, and signatories commit to reach those goals already by 2025 – in addition to use a minimum of 20% volume of recycled plastic material in the packaging of all household products in the A.I.S.E. portfolio. After one year, the committed companies are almost halfway to reaching those ambitious goals2, and these kind of voluntary industry initiatives tackling plastics pollution should continue to be considered and leveraged by the Commission.

…industry initiatives tackling plastics pollution should continue to be considered and leveraged by the Commission. It is A.I.S.E.’s view and experience that in specific circumstances, industry association-led initiatives can reach policy objectives quicker than regulation. However, in case the European Commission is considering sector-specific targets for the use of recycled material in packaging, we invite the European Commission to consult with the industry first, in line with the Better Regulation principles. Note to our contribution via the questionnaire: We want to point out relating objective 2 ("To limit and/or reduce the packaging waste generated across the EU"), that our answer is strictly referring to the limitation and reduction of packaging waste and NOT to packaging placed on the market. Furthermore, A.I.S.E.

…the limitation and reduction of packaging waste and NOT to packaging placed on the market. Furthermore, A.I.S.E. believes that the revision should consider the following aspects: EU wide action and safeguard of EU Single Market As indicated in the questionnaire, A.I.S.E. calls for a revision that helps steering tangible progress, while stimulating innovation and competitiveness of the EU industry in a well-functioning Single Market, allowing free movement of packaging and packaged goods. National legislation with potentially distorting effects on the common EU framework needs a thorough assessment of its compatibility with the objectives of the Single Market. The Single Market is the legal basis of the Packaging and Packaging Waste Directive.

…objectives of the Single Market. The Single Market is the legal basis of the Packaging and Packaging Waste Directive. 1 https://www.aise.eu/our-activities/sustainable-cleaning-78.aspx 2 https://www.aise.eu/our-activities/sustainable-cleaning-78/circular-economy/packaging-2222/voluntary-industry-initiative.aspx Ref. Ares(2020)7796907 - 19/12/2020 www.aise.eu Approach to the revision A.I.S.E. calls for a set of measures that: • Considers the importance of the packaging’s function, which is key to avoid product leakage, to ensure safe use, to protect products during transport and to enable correct dosage and application, i.e. packaging is designed for a specific purpose with technical specifications and shall not be considered only as a waste after use. • Is based on sound science and on the consideration of impacts across the full life cycle of the packaging, e.g.

…use. • Is based on sound science and on the consideration of impacts across the full life cycle of the packaging, e.g. light-weight packaging allows considerable reduction of CO2 emissions during the transport phase but might not be considered as ‘recyclable’ in some countries. • Considers a strategic allocation of public funding to support those market players being negatively impacted by some of the proposed measures and to foster the innovation needed to improve the market conditions, e.g. by o implementing harmonised modulated EPR fees, and ensure that the upcoming European eco-modulation guidelines are commonly interpreted and understood by all member states; o investing in R&D to develop emerging recycling technologies, e.g.

…interpreted and understood by all member states; o investing in R&D to develop emerging recycling technologies, e.g. digital watermarking; o reducing subsidies for the use of virgin plastic materials and diverting them to the use of secondary raw materials; o a more strategic allocation of public funds to promote innovative technologies such as chemical recycling to create a broader sourcing base for secondary raw materials. • Is developed in a consistent and coherent way with all existing (and applicable) legislation and with the other measures being developed by the EU Commission, e.g. parts of the Green Deal such as the Circular Economy, Industrial Strategy, etc. Specific targets, measures, and policy objectives A.I.S.E.

…such as the Circular Economy, Industrial Strategy, etc. Specific targets, measures, and policy objectives A.I.S.E. welcomes the consideration of a requirement that all packaging should be reusable or recyclable and, above all, that the Commission aims to provide an enforceable definition of ‘recyclable packaging’ and minimum quality standards for recyclates. • A.I.S.E. calls the Commission to avoid including targets, especially at specific material or packaging formats. This would unfairly favour certain actors on the market over others and hinder investments in innovations to move towards new technologies and developing new recycling streams.

…others and hinder investments in innovations to move towards new technologies and developing new recycling streams. • Moreover, the setting of recycled content targets is not only highly dependent on materials used and their existing material flows but also on the products contained, as some products require material qualities which cannot yet be delivered by recycled plastics (i.e. requiring high stress-crack resistance). • Thus, there are limitations by currently available quantities and qualities of secondary raw materials as well as by the fact that manufacturers have different product portfolios. • Should the Commission decide that setting targets for recycled content is essential, then these should be set as ‘minimum content’ that is achievable across a sector.

…for recycled content is essential, then these should be set as ‘minimum content’ that is achievable across a sector. In this context, we want to refer the Circular Plastics Alliance (CPA), which is a voluntary industry commitment to actively contribute to delivering on the declaration of the alliance, i.e. 'take action to boost the EU market for recycled plastics up to 10 million tonnes by 2025'. The CPA covers the European plastics value chains with more than 240 signatories, incl. A.I.S.E. • Restriction on the use of some packaging materials to certain applications shall be avoided as this would hinder innovation and could be difficult to ensure that niche applications/B2B specific applications are covered adequately. www.aise.eu • We ask the Commission to not exclude or favour the use of a specific material solely based on its sourcing, e.g.

…ask the Commission to not exclude or favour the use of a specific material solely based on its sourcing, e.g. bio-based plastics, but to assess the full material life cycle and its circularity potential. • For reusable packaging and a possible inclusion of refill quotas, A.I.S.E. asks the Commission to consider a reuse of packaging not only in terms of the related costs or whether it is “logistically feasible”, but to evaluate all impacts along the supply chain using life cycle assessment studies, and to consider especially consumer protection through product safety and hygiene. • A.I.S.E. calls the Commission to consider country level taxes on single use packaging only if the respective money is used for the set-up and modernisation of the recycling infrastructure to boost the circularity of plastics in the respective country.

…and modernisation of the recycling infrastructure to boost the circularity of plastics in the respective country. Moreover, double taxation (on top of contributions for EPR schemes) must be avoided. • Stakeholders should be involved; all technical expertise already available shall be considered when developing a definition for ‘recyclable packaging’, following the example of the Circular Plastic Alliance3. • Legal and quality requirements for packaging must be fulfilled. Barriers that should be addressed A.I.S.E. believes that the limited competitiveness of secondary materials is one of the key areas of focus to progress on the overall objectives of this initiative. To do so, A.I.S.E. considers essential: • Sufficient material availability, meaning that high quality recycled plastics material must be available in sufficient quantities to all market players.

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A.I.S.E.’s input to the European Commission Public Consultation on a proposal to review the requirements for packaging and other measures to prevent packaging waste 29 July 2020 ..................................................................................................................................................... A.I.S.E. welcomes the work done by the European Commission via the EU Plastic strategy first and now via the Green Deal to address the issue of pollution of the environment posed by plastic waste that is not properly disposed of. In this context, beyond developing an overall strategy directly contributing to the EU and UN SDGs1, A.I.S.E. supports the revision of the existing requirements for packaging and the consideration of other measures to prevent unmanaged packaging waste. A.I.S.E. believes that that this revision should consider the following aspects.

…to prevent unmanaged packaging waste. A.I.S.E. believes that that this revision should consider the following aspects. EU wide action and safeguard of EU Single Market A.I.S.E. calls for a revision that helps steering tangible progress, while stimulating innovation and competitiveness of the EU industry in a well-functioning Single Market, allowing free movement of packaging and packaged goods. National legislation with potentially distorting effects on the common EU framework needs a thorough assessment of its compatibility with the objectives of the Single Market. Approach to the revision A.I.S.E. calls for a set of measures that: • Considers the importance of the packaging’s function, which is key to avoid product leakage, to ensure safe use, to protect products during transport and to enable correct dosage and application, i.e.

…leakage, to ensure safe use, to protect products during transport and to enable correct dosage and application, i.e. packaging is designed for a specific purpose with technical specifications and shall not be considered only as a waste after use. • Is based on sound science and on the consideration of impacts across the full life cycle of the packaging, e.g. Light-weight packaging allows considerable reduction of CO2 emissions during the transport phase but might not be considered as ‘recyclable’ in some countries. • Pursues the overall objective of a circular economy, which can only be achieved in a context of ‘technology neutrality’, i.e. different recycling (complementary) technologies have to be evaluated based on their circularity potential on a case by case basis depending on their actual behaviour in a specific recycling stream.

…their circularity potential on a case by case basis depending on their actual behaviour in a specific recycling stream. • Undertakes a robust impact assessment, including consultation of relevant stakeholders and taking also socio-economic benefits into account. • Considers a strategic allocation of public funding to support those market players being negatively impacted by some of the proposed measures and to foster the innovation needed to improve the market conditions, e.g. by o implementing harmonized modulated EPR fees based on the packaging’s recyclability; o investing in R&D to develop emerging recycling technologies. 1 https://www.aise.eu/our-activities/sustainable-cleaning-78.aspx Ref. Ares(2020)4127314 - 05/08/2020 www.aise.eu o reducing subsidies for the use of virgin plastic materials and divert them to the use of secondary raw materials.

…reducing subsidies for the use of virgin plastic materials and divert them to the use of secondary raw materials. • Is developed in a consistent and coherent way with all existing (and applicable) legislation and with the other measures being developed by the EU Commission, e.g. parts of the Green Deal such as Circular Economy, Industrial Strategy, etc. Specific targets, measures and policy objectives A.I.S.E. supports the overall main objectives of this legislative proposal. In particular, A.I.S.E. welcomes the consideration of a requirement that all packaging should be reusable or recyclable and, above all, that COM provides an enforceable definition of ‘recyclable packaging’ and minimum quality standards for recyclates. A.I.S.E. also calls COM to: • Avoid including targets, especially at specific material or packaging formats.

A.I.S.E. also calls COM to: • Avoid including targets, especially at specific material or packaging formats. This could unfairly favour certain actors on the market over others and hinder investments in innovations to move towards new technologies and developing new recycling streams. Should the Commission decide that setting targets for recycled content is essential, then these should be set as ‘minimum content’ that is achievable across a sector. • Avoid the restriction on the use of some packaging materials to certain applications as this would hinder innovation and could be difficult to ensure that niche applications/B2B specific applications are covered adequately. • Consider and leverage existing voluntary industry initiatives tackling plastics pollution, both for consumers and professional applications.

…existing voluntary industry initiatives tackling plastics pollution, both for consumers and professional applications. A.I.S.E.’s long history in the area of voluntary initiatives2 has shown that significant results can be achieved by a sector-tailored approach. In the case of A.I.S.E.’s initiative on plastic packaging, after one year the nine market leading companies supporting it are almost halfway to reaching its ambitious goals3. • Involve stakeholders and consider all technical expertise already available when developing a definition for ‘recyclable packaging’, following the example of the Circular Plastic Alliance4. • Pursue the general principle of considering the recyclability of packaging materials in the design phase wherever possible, while acknowledging that packaging is part of the functionality of a product.

…in the design phase wherever possible, while acknowledging that packaging is part of the functionality of a product. • Avoid excluding or favouring the use of a specific material solely based on its sourcing, e.g. bio-based plastics, but assesses the full material Life Cycle and its circularity potential. Barriers that should be addressed A.I.S.E. believes that the limited competitiveness of secondary materials is one of the key areas of focus to progress on the overall objectives of the legislative proposal. To do so, A.I.S.E. considers essential to have sufficient: • Material availability, meaning that high quality recycled plastics material has to be available in sufficient quantities to all market players. • Material quality, meaning that the consistency of quality is guaranteed by recycled plastics material producers to ensure performance up to the industry standards.

…of quality is guaranteed by recycled plastics material producers to ensure performance up to the industry standards. • Material sourcing, meaning that good quality recycled plastics material is available from credible sources of supply. 2 https://www.aise.eu/our-activities/sustainable-cleaning-78/charter-kpi-reporting.aspx 3 https://www.aise.eu/our-activities/sustainable-cleaning-78/circular-economy/packaging-2222/voluntary-industry-initiative.aspx 4 https://ec.europa.eu/docsroom/documents/42362 www.aise.eu • Harmonisation of the collection and recycling systems across member states to ensure availability and quality of secondary raw materials and that there are no limits on cross-border shipments. • Legislative coherence and elimination of regulatory barriers preventing the use of recyclates in packaging. A.I.S.E.

• Legislative coherence and elimination of regulatory barriers preventing the use of recyclates in packaging. A.I.S.E. notes that the effectiveness of any legislation will also be highly dependent on the cost of recycled plastics material compared to the one of virgin plastics material. This will be influenced by the fact that the essential market conditions listed above will come into place.

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