K-C · Companies & groups · US
Kimberly-Clark Europe Limited Registered Office: Walton Oaks, Dorking Road, Tadworth, Surrey, England, KT20 7NS Reg. No. 04060641 (England and Wales) Kimberly-Clark is a global leader in the development and production of Absorbent Hygiene Products (AHPs), including baby nappies, period products, adult diapers, and tissue paper for private and professional use. As a user of packaging for our products, we fully support the PPWR proposal’s goal to create a level playing field across the EU for packaging, whilst reducing overpackaging, increasing recycling rates and promoting re-use. Our recommendations for the new PPWR relate to three areas: 1. Enable organic recycling to drive forward decarbonisation and circularity While the proposal is ambitious on the recycling of fossil-based plastics, it lacks ambition regarding organic recycling.
…the proposal is ambitious on the recycling of fossil-based plastics, it lacks ambition regarding organic recycling. As such, it does not fully live up to the goals of the Waste Framework Directive (WFD), which rightly included organic recycling in the definition of recycling, i.e. “any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes, including the reprocessing of organic material” with the clear objective of reducing the landfilling or incineration of bio-based material and providing a means for it to be recycled. In order to meet the dual goals of decarbonisation and circularity, we cannot rely solely on the recycling of fossil-based plastics. We must also ensure the development of alternative materials based on renewable sources, for packaging but also for other uses.
…also ensure the development of alternative materials based on renewable sources, for packaging but also for other uses. As recognised in the new Policy Framework on bio-based, biodegradable and compostable plastics, there are now clear science-based criteria and conditions for such alternative materials to be compostable and/or organically recyclable. It is thus imperative that the new PPWR does not backslide from the provisions of organic recycling in the WFD, but rather includes organic recycling on an equal footing with chemical and mechanical recycling. 2. Define clearly both plastic and natural polymers The European Commission rightly uses the same definition of ‘plastic’ in its PPWR proposal, as was used in the Single Use Plastics Directive.
…rightly uses the same definition of ‘plastic’ in its PPWR proposal, as was used in the Single Use Plastics Directive. We support this as we think it is critical to use the same definition of plastic across all instruments of EU law (note: in the current discussion around REACH microplastics, a different definition is being contemplated and this should be corrected). The new PPWR should also provide a clear definition of natural polymers which have not been chemically modified, as no such definition exists in EU law and the controversial SUPD guidelines used to address this are not uniformly applied by all EU member states.
…in EU law and the controversial SUPD guidelines used to address this are not uniformly applied by all EU member states. A clear definition in line with scientific evidence is needed to distinguish between fossil-based plastics and materials that retain the benefits of plasticity, without having a negative impact on climate, environment and health in terms of CO2 emissions and the generation of microplastics. This clarity will help improve circularity, avoid contamination of recycling streams, and reduce dependency on fossil-based plastics by encouraging innovation of alternatives. These materials can be used for packaging but also for other purposes. Such a definition could read as follows: Ref.
These materials can be used for packaging but also for other purposes. Such a definition could read as follows: Ref. Ares(2023)2890509 - 24/04/2023 Page 2 2 “A natural polymer that has not been chemically modified is a polymer that: (1) is biobased, and (2) is created by using or replicating naturally occurring processes found in plants, animals, fungi, or bacteria, and (3) retains its basic chemical structure during any process to convert it, and (4) neither contains nor generates persistent synthetic polymer microparticles during biodegradation.” 3.
…it, and (4) neither contains nor generates persistent synthetic polymer microparticles during biodegradation.” 3. Enable the market development of innovative materials in packaging and other applications which can reduce dependency on fossil-based raw materials Kimberly-Clark’s goal is to replace fossil-based plastics in our single-use AHPs with innovative biopolymers, such as PHA or polysaccharides, which after use (when soiled with human waste) would be collected and sent to organic recycling in an industrial facility. These polymers are (1) renewable without competing with raw material used for food or feed, (2) does not generate microplastics at any stage of the lifecycle, (3) is fully biodegradable in soil and maritime environments, (4) is compostable, recyclable and hence circular, and (5) retains the benefits of plasticity without the plastic.
(4) is compostable, recyclable and hence circular, and (5) retains the benefits of plasticity without the plastic. The European Commission, in its November, 2022 Policy Framework for bio-based, biodegradable, and compostable plastics, supported this vision when mentioning AHPs as a potential non-packaging application for compostable plastics which merits attention. The main application of these innovative materials and others, however, is packaging and it is crucial to enable innovation in compostable packaging to contribute to increased recycling rates across the EU. The approach taken in the PPWR proposal will negatively impact the availability and affordability of innovative materials which if allowed to be organically recycled (including industrial composting) would increase circularity and reduce dependency on fossil-based sources, for the benefit of climate and circularity. would…