CEFIC - European Chemical Industry Council

FEEDBACK APRIL 2023 From waste to resource: Packaging and Packaging Waste Regulation The Packaging and Packaging Waste Regulation (PPWR) is an opportunity to make waste a resource in the EU’s circular economy. Ambitious recycled content targets in the PPWR will ensure that waste has value enabling the further scale-up of recycling in the EU. This benefits the environment, the economy and reduces the EU’s reliance on imports of virgin fossil raw materials to produce plastics. The average EU recycling rate for plastic packaging was just 38% in 2020 with the remaining being landfilled, incinerated or exported. To close the gap to full plastic packaging circularity, mechanical and chemical recycling are needed as complementary technologies to deliver recycled content supported by improvements in design, collection and sorting of packaging waste.

…to deliver recycled content supported by improvements in design, collection and sorting of packaging waste. Targets can kick-start the EU’s single market for secondary raw materials Recycled content targets can incentivise the uptake of recycled content, leveraging the power of Europe’s single market. Setting targets is an important driver for creating and scaling the market. To do this in the most effective and meaningful way, Cefic considers setting total recycled content targets per average of packaging format. Total recycled content can use numbers accumulated over a period of time (e.g. 12 months). The development of a circular economy for plastics requires more waste to be collected, sorted, and directed towards recycling regardless of waste origin.

…for plastics requires more waste to be collected, sorted, and directed towards recycling regardless of waste origin. Cefic supports that all waste types should account for recycled content, beyond post-consumer waste, to include also pre-consumer waste, and to incentivise investment in technologies that would bring more recycled feedstock to the economy. Chemical recycling is key to deliver recycled content for the circular economy To further increase plastic recycling, other and complementary recycling routes will be required to process plastics that are difficult to handle in mechanical recycling processes. Chemical recycling can thus fill a void in the plastics recycling loop, conserve valuable resources, and contribute to the creation of a low-carbon circular economy.

…plastics recycling loop, conserve valuable resources, and contribute to the creation of a low-carbon circular economy. Chemical recycling technologies allow the use of plastic waste as feedstock to produce new chemicals including plastics. Chemical recycling can upgrade the quality and produce secondary feedstock materials that are equivalent to virgin resources and compliant with REACH. Chemical recycling also has the potential to remove undesired additives and impurities allowing the use as recycled content in high-demanding applications such as food contact materials or medical applications. In addition, waste streams originating from e.g. automotive and electronics with large quantities of mixed and/or contaminated plastic waste can be converted into secondary raw materials for the chemical industry. Ref.

…mixed and/or contaminated plastic waste can be converted into secondary raw materials for the chemical industry. Ref. Ares(2023)2885263 - 24/04/2023 2 Mass balance is the key enabler, and so far, the missing link One of the main barriers to scale up chemical recycling technologies is uncertainty about the method for calculating the recycled content of plastics. The current PPWR proposal indicates that the calculation rules for recycled content will be set by an implementing act by 31 December 2026, as per Article 7 (7). This is too late to provide legal certainty for businesses currently investing in new recycling facilities or working on scaling up. The same goes for the economic providers to ensure compliance with the targets set in this legislation.

…scaling up. The same goes for the economic providers to ensure compliance with the targets set in this legislation. In the case of chemical recycling, mass balance is needed to allow for a smooth and rapid transition to leverage recycled feedstocks in existing infrastructure, together with the virgin fossil sourced feedstock. As the two different feedstocks cannot be physically separated once they are co-fed into the complex large- scale installations, the mass balance methodology is required to accurately calculate and verify the amount of recycled content allocated to products. Without rapid resolution of the issue, the EU’s chemical industry may not be able to deliver recycled content to meet the EU’s climate and circular economy targets in time. The chemical industry is investing in chemical recycling capabilities.

…climate and circular economy targets in time. The chemical industry is investing in chemical recycling capabilities. Major investments for commercial scale installations have already been announced, covering different chemical recycling technologies. It is important to be able to leverage existing infrastructure to allow co-feeding of the recycled feedstock, replacing part of the virgin fossil-sourced feedstock. This is also because it would not be feasible to build an entirely new stand-alone infrastructure for producing plastics solely from recycled waste since it would take years to construct new manufacturing plants with billions in costs and high climate footprint. Mass balance is one of the well-known and widely used “chain of custody” models, as defined in ISO standard 220951.

Mass balance is one of the well-known and widely used “chain of custody” models, as defined in ISO standard 220951. It is already successfully deployed in other sectors, such as fairtrade cacao and coffee with their own relevant characteristics based on the nature of the products. To provide further clarity about future calculation methods for recycled content methods, the legal text of the PPWR should include a reference to the internationally recognized standards which the EU will base its future method on. Design for recycling measures should be based on clear criteria and subject to regular update Cefic appreciates considerations of design for recycling, with a view to improving the quality of end-of-life product streams in function of recycling.

…of design for recycling, with a view to improving the quality of end-of-life product streams in function of recycling. As such, there should be deadlines (by 2026 the latest) to develop the delegated acts referred to in Article 6 (4), including the preferred design methods, to ensure sufficient time for the packaging industry to adopt the changes. In addition, these deadlines for the delegated acts should take into account the fact that the time of implementation of Design for Recycling measures will vary depending on materials and packaging types. It is important that the recyclability requirements remain technology-neutral. While not yet specified in the proposal, the assessment of recyclability should consider the materials that can be recycled through all recycling pathways, including chemical recycling technologies.

…consider the materials that can be recycled through all recycling pathways, including chemical recycling technologies. 1 Mass balance is defined by ISO standard 22095:2020 as a system in which “materials or products with a set of specified characteristics are mixed according to defined criteria with materials or products without that set of characteristics" 3 Measures in this regard should be based on clear criteria, to be developed together with relevant stakeholders. These can provide for a robust basis for independent and case-by-case assessment of different packaging elements. In addition, technology is evolving and progressing, which means that some materials that are difficult to recycle today could potentially pose no issue tomorrow. As such, Cefic recommends continuous adaptation to technological progress.

…could potentially pose no issue tomorrow. As such, Cefic recommends continuous adaptation to technological progress. Provisions determining that products or materials are not recyclable should be carefully analysed via dedicated impact assessments, which should consider the role of the packaging types and potential alternative packaging systems (in terms of e.g., food safety and food waste prevention) together with the relevant environmental impacts. In terms of the recyclability at scale requirement, we are concerned that a narrow framework would limit the development of innovative materials and recycling processes, such as chemical recycling. The definition of ‘recycled at scale’ (as per Article 3 (32)) includes a 75% EU coverage requirement, which is a very ambitious target to achieve for newer technologies that are in the process of being scaled up.

…which is a very ambitious target to achieve for newer technologies that are in the process of being scaled up. On chemical safety, regulatory coherence is key and duplication should be avoided Cefic welcomes the attention that the European Commission has put in avoiding double regulation when establishing the requirements for substances in packaging. We strongly believe that allowing the restriction of certain substances for safety reasons under the PPWR would interfere with REACH and thus, introduce legal uncertainty and affect proper implementation by industry and authorities.

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Considerations: Reducing packaging waste July 2020 Considerations Reducing packaging waste roadmap consultation Cefic, the European Chemical Industry Council, founded in 1972, is the voice of large, medium and small chemical companies across Europe, which provide 1.2 million jobs and account for about 17% of world chemicals production. Cefic is devoted to promoting a thriving chemical industry that is broadly recognised to: • provide sustainable solutions to meet the challenges for future generations, • provide safe and resource efficient solutions • foster prosperity, growth and investments in Europe, The chemical industry provides the wheels for a circular economy. Whether you look at paper, battery, or plastics recycling, the process for the production of these products and recycling of these products is using chemistry.

…recycling, the process for the production of these products and recycling of these products is using chemistry. Transitioning towards a circular economy can contribute to addressing our global resource challenge, reduce greenhouse gas emissions through better use and reuse of the materials that already exist in the economy, reduce environmental littering, create new meaningful jobs, and spur economic growth. Going more circular means contributing to meeting the Paris Agreement and the broader UN 2030 Sustainability Development Goals. The faster we can develop and deploy circular solutions and technologies, the faster we can make the EU economy fully circular. For example, chemical recycling, a set of technologies developed by the chemical industry, can be a game changer for plastic waste management and drive the creation of a “new plastics economy”.

…can be a game changer for plastic waste management and drive the creation of a “new plastics economy”. The next step is to create the right conditions for our industry to develop this and other promising solutions on European soil. This includes the creation of a European Single Market for Waste and progressive transition from a waste-oriented to a resource-oriented policy framework. In this respect we like to point at the Circular Plastics Alliance (CPA) – an industry voluntary initiative set in collaboration with the European Commission. CPA signatories work together to realise the full potential of recycled plastics in the circular economy and help the European market for recycled plastics grow steadily in the future, with policies and measures that include facilitating the free movement of plastic waste for recycling and recycled plastics in the EU.

…measures that include facilitating the free movement of plastic waste for recycling and recycled plastics in the EU. The CPA aims to bring at least 10 million tonnes of recycled plastics – in products and packaging – back to the market by 2025. This target directly links to Recycled Content in products, and one of the metrics to monitor progress in achieving the circular economy for plastics Recycled content is obtained from “following” mass flows of recycled plastics streams. A too prescriptive or specific definition or measurement method based on mass flows would unduly discriminate alternative approaches associated with new recycling techniques. For instance chemical recycling, a set of technologies converting plastic waste into secondary feedstock materials for the production of new products including plastics. Ref.

…plastic waste into secondary feedstock materials for the production of new products including plastics. Ref. Ares(2020)3917299 - 24/07/2020 2 As these new recycling technologies come to the market plastic mass-flow may not be sufficient to cover all recycling options. The ability to ‘follow’ recycled plastics streams may become difficult or even impossible. Cefic therefore would like to invite the European Commission and like to work with the Commission to develop and implement metrics compatible with the common understood principle of “what goes in goes out” and attributing recycled-plastics-feedstock to selected products using a chain of custody Mass-Balance Approach.

…out” and attributing recycled-plastics-feedstock to selected products using a chain of custody Mass-Balance Approach. We therefore call the European Commission to assess the impacts of the policy scenarios it will envisage and to continuously consult the chemical industry in the development of recycling metrics, specifically introducing recycled content targets for specific packaging formats and the contributions chemical recycling of plastic waste can make in this respect. We support a recycled content assessment made at EU level, which also considers the evolution of packaging design, recyclability, material innovation, collection, sorting, and recycling technologies. While contributing to this consultation we are very aware we are experiencing unprecedented times, with events none of us have lived through before.

…we are very aware we are experiencing unprecedented times, with events none of us have lived through before. Many governments and institutions around the world are taking major actions to address the Covid-19 crisis, and introducing large-scale policies which will have significant impacts for years to come. We will continue to support Europe’s Member State governments and institutions in their efforts to overcome the socio-economic impacts of the crisis. When investing in the future, industry, governments and institutions will have to ensure investments align with the policy targets of a climate neutral Europe by 2050. All this also means that the attractiveness of Europe as a re- investment destination, and re-shoring industry back to Europe, will depend more than ever on a favourable policy framework that manages ever-growing differences between the world’s regions.

…more than ever on a favourable policy framework that manages ever-growing differences between the world’s regions. We look to the European Commission to undertake the appropriate assessments and to include these wider considerations in the future framework that will be developed. “

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