Steel for Packaging Europe

April 2023 PACKAGING AND PACKAGING WASTE REGULATION (PPWR) proposal COM(2022)0677 position PAPER steel for packaging sector APEAL, representing the steel for packaging sector, fully supports Commission’s objective that all packaging on the EU market be reusable or recyclable in an economically viable way by 2030, as stipulated by the Green Deal and the Circular Economy Action Plan (CEAP) 2.0. Our sector welcomes the general approach taken by the Commission but believes that more is to be done to fully close the circular loop. Therefore, our sector has prepared a set of recommendations and amendments to improve the draft Packaging and Packaging Waste Regulation. Executive Summary

…set of recommendations and amendments to improve the draft Packaging and Packaging Waste Regulation. Executive Summary 1. Criteria for recyclable packaging: The current Commission proposal is a step in the right direction. However, to fully close the circular loop the steel for packaging sector recommends: a) Stricter qualitative criteria to label packaging as ‘recyclable’. b) The introduction of packaging recyclability performance classes or ‘grades’ for each packaging unit put on the market is timely and necessary. Non-recyclable packaging should be gradually phased out. Best performers should be rewarded via eco- modulation of EPR fees and by a higher recyclability performance grade. c) Packaging should be ‘recycled at scale’ by 2030 covering at least 90% of the Union’s population and applied in 2/3rd of the Member States

‘recycled at scale’ by 2030 covering at least 90% of the Union’s population and applied in 2/3rd of the Member States 2. Recycled content: The steel for packaging sector supports the current Commission proposal that recycled content targets should only apply to materials with a low demand and uptake of recyclates. 3. Prevention of packaging waste: Waste reduction targets should be set for each of the specific materials contained in packaging waste: plastic, wood, ferrous metals, aluminium and paper/cardboard. 4. Transport packaging: Steel pails, drums, canisters and kegs are sales packaging and not transport packaging. Consequently, they should not be subject to the re-use targets set for transport packaging.

…not transport packaging. Consequently, they should not be subject to the re-use targets set for transport packaging. 5. Legal instrument and legal base: APEAL supports the choice for a Regulation and a full ‘internal market legal base’ for the Packaging and Packaging Waste Regulation (article 114 TFEU). 6. Phase out landfilling of packaging waste: The steel for packaging sector believes that the review of the PPWR should be complemented by a review of the Landfill Directive 99/31/EC, aiming at accelerating the phase-out of landfill of packaging waste. Ref. Ares(2023)2884319 - 24/04/2023 2/6 1. Criteria for recyclable packaging (article 3, 6 and Table 2 Annex II): Packaging put on the market should be designed for recycling. Packaging plays an essential role in protecting and preserving resources such as food and reducing waste.

…recycling. Packaging plays an essential role in protecting and preserving resources such as food and reducing waste. But the value of this role can be obscured by the impact of poor recyclability and ineffective recycling. a) Article 6, paragraph 2 subparagraph 1 - point d: APEAL believes that Packaging shall be considered recyclable when it (a) it is designed for recycling, (b) it is effectively and efficiently separately collected c) it is sorted into defined waste streams without affecting the recyclability of other waste streams and (d) it can be recycled multiple times so that the resulting secondary raw materials retains its main material properties and is of sufficient quality to substitute the primary raw materials. Packaging materials should not be downcycled or recycled just once. They should have the ability to be recycled multiple times and stay in a permanent material loop.

…recycled just once. They should have the ability to be recycled multiple times and stay in a permanent material loop. Products that are produced from such materials and are properly collected and processed at their end of life, become the raw material for new and endless production loops.

…properly collected and processed at their end of life, become the raw material for new and endless production loops. This is in line with the European Parliament resolution of 10 February 2021 on the New Circular Economy Action Plan (2020/2077(INI)), paragraph 39: “…stresses the need to increase the availability and quality of recyclates, focusing on the ability of a material to retain its inherent properties after recycling, and its ability to replace primary raw materials in future applications; in this context underlines the need to stimulate both increased recyclability in product design and measures such as effective separate collection…” b) Article 3, point 32 and article 6, paragraph 2 subparagraph 1 - point d: the current PPWR proposal defines ‘recycled at scale’ as follows: “means that the packaging needs to be collected, sorted and recycled through installed state-of- the-art…

…state-of- the-art infrastructure and processes, covering at least 75 % of the Union’s population by 01.01.2035”. The Impact Assessment carried out by the Commission does not clarify what the rationale is behind the 75% threshold. This could mean that the objective is met if just the 8 largest Member States, in terms of population, ‘recycle at scale’. APEAL believes that the definition of ‘recycled at scale’ should be reviewed. In order to ensure that the Regulation is effectively implemented at EU-level, the threshold should be increased to 90% of the Union population and at least 2/3 of the Member States. Article 6 – paragraph 3: Moreover, our sector believes that all criteria listed in Article 6, paragraph 2 subparagraph 1 i.e. (a), (b), (c), (d) and (e) determining what is ‘recyclable packaging’ are to be met by 01.01.2030.

…subparagraph 1 i.e. (a), (b), (c), (d) and (e) determining what is ‘recyclable packaging’ are to be met by 01.01.2030. This is in line with the European Commission’s self- proclaimed ambition to ensure that all packaging placed on the EU market shall be reusable or recyclable in an economically viable way by 2030. If a packaging is not ‘recycled at scale’ by 2030 it should not be considered as ‘recyclable’. 3/6 c) Article 6 – paragraph 3 and Table 2 of Annex II: APEAL fully supports the introduction of a set of so-called ‘packaging recyclability performance grades’. To ensure a level-playing field, these performances grades should apply to all packaging types and materials put on the market. The introduction of a performance grading system is timely and indispensable to ensure the transition to a true EU circular economy.

…of a performance grading system is timely and indispensable to ensure the transition to a true EU circular economy. Depending on its recyclability, packaging should be awarded a grade ranging from A to E, whereby the A-grade is the best-performer and E the worst. When labelled as E, the packaging format would have to be phased out by 1 January

…the best-performer and E the worst. When labelled as E, the packaging format would have to be phased out by 1 January 2030. (*) in terms of weight of the unit of packaging APEAL suggests introducing an explanatory text for each of the performance grades comparable to what has been suggested in the PPWR Impact Assessment: - For grade A the packaging should be able to be recycled multiples times and is fully compatible with the design for recycling criteria. The generated secondary raw material is of comparable quality to feed a closed material loop scheme. - For grade B, the packaging may have some minor recyclability issues that slightly affect the quality of the generated secondary raw material. However, the majority of the generated secondary raw material from this packaging can still potentially feed a closed material loop. - For grades C, D and E the wording can be found in the…

…and have the lowest EPR-fees, whereas packaging under grade E should be penalised and have the highest EPR-fees. 2. Recycled content should apply to packaging with a low uptake of recyclates (article 7): Article 7: APEAL supports the current Commission proposal that recycled content targets should only apply to materials with a low demand and uptake of recyclates. Steel packaging put on the market is being collected, sorted and recycled, at a very high recycling rate, reaching 85,5% in 2020. It is used to substitute the use of primary raw material in a wide range of steel products, including, but not limited to, packaging. A ≥95% B ≥90% C ≥80% D ≥70% E <70% Packaging recyclability perfomance grade Score of compliance with Design for Recycling (DfR) criteria of a unit of packaging(*) 4/6 Disrupting a well-established and a well-functioning material-based circular loop by setting a…

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APEAL - The Association of European Producers of Steel for Packaging Avenue Ariane, 5 - BE-1200 Brussels - Belgium Tel: +32 (2) 537 91 51 - Fax: +32 (2) 535 72 00 Email: [email protected] 1/3 July 2020 Feedback on EC’s Inception Impact Assessment “Review of the requirements for packaging and other measures to prevent packaging waste” 1. CONTEXT The broad objective of the PPWD is preventing the negative impact of packaging on the environment and ensuring the functioning of the internal market. Both the European Green Deal (EGD) and the new Circular Economy Action Plan (CEAP) call for actions relating to waste prevention, driving design for re-use and recyclability of packaging, inter alia, by reducing the complexity of packaging.

…driving design for re-use and recyclability of packaging, inter alia, by reducing the complexity of packaging. In light of the assessment of options for reinforcing the Packaging and Packaging Waste Directive’s essential requirements (PPWD ER) and other measures to reduce the generation of packaging and packaging waste, a webinar (26.05.20) and workshops (28-29.05.20) on packaging waste prevention consulting stakeholders were organized by Eunomia and DG ENV. Furthermore, by August 6, stakeholders are welcomed to provide feedback on DG ENV’s Inception Impact Assessment document, plus from mid-August, a 12-week public consultation, in the form of a questionnaire on the EC website, will be organized.

…from mid-August, a 12-week public consultation, in the form of a questionnaire on the EC website, will be organized. APEAL, the Association of European Producers of Steel for Packaging, welcomes the opportunity granted to stakeholders to provide feedback on potential packaging waste prevention measures at EU and/or MS level. When defining and analysing potential packaging waste prevention measures, APEAL believes that one should also bear in mind, the wider scope of waste prevention in general. Packaging indeed has the great potential to among others safe product (incl. food) losses, ensure food safety, extend the shelf life of products and optimize distribution and storage. One cannot look at packaging in an isolated way, but one has to look at the couple packaging-product.

…and storage. One cannot look at packaging in an isolated way, but one has to look at the couple packaging-product. Moreover, packaging that can be recycled over and over again without loss of the intrinsic properties of the material, such as steel packaging, allows primary raw materials to be substituted by secondary raw materials, not only just once, but multiple times, resulting in decreasing carbon emissions and saving energy. Ref. Ares(2020)3915086 - 24/07/2020 APEAL - The Association of European Producers of Steel for Packaging Avenue Ariane, 5 - BE-1200 Brussels - Belgium Tel: +32 (2) 537 91 51 - Fax: +32 (2) 535 72 00 Email: [email protected] 2/3 2. FEEDBACK ON THE BACKGROUND PAPER “PACKAGING WASTE PREVENTION” (European Commission, DG Environment, May 2020) 2.1.

…2. FEEDBACK ON THE BACKGROUND PAPER “PACKAGING WASTE PREVENTION” (European Commission, DG Environment, May 2020) 2.1. Problem definition It is correct to state that overall, packaging waste generation increased almost continuously in the EU (see Eurostat data 1997-2017). However, when looking at the different packaging materials, one can determinate that the non-permanent packaging materials are at the basis of this increase and thus not the permanent materials, being glass and metals, including steel, whose capability is to be recycled over and over again without loss of the intrinsic properties of the material. The evolution of the packaging waste generation of the permanent materials, is not only the result of packaging lightweighting actions (e.g. steel can weight reduction), but also of the substitution of permanent materials by other materials.

…actions (e.g. steel can weight reduction), but also of the substitution of permanent materials by other materials. As stated in the background paper, part of these other materials is less easy to collect, to sort and/or to recycle or can’t even be recycled at all due to the complexity of the packaging. Furthermore, it needs to be recognized that whilst packaging waste generation continuously increased (as a result of among others demographic changes), the packaging waste part going to landfill and incineration decreased to the benefit of recycling, meaning that more and more of the packaging stays in the circular loop, substituting primary raw materials by secondary ones.

…that more and more of the packaging stays in the circular loop, substituting primary raw materials by secondary ones. Promoting optimized separate collection, both from household packaging waste streams and industrial commercial ones, that guarantee a high-quality input into the recycling operations, will lead to increased recycling rates, enabling to increase resource efficiency. Not only, reuse ensures that a material’s value is maintained, but also using permanent materials does so. 2.2. Waste prevention measures APEAL welcomes packaging waste prevention measures that take into account the wider scope of a circular and resource efficient economy, ensuring a net decrease in carbon emissions. One needs to look at design for high-quality recycling, guaranteeing high-quality input in the recycling operations.

One needs to look at design for high-quality recycling, guaranteeing high-quality input in the recycling operations. Furthermore, it is about the couple packaging-product, as packaging indeed has, among other advantageous functionalities, the potential to safe product (incl. food) waste. APEAL - The Association of European Producers of Steel for Packaging Avenue Ariane, 5 - BE-1200 Brussels - Belgium Tel: +32 (2) 537 91 51 - Fax: +32 (2) 535 72 00 Email: [email protected] 3/3 APEAL therefore supports: • Harmonisation of waste prevention strategies across MS; • Integration of waste management measures (e.g.

…supports: • Harmonisation of waste prevention strategies across MS; • Integration of waste management measures (e.g. gradually increased landfill taxes for household waste and PAYT-principle application contribute phasing out landfilling); • Harmonisation of separate collection scenarios across EU; • Optimised separate collection requirements, ensuring high-quality input into recycling operations; • Harmonisation of EPR systems and EPR eco fee modulation across EU; • Promotion of packaging and packaging material that can be recycled over and over again without loss of intrinsic properties of the material, ensuring high-quality input into recycling operations; • Promotion of high-quality and multiple recycling; • Promotion of well-functioning re-usable packaging schemes where it is ecological and economic feasible (e.g.

…of well-functioning re-usable packaging schemes where it is ecological and economic feasible (e.g. in B2B for drums, kegs and barrels); • Reduction of the complexity of packaging materials; • Reduction targets should focus on phasing out complex and non-recyclable packaging • Packaging design that takes into account EoL; • Better alignment of the essential requirements with the waste hierarchy; • Increased information sharing of best practice across Member States • Packaging waste evaluation that not only takes into account weight, but also the recyclability of the packaging APEAL furthermore believes that recycled content measures aren’t suitable for packaging materials for which the scrap demand already exceeds the available scrap as for these materials, such as for steel, there is already a well-established, well-functioning and mature recycling market, guaranteeing the material…

…a well-established, well-functioning and mature recycling market, guaranteeing the material stays in the circular loop. Even when already achieving a steel for packaging recycling rate of 82.6% across the EU (data 2018), further promoting optimized separate collection is also the way forward for steel packaging. Contact details • APEAL – Alexis Van Maercke, Secretary General and Steve Claus, Sustainability & Circular Economy Officer [email protected], +32 (0) 2 535 72 06; [email protected], +32 (0) 496 54 14 11

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