Veolia Environnement

Veolia is the global leader in optimised resource management. With over 163 000 employees worldwide, the Group designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries. Through its three complementary business activities, Veolia acts and contributes to the transition towards a circular and low carbon economy by developing access to resources, preserving available resources, and replenishing them. According to the European Commission: “​the initiative aims to tackle the limited competitiveness of secondary materials from recycled packaging relative to virgin feedstock in view of its quality and availability and to address the increase in packaging waste generation​”. We welcome this new market-based, industrial approach to recycling.

…the increase in packaging waste generation​”. We welcome this new market-based, industrial approach to recycling. To waste management companies like Veolia, only resilient markets decoupled from the prices of virgin materials can ensure high levels of recycling over the medium/long run. This approach is already included in Annex IV of the revised Waste Framework Directive which lists several economic and regulatory incentives. 1# Moving towards high-quality recycling: phasing SVHCs out and working on recyclability across the value chain As a wide range of substances of concern has been used until recently, phasing them out should be the absolute priority to increase both the quality and quantity of recyclates. Still, dealing with these ‘legacy substances’ will remain a challenge for the recycling industry.

…of recyclates. Still, dealing with these ‘legacy substances’ will remain a challenge for the recycling industry. Should further recycling of some waste containing legacy substances be envisaged, decontamination et non-dilution should remain paramount and hazardous waste/substances should be treated as such. To avoid dilution, authorities should encourage separation of contaminated streams, which should be made much easier by recent improvements in traceability (SCIP database). Finally, upholding the principle of decontamination (already enshrined in the legislation) should be regarded as the most efficient way to move towards quality recycling. Indeed, the objective of decontamination is to make sure that substances of concern contained in waste or products are below regulatory thresholds and/or can be safely extracted and disposed of. 1 Ref.

…contained in waste or products are below regulatory thresholds and/or can be safely extracted and disposed of. 1 Ref. Ares(2020)4140663 - 06/08/2020 Veolia is identified in the EU Transparency register under n°72103751229-92. While the legislation should remain technology-neutral, the eco-design of packaging should focus primarily on widely available, environmentally sound and cost-efficient technologies (i.e. mechanical recycling for plastics). To that end, we think eco-design should focus on 3 key principles: ● Simplifying packaging: this means clearer labelling on products, as well as schemes to encourage recycling on the move, which will remove confusion and inconvenience and increase recycling rates.

…schemes to encourage recycling on the move, which will remove confusion and inconvenience and increase recycling rates. The following types of packaging can be difficult to recycle and their recyclability should be improved: ○ Multilayer packaging (preferred option: monolayer and mono-material packaging); ○ Flexible packaging; ○ Lightweight packaging; ○ Packaging with features such as labels, glue, staples. ● Standardising packaging: Adopting sustainable and consistent design (avoiding multi-polymer and/or multilayer packaging) will ensure that products can be recycled more easily. ● Increasing recycled content in packagin​g: Using recycled content in new products will increase the demand for recycled material, help to drive costs down in the process and ensure that enough materials are in the “loop” to create new ones.

…help to drive costs down in the process and ensure that enough materials are in the “loop” to create new ones. 2# Plastics: tackling plastic pollution and increasing recycling rates should remain a priority We are convinced that the key to solving the plastic challenge is to ensure that any discarded plastics can be recycled and have a second life; and for that to happen, waste must have a residual value that allows the creation of a circular economy. To drive the development of this circular plastic economy we believe that, when choosing plastics as a packaging material, the following conditions should be assessed : ● plastics must be manufactured using recycled plastic material which contributes to closing the loop on plastics, encourages the industry to collect more and ultimately reduces the amount that ends up in the environment.

…on plastics, encourages the industry to collect more and ultimately reduces the amount that ends up in the environment. This approach has been proven with other materials such as paper, cardboard, metals and glass; ● plastics must be properly ​designed to be recyclable​: for example, avoiding multilayers of different types of materials, or using one unique polymer to make the recycling process more cost-effective; ● plastics must be ​clearly labelled so that consumers can easily understand which bin to use so that they can be recycled Regarding mandatory recycled contents, the EU should go beyond plastic bottles (already covered by the 2019 Directive on Single-Use Plastics) and target packaging/applications with high potential for incorporation.

…by the 2019 Directive on Single-Use Plastics) and target packaging/applications with high potential for incorporation. Building on the current work of the Circular Plastic Alliance, mandatory recycled contents could be introduced in different pieces of waste/product legislation. Based on the amount of plastic put on the market (from virgin or recycled resin), it is possible to consider that the most consuming sectors are those with the greatest potential for incorporation and, in particular packaging (the most common resins are PE and PP (films, jars and trays) and PET (bottles)). 2 Veolia is identified in the EU Transparency register under n°72103751229-92.

…jars and trays) and PET (bottles)). 2 Veolia is identified in the EU Transparency register under n°72103751229-92. The following measures would help to increase the demand for recycled plastics for the packaging sector: ● food-grade plastics should only be used for packaging that is in direct contact with food; ● It would be useful to reduce or even eliminate certain constraints regarding the origin (recycled vs. virgin) of the supply (feedstock) of plastic for food-grade packaging. Finally, Veolia believes that customers willing to switch to bioplastics and/or biodegradable plastics should be aware that they do not necessarily contribute to the development of a circular economy nor do they necessarily represent a better environmental option. We welcome the proposal to set up a specific regulatory framework as proposed by the Commission in its Circular Economy Action Plan.

…proposal to set up a specific regulatory framework as proposed by the Commission in its Circular Economy Action Plan. 3# Paper and cardboard: Veolia calls for an ambitious European strategy It is crucial to optimise the incorporation rate for certain fibrous products or as a substitute for plastics. It is, therefore, useful to push incorporation requirements on all fibrous materials. The incorporation of recycled materials into cellulosic fibre-based products should be a priority, along with switching materials: for example using paper (kraft bags) or cardboard as a substitute for single-use plastic packaging (takeaway sales), insulation material for construction or chipboard for furnishing. *** 3

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