ASSUC- European Association of Sugar Traders

ASSUC aisbl ▪ Rue de Trèves 49-51, Box 14 ▪ B - 1040 Brussels Tel +32(0)2 231 06 38 ▪ Fax +32(0)27 326 766 ▪ [email protected] ▪ www.assuc.eu ETI register identification number: 73074372526-61 ASSUC is the voice of European sugar traders, representing over sixty sugar trading companies across Europe through its membership. ASSUC strongly calls on the European Commission to remove sugar from the list of products under point four Annex V, banning single-use portion packaging for consumption in HORECA. The Proposal for a revision of EU legislation on Packaging and Packaging Waste already presents alternative approaches for this product, which can allow the EU to meet its important packaging reduction targets in a manner that is not discriminatory, disproportionate, or burdensome.

…meet its important packaging reduction targets in a manner that is not discriminatory, disproportionate, or burdensome. Specifically, this position paper is calling for the Commission to reconsider its position on a ban of sugar sachets in HORECA establishments. We argue that: I. Sugars are not homogenous products; several types of sugars used in HORECA have different packaging needs in order to maintain quality, hygiene, and functionality. II. Sustainable packaging solutions for sugar are on the market, in the form of compostable sachets, which would contribute to the EU’s targets on reducing packaging and packaging waste. III. A ban on all packaging for sugar consumed on HORECA sites would be detrimental to important non- EU origins, many of these being developing countries with preferential access to the EU. IV.

…to important non- EU origins, many of these being developing countries with preferential access to the EU. IV. The Commission can support adherence to the regulation by establishing a clearer transition timeline, increased incentives for, and investment in, sustainable packaging, and stronger harmonisation and standardisation at Member State level on reuse, recycling, and composting. ASSUC welcomes this opportunity to provide public feedback on the Proposal for a revision of EU legislation on Packaging and Packaging Waste. ASSUC recognises the importance of having in place a robust, viable, and comprehensive approach to address packaging waste and overpackaging, whilst promoting recyclable, compostable, and reusable packaging, and product distribution solutions.

…overpackaging, whilst promoting recyclable, compostable, and reusable packaging, and product distribution solutions. The sugar sector is aligned with these objectives, and many of its products are already available in reusable distribution forms. Under the fourth point of Annex V to the Proposal for a Regulation on packaging and packaging waste, the European Commission proposes a prohibition of “Single use packaging for condiments, preserves, sauces, coffee creamer, sugar, and seasoning in HORECA sector.” ASSUC, whilst sympathetic to the positive intention of the European Commission to reduce waste from single- use / serve packaging forms in the HORECA sector, is highly concerned by the inclusion of sugar sachets in the list of products proposed to be banned.

…the HORECA sector, is highly concerned by the inclusion of sugar sachets in the list of products proposed to be banned. We strongly believe that where sugar is concerned, there are clear, irrefutable, and balanced arguments for a limited exemption mandating instead the use of compostable packaging for sugar sachets, wrappers, and sticks. ASSUC FEEDBACK ON PACKAGING AND PACKAGING WASTE REGULATION PROPOSAL April 2023 Ref. Ares(2023)2875908 - 24/04/2023 ASSUC aisbl ▪ Rue de Trèves 49-51, Box 14 ▪ B - 1040 Brussels Tel +32(0)2 231 06 38 ▪ Fax +32(0)27 326 766 ▪ [email protected] ▪ www.assuc.eu ETI register identification number: 73074372526-61 1. Sugars are not a homogenous product. White sugar, and several types of brown sugars present different challenges in terms of their use in common reusable sugar distribution systems.

…types of brown sugars present different challenges in terms of their use in common reusable sugar distribution systems. Different sugars have different moisture contents, affecting their ability to be poured, and the conditions under which they need to be stored in order to maintain their desired attributes and quality. Sugar as a product in general, is very sensitive to moisture and exposure to humidity, which can lead to clumping and spoilage, rendering it unusable. One common reusable (zero waste) distribution method for sugar is the sugar pourer that is available on service counters and tables. The obvious advantage of sugar pourers is that they are cost-effective, hygienic, minimise waste, and consumers are able to use them with ease, compared to large sugar click or lever dispensers, or sugar that sits in bowls or other containers, etc.

…with ease, compared to large sugar click or lever dispensers, or sugar that sits in bowls or other containers, etc. However, certain sugars, such as brown sugars, have a moisture content that makes them less amenable to use in distribution systems such as sugar pourers, which depend on a product being able to flow freely out of a nozzle. Subsequently, brown sugars have fewer hygienic, affordable, reusable distribution solutions on the market compared to white sugar. These qualities of brown sugars also distinguish them from other products that are also placed under point four of Annex 5, such as ketchup, mayonnaise, vinegar, or other condiments, preserves, sauces, coffee creamer, and seasoning (salt and pepper).

…ketchup, mayonnaise, vinegar, or other condiments, preserves, sauces, coffee creamer, and seasoning (salt and pepper). These products, despite differences in formulation, maintain a consistency that makes them amenable to distribution in a hygienic reusable system or method – either pump or squeeze bottles, or grinders. Any proposal on packaging and packaging waste should take into careful consideration the heterogeneity of sugars. It should avoid measures that will result in an unfair advantage of one product over another, and needlessly limit choice for consumers and HORECA establishments. 2. Sustainable packaging options are already on the market. Packaging waste is a severe problem, and the regulation proposes various solutions and approaches to address this. These include solutions that centre around recycling and compostability, as well as reuse.

…approaches to address this. These include solutions that centre around recycling and compostability, as well as reuse. Given the lack of a hygienic, cost-effective, and easy to use reuse solution for certain types of sugar, other options which are in line with the regulation’s aims should also be available to the HORECA sector. Notably, industrially compostable packaging (in the form of sachets, sticks, and sugar cube wraps) already exists on the market. This solution is in line with article 8 of the Proposal for a Regulation on packaging and packaging waste, which concerns compostable packaging that would apply to plastic stickers for fresh produce and for tea and coffee pods or bags.1 Mandating the use of compostable packaging for sugar (sachets, sticks, wraps) would address the question of sustainability, hygiene, waste, consumer choice, and cost for the HORECA sector.

…wraps) would address the question of sustainability, hygiene, waste, consumer choice, and cost for the HORECA sector. This is because the transition cost to the use of compostable packaging would be borne by manufactures, and waste management for the compostable sachets would be in line with what is already provided for products under the scope of Article 8 (singe serve tea and coffee pods or bags being products that are already widely used in the HORECA sector). 1 Tea or coffee bags necessary to contain a tea or coffee product and intended to be used and disposed of together with the product; and coffee or tea system single-serve unit necessary to contain a coffee or tea product and intended to be used and disposed of together with the product.

…unit necessary to contain a coffee or tea product and intended to be used and disposed of together with the product. ASSUC aisbl ▪ Rue de Trèves 49-51, Box 14 ▪ B - 1040 Brussels Tel +32(0)2 231 06 38 ▪ Fax +32(0)27 326 766 ▪ [email protected] ▪ www.assuc.eu ETI register identification number: 73074372526-61 Finally, as individual servings of sugar typically also coincide with individual servings of tea and coffee, the ability to streamline the packaging management and disposal of a compostable sugar sachet and a compostable coffee pod or tea bag is potentially more straightforward. 3. Banning sustainable single-use packaging would disadvantage brown sugar producers, origins, consumers, and the HORECA sector.

…sustainable single-use packaging would disadvantage brown sugar producers, origins, consumers, and the HORECA sector. As already established above, brown sugar is especially challenging to distribute in distribution systems that depend on the free flow of the product through a nozzle or holes, and its susceptibility to clumping also presents specific challenges in relation to other forms of distribution. A sustainable single-use packaging option, such as industrially compostable sachets, would ensure that consumers and HORECA establishments are able to continue providing both brown and white sugars. Many types of brown sugars on the market are of non-EU origin, including a significant amount from ACP/LDC2 countries, for whom the EU is an important destination for their speciality sugars.

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