Companies & groups · FI
…1LCA study on takeaway - EPPA (eppa-eu.org) 2 Cepi, Press release. Available here: Press release: European Commission proposal on packaging and packaging waste could build a world class circularity model where reuse and recycling are complementary | www.cepi.org 1/2 Ahlstrom welcomes the European Commission’s ambitious proposal for a Regulation on Packaging and Packaging Waste. We wish to highlight further improvements to ensure all targets and measures are science based. Reuse and recyclability should be complementary alternatives to choose from to achieve the greatest environmental benefits The full life cycle impact of all packaging products should serve as the basis when choosing between reusable or recyclable packaging.
…impact of all packaging products should serve as the basis when choosing between reusable or recyclable packaging. The prohibition on single-use paper packaging for in-store use (article 22) and mandatory reusable targets in takeaway services (article 26) should only be implemented if based on scientific and material specific data regarding the environmental benefits, the logistics involved, hygiene aspects and the importance of high return and rotation rates, as well as low wastage. According to a recently published life cycle analysis study, recyclable, paper-based packaging used in the food delivery and takeaway sector offers significant environmental advantages over reusable systems across 12 ‘impact categories’ including climate change, freshwater consumption and resource depletion1.
…across 12 ‘impact categories’ including climate change, freshwater consumption and resource depletion1. As the industry continues to improve the environmental performance, this will bring further environmental impact savings of packaging in the future. If adopted, the reuse targets provided in the Commission proposal will disrupt the high-performing recycling infrastructure the paper and board industry have invested in and are committed to further improve. The paper and board industry has, together with the entire value chain, set a 90% voluntary recycling target by 20302. The targets should be aligned with the Waste Framework Directive article 4 (2), which allows to deviate from the waste hierarchy on the basis of proof of environmental benefits.
…article 4 (2), which allows to deviate from the waste hierarchy on the basis of proof of environmental benefits. Compostable solutions are a good alternative when dealing with food contamination Biobased materials are important to support Europe achieving its climate ambitions. Compostable packaging does not only concern compostable plastic, and other compostable packaging materials should be clearly reflected in the legislation. Composting plays a key role in reducing the waste to landfill stream (which eliminates the 3rd highest contributor of methane generation) and is equivalent to recycling in waste hierarchy.
(which eliminates the 3rd highest contributor of methane generation) and is equivalent to recycling in waste hierarchy. According to the Biodegradable Products Institute, commercial compost facilities that accept food scraps and certified compostable packaging in addition to garden trimmings, combined with municipal collection programs for businesses and households, are the solution to diverting more of these materials from landfills, in addition to removing complexity for consumers. Composting allows consumers to not contaminate the recycling stream with food contamination, whilst adding value to the compost stream. Creating a regulatory approach that allows for multiple end of life scenarios, like recyclable or compostable would be key to enabling a potentially faster pace of change in the market, and is supported by other packaging regulations, like that of CA SB54. Ref.
…faster pace of change in the market, and is supported by other packaging regulations, like that of CA SB54. Ref. Ares(2023)2825381 - 21/04/2023 3 Cepi, CITPA, ACE, FEFCO (2019). Paper-Based Packaging Recyclability Guidelines. Available here: https://www.cepi.org/wp-content/uploads/2020/10/Cepi_recyclability-guidelines.pdf 4 4evergreen. Circularity by Design Guidelines for Fibre-based packaging. Available here: https://4evergreenforum.eu/4evergreen-releases-expert-based-guidelines-for-how-to-produce-packaging- designed-for-recycling/ 2/2 Mandatory plastic recycled content targets should only apply to packaging predominantly composed of plastic Market capacity for high quality plastic recyclates should be balanced prior to recycled content targets applying to all packaging containing plastic.
…plastic recyclates should be balanced prior to recycled content targets applying to all packaging containing plastic. Mandatory recycled targets need to be well gauged, and their technical feasibility assessed with a view to determine viable thresholds and implementation timelines. Targets should be introduced incrementally as the market develops and should initially only apply to packaging predominantly composed of plastic, as they will be collected and recycled in the plastic fraction. The definition of plastic is formulated to include barriers used in fiber composite packaging. These barrier layers only comprise a small fraction of the whole packaging and help reduce the total amount of fossil based plastic materials used. Recycled targets for these barriers are not reconcilable with greater environmental benefit until the plastic recyclate market is developed and alternatives exist.
…reconcilable with greater environmental benefit until the plastic recyclate market is developed and alternatives exist. There is a risk that a scenario arises with lack the of necessary quantity and quality of sustainable recycled plastics to meet the proposed threshold. Consult industry in the work of delegated acts The paper and board industry has developed Paper-Based Packaging Recyclability Guidelines3 and Circularity by Design Guidelines4 to support the value chain in the design of paper and board packaging that is recyclable. Collecting and sorting paper as a separate waste stream is an essential prerequisite supporting this process. We ask policy makers to ensure stakeholders from the fiber-based, paper packaging industry, including recyclers, are consulted in a transparent and systemic manner in the drafting process of delegated acts, explicitly incorporated into legislation.
…a transparent and systemic manner in the drafting process of delegated acts, explicitly incorporated into legislation. It is critical to ensure the exchange of expertise allowing measures to be science based and fit for purpose, properly considering technology, equipment and innovation.