International Flavors & Fragrances

Packaging and Packaging Waste Regulation Proposal POSITION PAPER April 2023 IFF, an innovator in sustainable solutions in the food, beverage, health, biosciences and fragrances industries welcomes the publication of the proposal on PPWR and its ambition to make packaging more sustainable by reducing overpackaging, and increasing recycling rates and re-use. IFF calls on the Commission and Member States to also make sure that industries focused on material innovation which are developing sustainable solutions for the packaging sector are equally encouraged to innovate for the EU. We therefore wish to highlight the following key elements which will help enable a strong circular economy as a key lever for the net-zero transition. Open the recycled content target to biobased content We need all the solutions we have available to reduce our use of virgin fossil carbon.

…target to biobased content We need all the solutions we have available to reduce our use of virgin fossil carbon. Increasing recycled content in products is very important but won’t be enough. Bio-based materials offer the same opportunity to reduce our reliance on virgin fossil carbon and can contribute to the European Commission’s aspirational target of at least 20% sustainable, non-fossil carbon to be used in chemicals and plastics by 2030, as mentioned in the Communication on Sustainable Carbon Cycles. We therefore ask that within the PPWR, that the Commission incentivizes the use of different renewable carbon sources in addition to recycled materials.

PPWR, that the Commission incentivizes the use of different renewable carbon sources in addition to recycled materials. These materials can offer similar GHG reductions as recycled packaging and they offer flexibility for producers in implementing sustainable solutions, thus accelerating the EU’s green transition and decreasing dependency on fossil feedstocks in the packaging sector. We therefore call for biobased content to count as equivalent towards the recycled content targets set out in the PPWR proposal.

…call for biobased content to count as equivalent towards the recycled content targets set out in the PPWR proposal. Define clearly ‘plastic’ and ‘natural polymer’ The definition of plastic in the PPWR accurately references the SUPD and REACH definition – and should be kept as such: ‘plastic’ means a polymer within the meaning of Article 3(5) of Regulation (EC) No 1907/2006, to which additives or other substances may have been added, and which is capable of functioning as a main structural component of packaging, with the exception of natural polymers that have not been chemically modified. We equally need a clear definition for natural polymer since no such definition exists in EU law, and the controversial Single Use Plastics Directive (SUPD) Guidelines used to address this are not uniformly applied by all EU member states.

Single Use Plastics Directive (SUPD) Guidelines used to address this are not uniformly applied by all EU member states. Using the problematic and restrictive definition for natural polymers from the SUPD will discourage further innovation, development and investment towards scaling of this type of polymer for the EU. And this jeopardizes the goal of having in the near future, viable, industrial-scale alternatives to fossil-based plastics for the EU. These innovative natural polymers are biobased and derived from renewable sources, do not generate persistent microplastics at any point in their lifecycle, can be recycled or composted/biodegraded, i.e. they are fully circular.

…microplastics at any point in their lifecycle, can be recycled or composted/biodegraded, i.e. they are fully circular. These materials thus retain the benefits of many plastics in terms of material properties for use in packaging applications, without releasing additional CO2 to the atmosphere or generating persistent microplastics when they decompose/biodegrade. As such, innovative biopolymers can therefore be used as alternative solutions to replace fossil-based plastics in packaging. Ref.

…biopolymers can therefore be used as alternative solutions to replace fossil-based plastics in packaging. Ref. Ares(2023)2892299 - 24/04/2023 Packaging and Packaging Waste Regulation Proposal POSITION PAPER April 2023 For this reason, we propose to introduce the following new definition for natural polymers into PPWR, which could provide the clarity that industry needs to innovate: “A natural polymer that has not been chemically modified is a polymer that: (1) is biobased, and (2) is created by using or replicating naturally occurring processes found in plants, animals, fungi, or bacteria, and (3) retains its basic chemical structure during any process to convert it, and (4) neither contains nor generates persistent synthetic polymer microparticles during biodegradation.” This will ensure the policy clarity and coherence needed by industry to avoid any risks of policies being…

…the policy clarity and coherence needed by industry to avoid any risks of policies being interpreted differently. IFF’s sustainable material solutions enable many industries to meet their sustainability goals without compromising the performance of the products and safety to the consumer and is proud to belong to the circular biobased industry which is a key enabler of the European Green Deal. While we are also concerned about the challenges around packaging and the impact on the environment and are committed to reducing it through our sustainable solutions, it is equally critical to encourage innovation in the packaging sector, which ultimately contributes to EU’s key policy objectives of the Circular Economy.

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