Companies & groups · CH
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Tetra Pak is a trademark belonging to the Tetra Pak Group. 1(2) Inception Impact Assessment Tetra Pak’s reply to the consultation on the review of the requirements for packaging and other measures to prevent packaging waste August 2020 Tetra Pak supports the EU Commission’s objectives for the revision of the Packaging and Packaging Waste Directive (PPWD) to ensure the internal market for packaging, compliance with recycling targets and the reduction of packaging waste. At the same time, we believe that the next revision of the Directive should ensure that it contributes to the Green Deal’s objectives of delivering a climate neutral circular economy that preserves natural resources, while ensuring resilient food systems.
…delivering a climate neutral circular economy that preserves natural resources, while ensuring resilient food systems. To do so, a future PPWD must deliver on the Green Deal’s overarching objective of achieving carbon neutrality by supporting and accelerating the decarbonization of the packaging sector. It has been estimated that emissions from materials used for packaging are already larger than those for global aviation and they have so far gone unaddressed.1 Thus, the transition of the sector towards the lowest possible climate impact should be an additional objective of the revision.
…transition of the sector towards the lowest possible climate impact should be an additional objective of the revision. To this end, we believe the future PPWD should provide an enabling policy framework with clear criteria for innovation in low carbon and circular packaging and we make the following recommendations for the EU Commission to consider as it develops its proposal: Decarbonisation of packaging sector: To meet the climate neutrality objective, we support a revision of the ‘essential requirements’ according to which all packaging placed on the market must be low carbon, and reusable or recyclable, by 2030. The upcoming Impact Assessment must ensure that any new policy measure is designed to contribute to the objective of reaching climate neutrality by 2050, while contributing to the EU’s environmental, social, and economic goals.
…of reaching climate neutrality by 2050, while contributing to the EU’s environmental, social, and economic goals. Restrictions on the use of specific packaging materials risk being counterproductive. A future sustainable and resilient food supply system needs a variety of packaging solutions, including single use, multi-material, and reusable packaging. What works under normal conditions might not work in a crisis, as the current pandemic has shown. Instead, the future PPWD should be outcomes-based: it should set clear goals and targets (e.g. on packaging recyclability and minimal climate impact in the Essential Requirements) but abstain from being overly prescriptive on the means to meet them. If a packaging format is both recyclable and low carbon, there should be no further requirements or restrictions.
…them. If a packaging format is both recyclable and low carbon, there should be no further requirements or restrictions. Commercial operators should be responsible to determine the most effective measures to 1 Materials Economics analysis; IEA – Energy Technology Perspectives 2017. https://iea.org/etp/ Ref. Ares(2020)4122429 - 05/08/2020 Tetra Pak is a trademark belonging to the Tetra Pak Group. 2(2) meet the given targets and report on progress made, which competent authorities should monitor closely. Targets on recycled content: Should mandatory recycling targets for food packaging be introduced in the future PPWD, regulators should treat low-carbon materials such as renewable and bio-based materials equally to recycled materials. Renewable and bio-based materials have the lowest carbon footprint, regenerate (and thus are circular by nature), and act as a powerful carbon sink.
…have the lowest carbon footprint, regenerate (and thus are circular by nature), and act as a powerful carbon sink. The reduction of waste generation is essential and should focus on residual non-recyclable waste. Bans on specific packaging fall short and do not address the key issue which is to reduce the amount of waste that is landfilled or incinerated. Tetra Pak also fully concurs with the more detailed replies provided by our associations, the Alliance for Beverage Cartons and the Environment (ACE) and the European Organisation for Packaging and the Environment (EUROPEN).