FoodDrinkEurope

Avenue des Nerviens 9-31 - 1040 Brussels - BELGIUM - Tel. +32 2 514 11 11 [email protected] - www.fooddrinkeurope.eu - ETI Register 75818824519-45 Copyright FoodDrinkEurope aisbl; photocopying or electronic copying is illegal FoodDrinkEurope accompanying text to the Open Public consultation on to inform the review of the requirements for packaging and other measures to prevent packaging waste Contents Questionnaire part 2 ............................................................................................................................... 3 Questionnaire part 3 - Notes on Objectives ........................................................................................... 3 Objective 2: To limit and/or reduce the packaging waste generated across the EU .........................

…3 Objective 2: To limit and/or reduce the packaging waste generated across the EU ......................... 3 Objective 3: To promote the use of reusable packaging whenever logistically feasible with a view to reduce packaging waste generation ............................................................................................... 4 Objective 7: Set criteria for the use of compostable packaging in order to restrict the types of packaging that can be designed for composting ................................................................................ 4 Objective 8: Increase the level of recycled content in packaging ....................................................... 5 Questionnaire part 3 - Notes on answers to Question 12.1 ..................................................................

…part 3 - Notes on answers to Question 12.1 .................................................................. 6 Question 12.1 – Policy option 2: Member State level packaging waste generation reduction targets or limits relative to population (e.g. maximum amount of kg per capita) apply ................................ 6 Question 12.1 – Policy option 6: Requirement on mandatory use reusable packaging for some transport packaging e.g. pallets. ......................................................................................................... 6 Question 12.1 – Policy option 14: Requirement on producers to reduce overpackaging by reporting to a central registry on the volume, weight and planar area ratios of packaging to product if, for either one of these three measures, the packaging exceeds a specific threshold ratio.

…of packaging to product if, for either one of these three measures, the packaging exceeds a specific threshold ratio. .................................................................................................................................................... 6 Questionnaire part 3 - Notes on answers to Question 12.2 .................................................................. 6 Policy option 3: The term ‘recyclable’ in the requirement above is defined by a design for recycling based approach implemented through a technical committee. ........................................................ 6 Policy option 4: The term ‘recyclable’ in the requirement above is defined by use of a recycling rate threshold (i.e.determine minimum threshold to be achieved for a packaging format to qualify as ‘recyclable’) – facilitated through utilisation of digital watermarking technologies.

…a packaging format to qualify as ‘recyclable’) – facilitated through utilisation of digital watermarking technologies. .................... 7 Policy option 6: In addition to the requirement to be reusable or recyclable, the packaging shall be designed not to exceed the minimum volume and weight necessary for its functionality under critical areas (limited to product protection, hygiene, safety. legally required information and recyclability functions). In addition to amending the wording of the Annex II, point 1, this measure would include amending Standard EN 13428 to refine/remove the critical areas that limit further reductions in the volume or weight of packaging. ............................................................................. 7 Ref.

…the volume or weight of packaging. ............................................................................. 7 Ref. Ares(2020)7875853 - 22/12/2020 2/9 Policy option 7: Requirement mandating the reduction in the use of polymers used in packaging in order to increase recycling rates. ....................................................................................................... 7 Policy option 10: Requirement mandating compostable packaging when this could facilitate the collection of organic waste (e.g. disposable coffee capsules). ........................................................... 8 Policy option 12-15: Requirement for all recyclable, non-recyclable, compostable, reusable packaging to be clearly labelled ..........................................................................................................

…labelled .......................................................................................................... 8 Questionnaire part 3 - Notes on answer to Question 15........................................................................ 8 Policy option 2: Tracer based sorting technologies ............................................................................ 8 Policy option 5: Reducing the number of polymers in use for packaging ..........................................

…8 Policy option 5: Reducing the number of polymers in use for packaging .......................................... 9 3/9 Questionnaire part 2 FoodDrinkEurope is not answering to Part 2 of the questionnaire as we believe these questions are repeated in part 2 or are too specifically addressed to consumer/citizens and we are not in a position to answer them Questionnaire part 3 - Notes on Objectives Over the last two decades, the food and drink industry has been making consistent efforts to reduce the environmental impacts of packaging and improve the environmental footprint of their products. Efforts have contributed to reduce the weight of packaging and the quantities of materials put into every packaging unit. In many cases such efforts are already very advanced, and provide little room for additional reduction of weight.

…unit. In many cases such efforts are already very advanced, and provide little room for additional reduction of weight. Our industry has naturally high self interest in decreasing the quantities of packaging as the volume and weight of packaging are determining factors in the costs of packaging purchase, transport and logistics, and end of life as well as related Greenhouse gas emissions, essential to meet the EU Green Deal decarbonisation objectives. Our industry has as well made significant investments in innovative packaging technologies, such as light weighting or switching to materials that confide a higher resistance/weight ratio to packaging. Reuse has also been considered for certain applications when and additional benefit could be obtained from an environmental, safety and economic perspective, eg. for some transport applications.

…benefit could be obtained from an environmental, safety and economic perspective, eg. for some transport applications. Finally producers have contributed to the setup of waste management and recycling infrastructures, in certain countries existing since more than two decades ago. The eco-modulation of Extended Producer Responsibility (EPR) fees across the EU contributes to a more sustainable use of packaging throughout the packaging value chain and helps boost the availability of high quality secondary raw materials. Close collaboration with partners along the packaging value chain has been instrumental in these efforts. As part of our circular economy commitments, the European food and drink industry will further work with its supply chain partners to optimise the amount of packaging we use, reduce packaging waste and develop new business models for reuse/refill as much as possible.

…of packaging we use, reduce packaging waste and develop new business models for reuse/refill as much as possible. The objectives pursued here below by the reviewed PPWD are only part of what is necessary to close the loop and achieve packaging sustainability. Collection and innovation are as well essential drivers for this. Objective 2: To limit and/or reduce the packaging waste generated across the EU FoodDrinkEurope agrees with decreasing the generation of packaging waste as a principle. To achieve a more circular, resource efficient economy, it is important to clearly distinguish measures aimed at reduction of unnecessary packaging from measures aimed to reduce the quantities of materials lost to the environment (i.e. litter)and to clearly define the ultimate common goal of those measures.

…of materials lost to the environment (i.e. litter)and to clearly define the ultimate common goal of those measures. The main goal of both types of measures should be to achieve minimum environmental footprint for the provision of products to the consumer up until the end of life and allow innovation at scale. 4/9 We therefore understand the meaning of this objective as aiming to avoid that packaging materials and their value are lost to the environment, coupled with actions on avoiding unnecessary packaging, innovating with alternative ways to offer food and drink products safely to the consumer and by fostering recycling and reuse. Objective 3: To promote the use of reusable packaging whenever logistically feasible with a view to reduce packaging waste generation FoodDrinkEurope members innovate towards the objective to use less packaging where we can.

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…1/6 FoodDrinkEurope’s reply to EU Commission consultation on the Packaging and Packaging Waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC April 2023 INTRODUCTION FoodDrinkEurope supports the general objectives set in the new Packaging and Packaging Waste Regulation (PPWR) of ensuring a well-functioning Internal Market through fully harmonised rules on packaging while tackling the packaging environmental impact.

Internal Market through fully harmonised rules on packaging while tackling the packaging environmental impact. The European food and drink industry strongly supports the ambition to prevent and reduce the adverse effect of packaging and packaging waste on the environment and human health, and recognise the need of unlocking enabling conditions to ensure that sustainability goes alongside with EU growth and competitiveness Over the years, the food and drink industry has constructively worked for the enshrinement of recyclability and reuse goals in legislation supported by a holistic view in the context of the European Green Deal. All economic actors have engaged collectively to come with a common trajectory and encourage the swifter development of enabling conditions.

…engaged collectively to come with a common trajectory and encourage the swifter development of enabling conditions. To ensure Europe becomes the leading continent in circularity and green transition globally, long term guidance and predictability to businesses to invest are paramount. It will enable faster and more far- reaching and ambitious actions to prevent packaging waste, confirmed by years of investments in recycling.

…more far- reaching and ambitious actions to prevent packaging waste, confirmed by years of investments in recycling. The sector had achieved undoubtedly considerable results and made Europe an example of green and sustainable policies Finally, FoodDrinkEurope supports the move towards circularity of packaging, looking at a comprehensive set of complementary actions, including making packaging more recyclable, re-using packaging wherever possible and wherever it provides environmental advantages, exploring ways to reduce packaging from the design phase without compromising on food safety or quality, informing consumers about waste disposal, and helping to boost collection rates, amongst others. This document provides an overview of key recommendations developed by FoodDrinkEurope to ensure that circularity goes hand in hand with innovation, competitiveness and food safety.

…by FoodDrinkEurope to ensure that circularity goes hand in hand with innovation, competitiveness and food safety. Executive summary The European Commission (EC) has published the new Packaging and Packaging Waste Regulation (PPWR) with the aim to prevent and reduce the adverse effect of packaging and packaging waste on the environment and human health. FoodDrinkEurope developed a reply to the feedback period lunched by the Commission to help promote packaging circularity in Europe and achieve the intended aims of the Regulation. Ref.

…by the Commission to help promote packaging circularity in Europe and achieve the intended aims of the Regulation. Ref. Ares(2023)2890150 - 24/04/2023 2/6 KEY MESSAGES – Our guiding principles • Contribute to the EU’s climate neutrality goal and Green Deal objectives and align with the United Nations Sustainable Development Goals • Be coherent and consistent with other packaging-related legislation, such as the Waste Framework legislation, the Single- Use Plastics Directive, the Food Contact Materials legislation and ensure food safety is uncompromised • Ensure appropriate and practicable timelines allowing for the transition to the enforcement of new rules throughout the packaging value chain and consider the needs of SMEs, which form 99% of the EU food and drink sector • Foster effective cooperation among all packaging value chain actors, including packaging producers, packaging…

…that allow space to innovate and to compete while focusing on improved overall product environmental footprint. Enablers of the three priorities: 1. Recyclability • Support industry in its commitment to making packaging recyclable • Ensure industry provides its expertise and is consulted in the development of DfR guidelines • Assume a material, end-of-life pathway and technology neutral approach • Foster a system that helps innovation and safeguard forward-looking policies • Improve collection and sorting of packaging waste (e.g., through infrastructure investment; harmonised minimum requirements for an efficient EPR, DRS across Europe) • Leverage the single market to safeguard efficient waste stream flows • Support harmonised labelling (incl. digital solutions) and sorting instructions across all MS

…waste stream flows • Support harmonised labelling (incl. digital solutions) and sorting instructions across all MS 2. Reuse • Consider re-use when demonstrably beneficial for the environment, underpinned by consumer acceptance, hygiene and safety standards along with proven cost-efficiency. Reuse should be considered as complementary with high quality recycling. • Ensure realistic, evidence-based and proportionate targets only when providing environmental benefit with clear definitions and scope • Apply a broad definition of re-use and refill that can help all sectors to be part of the green transition • Guarantee infrastructure and funding to ensure smooth (reverse) logistics • Ensure high level of food safety and hygiene

…infrastructure and funding to ensure smooth (reverse) logistics • Ensure high level of food safety and hygiene 3. Recycled content • Make sure targets consider availability and costs of the recycled material, as well as the quality of infrastructure and technology available • More incentives should be provided to ensure investments in packaging recycling including government investments (shared responsibility) • Avoid that recycled content is calculated per unit of packaging • Ensure a high level of food safety and consistency with other EU legislation • Avoid packaging functionality from being undermined • Unlock and formally recognize new and innovative recycling technologies (chemical recycling) Recommendations

…and formally recognize new and innovative recycling technologies (chemical recycling) Recommendations 1. Definitions and scope 3/6 • Plastic packaging: Introduction of a definition of “plastic packaging” specifically for article 7 on recycled content  Improving and clarifying definition of recyclability at scale. The geographical scope of industrial sorting and recycling must be EU wide. Collection will take place in one country, but to maximise efficiency it is possible that sorting and/or recycling will happen in another country. The absence of sorting or recycling facilities in a single Member State should not be a reason to determine the non- recyclability of packaging if conditions are in place for the packaging to be recycled in another Member State. To prove its effective and at scale recyclability, packaging must be sorted and recycled in practice across the EU territory 2.

…its effective and at scale recyclability, packaging must be sorted and recycled in practice across the EU territory 2. Recyclability  Clear timeline. As currently proposed in Article 6(1), there is no deadline for the obligation for all packaging to be recyclable. A more realistic timeline would be to have all packaging recyclable by 2030 at the earliest and should consider also other important factors such as the availability of collection, sorting and recycling infrastructure, which varies greatly across Europe. • Improving collection and sorting. Strengthening infrastructures is a key enabler for scaling up packaging circularity. The legislative proposal should be integrated with concrete provisions supporting investments in sorting and recycling infrastructures, as well as with collection requirements and targets for waste management operators.

…and recycling infrastructures, as well as with collection requirements and targets for waste management operators. Enabling conditions are necessary to ensure packaging are recycled at scale from 2035. The first step to recycling is collection. It would be unjustified to ban packaging that is perfectly recyclable if not recycled at scale from 2035. Incentive to increase investments in sorting and recycling, and predictability of volumes collected, would be support the achievement of EU’s packaging recycling targets, and complement industry’s continuous investments in packaging design and recycling innovations. • 5 years transition period for DfR. The article should include timeframes for the adoption of secondary legislation. Redesigning packaging and comply with a new system at scale requires time and investments and human resources.

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Avenue des Nerviens 9-31 - 1040 Brussels - BELGIUM - Tel. +32 2 514 11 11 [email protected] - www.fooddrinkeurope.eu - ETI Register 75818824519-45 Copyright FoodDrinkEurope aisbl; photocopying or electronic copying is illegal Review of the Packaging and Packaging Waste Directive: FoodDrinkEurope input to the Inception Impact assessment Consultation FoodDrinkEurope would like to share its views on the ongoing consultation on the Inception Impact assessment on the upcoming review of the Packaging and Packaging Waste Directive (PPWD).

…on the Inception Impact assessment on the upcoming review of the Packaging and Packaging Waste Directive (PPWD). Setting the end goal and the pathway The end goals of the future PPWD and the new Circular Economy Action Plan (CEAP) should be to reduce and limit the environmental footprint of the life cycle of providing products to the end consumer and ensure that no packaging waste ends up into the environment, while fostering innovation in line with the European Green Deal ambitions. The Commission should follow an integrated approach to designing the most suitable set of measures, including in relation to recycling, reuse, packaging waste minimisation, and improvement of waste management infrastructure.

…in relation to recycling, reuse, packaging waste minimisation, and improvement of waste management infrastructure. Measures should be conceived as tools to achieve the end goals and their impact should be assessed through robust cost/benefit analysis and life cycle assessments that allow business to innovate at scale. The Commission should seek to provide solutions along supply chains and different packaging applications while considering other packaging elements, such as design for recycling, food waste prevention and reduction, and product safety and quality. Impact assessment considerations Future measures to be included in the PPWD should be subject to robust impact assessments founded on science-based criteria.

…measures to be included in the PPWD should be subject to robust impact assessments founded on science-based criteria. The economic implications should be evaluated, especially when those measures are to be added to other ongoing packaging measures, such as EU / national plastics taxation schemes, Extended Producer Responsibility schemes (including EPR fees’ eco-modulation) and the implementation of the Single- Use Plastics Directive.

…schemes (including EPR fees’ eco-modulation) and the implementation of the Single- Use Plastics Directive. The following elements should be taken into account: − Single market disruption; − Safeguarding food safety and preventing food waste; − Market trends and drivers for retailers and consumers’ uptake of sustainable packaging and cost implications; − The mechanism for ensuring that investments could be rewarded through lower EPR fees compared to less sustainable alternatives and better consumer acceptance; − Cost of proving compliance for businesses; − Systemic changes (e.g. distribution, management) that entail some of the packaging design measures assessed (recycling, reuse etc); − Competitiveness of products exported from Europe; Ref.

…the packaging design measures assessed (recycling, reuse etc); − Competitiveness of products exported from Europe; Ref. Ares(2020)4138554 - 06/08/2020 2/4 − Investments and capital expenditure done for the uptake of recycled content which should not be undermined by bans. Any measures should be based on environmental footprint comparative assessment concluding in favour of such measure against existing packaging design and post-consumer management options. Environmental footprint of certain packaging options needs to be assessed in view of the implementation and scaling of new waste management technologies. Harmonised collection, advanced sorting techniques and innovative recycling technologies will have a major impact on the environmental impact of packaging.

…techniques and innovative recycling technologies will have a major impact on the environmental impact of packaging. The measures considered in the impact assessment should also take into account the findings1 and deliberations of the evaluation of the Food Contact Material legislation2 currently being undertaken by European Commission DG SANTE. Recyclability and infrastructure To support a more circular and resource efficient economy, measures should be taken to further develop collection, sorting and recycling infrastructure and new recycling technologies, such as enhanced recycling. The food and drink industry welcomes the Commission’s proposal to look into EU-harmonised collection and separation of packaging waste including harmonised information to consumers.

…to look into EU-harmonised collection and separation of packaging waste including harmonised information to consumers. For specific packaging, deposit return schemes (DRS)- where consumers return their packaging to collection points - can be an effective way to reach collection and recycling targets with the right conditions in place. Such system should coexist with a correct functioning of existing EPR schemes and with enough incentives for the efficient collection of the remaining materials by these schemes. Taking these considerations into account, the Commission should develop guidance on the matter to ensure the implementation and proper functioning of DRS across Europe. Recyclability of packaging has a packaging-design component, but also depends on existing infrastructure. Definition of recyclability should be technology neutral.

…component, but also depends on existing infrastructure. Definition of recyclability should be technology neutral. Requirements establishing minimum harmonised end-of-life infrastructure across the EU are urgently needed, in parallel to the development of Design-for- Recycling (DfR) guidelines which should as well include considerations on design for sorting. DfR guidelines should build on the work of the Circular Plastics Alliance3. When applicable, funds to public authorities through increased EPR fees and packaging-related levies should be clearly earmarked and directed to contribute to increased and improved waste collection and management infrastructure.

…clearly earmarked and directed to contribute to increased and improved waste collection and management infrastructure. To boost a circular economy, ensure the availability of recycled material and the creation of a functioning secondary raw material market, measures on packaging need to incentivize, encourage and reward circularity of packaging materials. We support the introduction of more recycled materials quality grades beside food- grade in order to avoid competition for recycled materials in the market.

…materials quality grades beside food- grade in order to avoid competition for recycled materials in the market. Considering that there are already legislative targets set to reintegrate recycled materials in drink packaging, we also call on the Commission to develop guidance to promote the circularity of materials especially with regards to redirect as a priority foodgrade plastics (PET, PE, HDPE, PP) into foodgrade recycled plastics to secure adequate supply without compromising safety standards for the food and beverage sectors. Exports of high-quality material outside of Europe (e.g. China) are detrimental to further use of recycled material within the EU market. Incentivising a stronger uptake of recycled content should be realized through tools providing long-term perspective and legal certainty for economic operators.

…content should be realized through tools providing long-term perspective and legal certainty for economic operators. Restrictions fail to convey these necessary economic conditions as they do not support sustainable packaging as positive contributor to circularity . 1Study supporting the Evaluation of Food Contact Materials (FCM) legislation - (Regulation (EC) No 1935/2004) https://op.europa.eu/en/publication-detail/-/publication/3ae0294b-bc0c-11ea-811c-01aa75ed71a1/language-en 2 https://ec.europa.eu/food/safety/chemical_safety/food_contact_materials/evaluation_en 3 https://ec.europa.eu/growth/industry/policy/circular-plastics-alliance_en 3/4 Packaging waste reduction vs.

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