Interesų grupė
…1 ZUMOS Y GAZPACHOS DE ESPAÑA CONTRIBUTION TO THE CONSULTATION ON THE PACKAGING AND PACKAGING WASTE REGULATION PROPOSAL OF THE EUROPEAN COMMISSION Introduction The juices and gazpachos sector shares the Commission's ambition to continue moving towards packaging sustainability, innovating in eco-design to improve its recyclability, promoting the prevention of packaging waste, and increasing the content of recycled material, thus favoring the market for secondary raw materials. The sector is committed to the concept of "circular packaging" especially for beverage packaging, which meant to be a circular, sustainable, and waste-preventing alternative to traditional throwaway models, and that could even be a better and wider concept than only “reuse”.
…alternative to traditional throwaway models, and that could even be a better and wider concept than only “reuse”. Therefore, before imposing obligations that are extremely restrictive and technically unfeasible in some sectors and cases, it is necessary to carry out a thorough evaluation that allows to deeply analyse the feasibility and benefits of the measures to determine which is the best option in each situation, from an environmental, technical, economic and social perspective, without jeopardizing food security and giving companies sufficient time to adapt to possible changes that entail relevant impacts on production processes and high investments. It is important to provide a margin of flexibility to companies to be able to comply with the objectives, as well as try to minimize bureaucratic burdens.
…of flexibility to companies to be able to comply with the objectives, as well as try to minimize bureaucratic burdens. This regulation should also ensure the integrity and proper functioning of the single market, avoiding the proliferation of national or regional legislation that entails legal uncertainty for businesses. Zumos y Gazpachos comments on key matters Reuse and Refill (Article 26) We consider it is essential during this process to insist on the fact that reuse should only be considered an option when life-cycle analysis prove that it is the most beneficial from the environment point of view and cost-efficient.
…when life-cycle analysis prove that it is the most beneficial from the environment point of view and cost-efficient. Before proposing targets, it is very important to analyse the specificities of the different categories: for example, their volume of consumption, characteristics of the distribution channel that can make the reverse logistics process very complicated, location of the factories, size of the companies or the Ref. Ares(2023)2863696 - 23/04/2023 2 density and organic content of the product itself. Indeed, an extensive analysis on the unfeasibility of reusability in the juice sector is provided as Annex 1. The juice and nectar sector would like to draw the attention to the fact that the particularities of sensitive food products, such as fruit juices, have to be taken into account, and that justify/support the exemption from reusability targets.
…such as fruit juices, have to be taken into account, and that justify/support the exemption from reusability targets. As members of AIJN (European Association of Juice and Nectar Producers) we share the position that has been developed at European level and whose reasoning is enclosed as Annex 2. Thus, the different beverage sectors are at very different starting points. The volume of the juice category is lower to make reuse viable, and its indirect distribution channel formed by numerous intermediaries between the supplier and the end customer makes the reverse logistics process particularly complicated. Furthermore, the reconditioning of the juice bottles poses additional problems due to the density and organic content of the product.
…reconditioning of the juice bottles poses additional problems due to the density and organic content of the product. Due to the viscosity and pulp content of the fruit, the residues deposited on the walls and bottom of the container tend to solidify over time due to moisture loss, a phenomenon that would be aggravated in the hottest months and with long times and distances related with reverse logistics, which would imply the need for many washings with the consequent expense of water, energy and chemical cleaning and disinfection products, and could also significantly increase the risk of contamination by foreign bodies due to the loss of asepsis. Indeed, the juice sector is very similar to the milk and milk products sector and the exemption from the re-use targets to milk is also essential for the juice sector.
…milk and milk products sector and the exemption from the re-use targets to milk is also essential for the juice sector. Moreover, the economic investments involved are currently unaffordable, without forgetting that the reuse lines require a significant amount of space for the additional stages of the process, which many companies do not currently have because of the way they have been designed. Due to the location of the factories, the distribution of products in reusable packaging throughout the territory would mean that the empty packaging would have to travel long distances, so the environmental impacts generated by the return logistics would be quite high. We also believe it is necessary to include the concept of “circular packaging” (single-use or reuse) as a circular, sustainable and waste-preventing alternative to traditional throwaway models.
(single-use or reuse) as a circular, sustainable and waste-preventing alternative to traditional throwaway models. Circular packaging is that which is collected separately at a high rate, refilled or recycled multiple times for the same use; so when recycled, it should contain a high percentage of recycled material originating from packaging, thereby contributing to material resource efficiency and litter prevention. Instead of focusing only on re-use as the unique alternative, circular packaging is a wider concept that includes single-use and refillable/returnable packaging as valid solutions in terms of waste prevention and environmental impact minimization.
…refillable/returnable packaging as valid solutions in terms of waste prevention and environmental impact minimization. Single-use circular packaging is an option technically, economically and environmentally useful, effective and feasible (even more than reusable packaging for long supply and 3 distribution chains) to minimize the use of virgin materials, to reduce the environmental impact of packaging and to prevent packaging waste generation. Recycled content (art. 7) To meet their recycled content obligations laid down, the producers need to have access to a sufficient amount of affordable, high-quality recycled food-grade plastic. Recycled PET is highly demanded by other sectors to incorporate it into lower quality applications, such as textiles or tires, where it will generally no longer be recyclable.
…it into lower quality applications, such as textiles or tires, where it will generally no longer be recyclable. To avoid this downcycling, producers – and any other sector that must be subject to mandatory minimum recycled content targets – should have priority access to a fair share of the recycled materials they put on the market. On the other hand, the targets lay down in Article 7 apply for the plastic part of the packaging, and after clarification by CE, any part of plastic packaging, no matter how much there is of it, will need to comply with these targets. However, so far, PET is practically the only recycled plastic generally authorized for use in food contact material. It is expected that EFSA will be authorizing new processes for other kind of plastics, but there is no timeline so, currently, the only real market for recycled plastic suitable for contact with food is PET.
…is no timeline so, currently, the only real market for recycled plastic suitable for contact with food is PET. This provision “for the plastic part in packaging” should only apply when EFSA not only assessed the processes of recycling for other plastics as safe, but authorized it, and these plastics will be available on the market. We believe that targets could be set per economic operator as an average of their product portfolio placed on the market, in a manner consistent with the SUP Directive, rather than per unit of packaging. Unlock (early authorisation of) new and innovative recycling technologies such as chemical recycling, in order to have food-grade recycled material available.
…innovative recycling technologies such as chemical recycling, in order to have food-grade recycled material available. For this, we want to promote this more quickly, taking into account that the creation of "fuel" would not be counted as recycled, as established by Spanish legislation, and support the balance of masses and the credit method. All operators of the food and beverage sector with mandatory recycled plastic targets should be granted priority access to recycled material from packaging placed on the market (Right-of-first Refusal), thus avoiding downcycling. Plastic parts in non-plastic dominated packaging, like paper and metal, should be excluded from the recycled plastics targets. Restrictions on packaging (Art.
97 → 12