Interesų grupė
Website: pbpc.com Jessica Bowman | (202) 331-2028 [email protected] 6 January 2020 European Commission Submitted as Supplement to Public Consultation Survey Responses RE: Final Remarks on Public Consultation to Inform the Review of the Requirements for Packaging and Other Measures to Prevent Packaging Waste The Plant Based Products Council (PBPC) appreciates this opportunity to provide input to the European Commission in response to the 30 September 2020 Public Consultation to inform the review of the requirements for packaging and other measures to prevent packaging waste.
Consultation to inform the review of the requirements for packaging and other measures to prevent packaging waste. PBPC represents businesses large and small in the United States and internationally, including the European Union, who are committed to guiding the evolving global economy toward more sustainable and responsible consumer products and packaging through greater use of plant-based materials (sometimes termed “bioproducts”). We aspire to deliver a future based on renewable goods, improving global resource efficiency to meet the challenges of the 21st century while also providing environmental benefits through reduced greenhouse gas (GHG) emissions and improved soil quality and water quality, along with improved recycling of food waste.
…gas (GHG) emissions and improved soil quality and water quality, along with improved recycling of food waste. Plant-based materials are derived from renewable sources, including agricultural commodities such as colza, maize, hemp, soy, and sugarcane and can serve as alternatives to traditional consumer materials, including plastics, that are often derived from fossil fuels. These plant-based materials can be used to manufacture the next generation of packaging, some of which is recyclable like bio-PET, and some which is compostable like PLA. PBPC recommends that in considering ways to enhance the Packaging and Packaging Waste Directive (PPWD) through implementation of the Circular Economy Action Plan (CEAP) and the European Green Deal more broadly, the European Commission should appropriately consider the role of plant-based packaging in meeting the PPWD objectives.
…the European Commission should appropriately consider the role of plant-based packaging in meeting the PPWD objectives. Renewable plant-based packaging supports multiple objectives of the PPWD, including prevention of packaging waste and minimizing the environmental impact of packaging. These materials are an essential part of advancing a circular economy and part of the solution to the packaging pollution that plagues our planet’s environments. Across the plant-based packaging spectrum, from plastics to molded fiber, these materials offer a wide range of performance advantages and disposal options when compared to traditional packaging.
…materials offer a wide range of performance advantages and disposal options when compared to traditional packaging. 1. Waste Prevention Many plant-based packaging materials, including molded fiber and plastic resins like polylactic acid (PLA), are compostable. Compostable plant-based packaging materials, when used in food-related applications, presents an opportunity to help divert both the packaging itself and accompanying food scraps to composting facilities. Such use helps prevent food contamination in the recycling stream and allows for broader diversion of food waste to compost. Challenges exist regarding the processing of compostable packaging, including confusion with non-compostable materials. However, when coupled with appropriate, consistent end-of-life labeling across all packaging, along with proper infrastructure, Ref. Ares(2021)118302 - 06/01/2021 Page | 2 plant-based…
…as a resource that aligns with the PPWD objective to help Member States prevent the generation of packaging waste. 2. Minimized Environmental Impacts According to the objectives of the PPWD, packaging must ensure greater environmental protection than just packaging waste prevention. All plant-based packaging can help support this objective. In terms of the environmental benefits rendered from compostable plant-based packaging, these materials can positively contribute to reduced waste and lower GHG emissions, as well as improved water quality and soil health.
…can positively contribute to reduced waste and lower GHG emissions, as well as improved water quality and soil health. When considering the GHG emissions reduction potential of these materials, look to the beginning and end of the life of these products: compostable plant-based materials are produced from renewable feedstocks, and at the end of their useful life they are disposed of in a way that avoids landfill methane emissions due to the diversion of organic matter that accompanies this packaging. Soil health benefits can be derived from the composting of plant- based materials, where these products contribute to the production of a powerful soil amendment. Lastly, compostable plant-based materials can contribute to improved water quality by keeping litter out of our oceans and helping prevent the runoff of nutrients into vulnerable bodies of water.
…by keeping litter out of our oceans and helping prevent the runoff of nutrients into vulnerable bodies of water. In addition, some forms of plant-based packaging can be recycled, like molded fiber in paper recycling streams and bio-based PET in traditional PET recycling. In addition to fitting into existing recycling streams, recyclable plant-based packaging holds the benefit over petroleum-based packaging of being sourced from renewable materials, leading to reduced fossil fuel use and overall GHG emissions. In addition to supporting the general objectives of the PPWD, PBPC believes that compostable plant- based packaging addresses the goals of the Circular Economy Action Plan (CEAP), particularly its goals of: making sustainable products the norm in the EU, focusing on the sectors that use the most resources and where the potential for circularity is high, and ensuring less waste.
…on the sectors that use the most resources and where the potential for circularity is high, and ensuring less waste. Regarding making sustainable products the norm in the EU, plant-based packaging is widely available and ready to assume a greater presence on the market at scale through efforts of the private sector or similarly through green public procurement. For example, the Ellen MacArthur Foundation has estimated that bio-based plastic resins that exist today have the potential to replace about 66% of major traditional plastics used in packaging.1 In focusing on sectors that have a high potential for circularity, plant-based plastics meet that criteria.
…packaging.1 In focusing on sectors that have a high potential for circularity, plant-based plastics meet that criteria. Take for example the circular lifetime of compostable plant-based plastic: renewable plant-based feedstocks are converted into plastic pellets through advanced manufacturing technologies, which are then molded into consumer products and packaging, disposed of at the end of their useful life alongside any organic waste like food that was part of its packaging function, and sent to a composting facility to be turned into compost, a valuable soil amendment that helps grow the next generation of compostable plastic feedstock. In addition to supporting the implementation of the CEAP, the widespread adoption of compostable plant-based packaging also supports important elements of the broader European Green Deal from which the CEAP is derived.
…packaging also supports important elements of the broader European Green Deal from which the CEAP is derived. In its missions to achieve greater reductions in GHG emissions, plant- 1 World Economic Forum, Ellen MacArthur Foundation, and McKinsey & Company. The New Plastics Economy: Rethinking the Future of Plastics. (2016) pp. 93. https://www.ellenmacarthurfoundation.org/our- work/activities/new-plastics-economy/reports Page | 3 based packaging can help reduce overall EU consumption of fossil fuels to produce traditional packaging. For example, the United States Department of Agriculture has estimated that the use of biobased products as alternatives to petroleum-based products in 2016 reduced the total GHG emissions profile of these consumer products and materials in the U.S.
…products in 2016 reduced the total GHG emissions profile of these consumer products and materials in the U.S. by 12.7 million metric tons of CO2 equivalents.2 These materials more specifically reduce methane emissions from landfills as well. In 2018, 24% of all municipal waste generated in the EU is landfilled3, roughly 34% of which was organic waste in the form of food and garden waste4. With compostable plant-based food packaging, food waste can accompany the packaging to a composting facility rather than end up in a landfill to contribute to methane emissions. Additionally, plant-based packaging materials support the European Green Deal element of mobilizing industry for a clean and circular economy for the reasons stated in the paragraph above that support their place in the policy implementation of the CEAP.
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