ALPLA Werke Alwin Lehner GmbH & Co KG

ALPLA Werke Alwin Lehner GmbH & Co KG Circular Economy & Public Affairs [email protected] Position paper Packaging and Packaging Waste Regulation (PPWR) – COM(2022)677 The ALPLA Group, with its 190 locations and 23,300 employees in 46 countries worldwide, is one of the leading global plastic converters and a growing recycler. We develop and produce innovative rigid plastic packaging solutions, while ensuring that our products become lighter, more durable and by 2025 fully recyclable. We have more than 25 years of experience in recycling operations and invest €50 million annually in the expansion of our recycling infrastructures to increase the average share of post- consumer recycled content (PCR) in our products to 25% by 2025. We consider the proposal of the Commission for a Packaging and Packaging Waste Regulation (PPWR) to be an important step towards a circular economy.…

…preventing ecological setbacks, especially in terms of climate protection. We like to point out the following aspects: 1. Legal requirements, such as minimum recycled content quotas (Art. 7), reuse quotas (Art. 26) and deposit return systems (Art. 44), must be applied equally to all packaging materials to ensure material neutrality. 2. Reuse and recycling are complementary solutions to achieve true circularity in packaging. All recyclable and reusable packaging must therefore be evaluated equally according to its actual environmental footprint instead of setting strict reuse targets for example for transport packaging (Art. 26). 3. Recycled content targets (Art. 7) are useful and can promote the upscaling of recycling. However, these targets must be realistic and achievable by means of environmentally beneficial mechanical recycling.

…these targets must be realistic and achievable by means of environmentally beneficial mechanical recycling. 4. EPR fees must be modulated for all packaging based on recyclability criteria, recycled content and CO2e footprint to avoid material discrimination and promote a level playing field. 1. Legal requirements, such as minimum recycled content quotas (Art. 7), reuse quotas (Art. 26) and deposit return systems (Art. 44), must be applied equally to all packaging materials to ensure material neutrality. Our packaging solutions can contribute to climate neutrality, as their CO2e footprint is significantly smaller compared to packaging solutions using other materials1. Therefore, we consider an equal treatment of all packaging solutions regardless of their material to be appropriate in order to enable fair economic competition as well as the best solution for the environment.

…to be appropriate in order to enable fair economic competition as well as the best solution for the environment. 1 McKinsey & Company, Climate impact of plastics, July 2022 (climate-impact-of-plastics-v2.pdf (mckinsey.com)) Ref. Ares(2023)2065498 - 22/03/2023 We welcome the fact that the Commission is introducing target quotas for recycled content in plastic packaging (Art. 7), to ensure demand for PCR. However, to guarantee material neutrality, targets or legal requirements such as recycled content quotas do not only have to be applied to plastic packaging. If other materials are not included in those requirements, we will face economic disadvantages and a shift towards potentially less sustainable packaging solutions. This trend is already be observed on the Member State level, due to national measures such as plastic taxes.

…solutions. This trend is already be observed on the Member State level, due to national measures such as plastic taxes. We are highly appreciating the following amendments to the regulation: • Expansion of minimum recycled content quotas to all packaging materials (Art. 7) • No material-specific exemptions from reuse quotas for transport packaging (Art. 26) • Expansion of deposit return systems to all other single-use beverage packaging materials (Art. 44) In our view, these measures will lead to a level playing field that will promote the use of recycled content, reuse where it is environmentally beneficial, and the return and collection of all single-use beverage containers. 2. Reuse and recycling must be considered as complementary solutions to achieve true circularity in packaging.

…2. Reuse and recycling must be considered as complementary solutions to achieve true circularity in packaging. All recyclable and reusable packaging must therefore be evaluated equally according to its actual environmental footprint instead of setting strict reuse targets for example for transport packaging (Art. 26). We fully agree that the promotion of reuse can lead to a decrease in packaging waste and can hence be useful in multiple applications. At ALPLA, we develop and produce reusable PET beverage bottles that have an excellent environmental footprint. However, as multiple scientific studies2 have proven, reuse solutions are not always the best option in terms of their ecologic, economic and societal impact. Therefore, all packaging must be evaluated based on its actual environmental footprint.

…economic and societal impact. Therefore, all packaging must be evaluated based on its actual environmental footprint. A single-use PET bottle is outperforming a heavy reusable glass bottle from a sustainability perspective when it contains a certain percentage of recycled content, is lightweight and is recycled at the end- of-life stage3. Reuse targets as proposed in Art. 26 will not necessarily lead to a reduction of emissions and other environmental impacts. This is also recognised in the impact assessment (p. 391). We at ALPLA are already using reusable and recyclable transport packaging where possible, like reusable plastic pallets or foldable metal packaging used in combination with single-use, recyclable plastic bags or inliners, to minimise packaging waste. A reuse target of 10–30% for straps and wrappings (Art.

…bags or inliners, to minimise packaging waste. A reuse target of 10–30% for straps and wrappings (Art. 26(9)) implies shifting to solutions without wrappings and straps at all, which makes secondary packaging more complicated regarding feasibility and requires more manpower. However, the recycling of wrappings and straps is possible, and this is how it is practised for example at ALPLA. In consideration of the above points, we highly recommend that optimised recyclable single-use packaging that is ecologically better or at least equivalent to reusable packaging have to be counted towards the quotas. Additionally, the impact assessment of the Commission focuses mainly on the factor of waste reduction and does not consider possible impacts on transport-related emissions and other unintended side effects.

…and does not consider possible impacts on transport-related emissions and other unintended side effects. We therefore encourage the Commission to support its proposal with scientific facts underlining the necessity of such reuse quotas compared to other measures. 2 Ifeu Heidelberg (2010) – Einweg und Mehrweg: Aktuelle Ökobilanzen im Blickpunkt 3 Fehringer, Roland, Ökobilanz für Gebinde aus PET und anderen Materialien, April 2019 (ALPLA LCA Packaging - Ökobilanz für Gebinde aus PET und anderen Materialien) 3. Recycled content targets (Art. 7) are useful and can promote the upscaling of recycling. However, these targets need to be realistic and reachable by means of less energy-intensive mechanical recycling.

However, these targets need to be realistic and reachable by means of less energy-intensive mechanical recycling. Minimum quotas for the use of recycled content in plastic packaging are intended to create a guarantee demand for recyclates independent of the virgin material price and thus ensure investment security for recycling. We really appreciate this approach. Nevertheless, the possible risks for mechanical plastics recycling need to be considered. Especially the high recycling quotas for food-contact polyolefins are posing a risk to mechanical recycling. Due to lacking European Food Safety Authority (EFSA) approvals, the use of mechanically recycled polyolefins in food-contact applications is currently not possible in the EU.

…the use of mechanically recycled polyolefins in food-contact applications is currently not possible in the EU. To avoid a potential corresponding shift from mechanical recycling to energy-intensive chemical recycling processes, an exemption for polyolefin packaging in direct contact with food is necessary and in our opinion must therefore be introduced (Art. 7). Chemical recycling must be understood as a complementary technology to mechanical recycling, for input which is not suitable for mechanical recycling only. A general promotion of chemical recycling contradicts the targets of the PPWR in terms of climate neutrality and the protection of the environment. We therefore strongly recommend exemptions for food-contact polyolefins and the re-examination of the preconditions five years after the entry into force of the regulation.

…polyolefins and the re-examination of the preconditions five years after the entry into force of the regulation. This will promote innovation in mechanical recycling and give EFSA enough time to issue the approvals needed. 4. EPR fees must be modulated for all packaging based on recyclability criteria, recycled content and CO2e footprint to avoid material discrimination and promote a level playing field. We welcome that financial contributions to be paid by producers to comply with their extended producer responsibility (EPR) obligations shall be based on design for recycling criteria, recycling performance grades and, for plastics, recycled content (Art. 6 (4)). However, we recommend expanding the scope of recycled content as a criterion for EPR fees to all packaging materials. This will avoid material discrimination and promote a level playing field.

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