innocent drinks

…1 Innocent drinks Position paper on the proposal for a Regulation on Packaging and Packaging Waste (PPWR) About innocent Drinks • innocent drinks have been on a mission to make it easy for people to do themselves some good. We get our hands on the tastiest fruit and veg we can find, stick it in a bottle and never add any nonsense like sugar. • We sell our tasty little drinks in 18 markets, mainly in Europe. innocent’s sustainability and circularity commitments We support the Commission’s ambitions set out in the Green Deal as it sets the blueprint for the transformational change that is needed to address climate change. At innocent we are supporting this directly by: • Ensuring our bottles contain 50% recycled content and we are trialling our most sustainable bottle yet that is made from recycled and plant-based materials, eliminating the use of fossil fuels.

…most sustainable bottle yet that is made from recycled and plant-based materials, eliminating the use of fossil fuels. • Ensuring our packaging is easy to recycle and campaigning to join Deposit Return Schemes (DRS) where possible. • Keeping the carbon footprint of our drinks as low as possible. We’re committed to reducing our carbon footprint by 50% per litre by 2030 as part of our verified Science Based Target (SBT). • Building an all-electric sustainable factory in Rotterdam which will be powered by solar and wind energy called the Blender which will help us make 70% of our drinks under one roof, from fruit to bottle. Whilst we get our solar panels and wind turbines up and running the Blender is powered by renewable energy from the grid. • Commit to always sourcing our ingredients sustainably. Our view on the PPWR Topline priorities

…energy from the grid. • Commit to always sourcing our ingredients sustainably. Our view on the PPWR Topline priorities 1. Recyclability – packaging should be made to ensure high quality recyclability. The regulation should ensure that sorting and collection rates are achieved through harmonised minimum requirements for Deposit Return Schemes. 2. Re-use and refill – ensure realistic evidence based proportionate targets that recognise the constraints and nuances of the juice sector, calculated at EU level. 3. Recycled content - ensure that the availability and cost of recycled content is considered in the targets. Allow priority access to rPET for the beverages sector.

…and cost of recycled content is considered in the targets. Allow priority access to rPET for the beverages sector. PPWR Measures There is lots to welcome in the Packaging and Packaging Waste Regulation, but there are also elements that, whilst we support their purpose, we are concerned about with regards to our sector’s ability to deliver them in the timeframe given. Ref. Ares(2023)2890155 - 24/04/2023 2 I) Measures where industry is well placed to deliver • Mandatory Deposit Return Schemes: We think they're a great idea. There are lots of countries where deposit return schemes are working well and get much higher recycling rates. We support any system that increases the recycling rates for plastic, makes economic sense and improves the quality of recycled plastics so they can be used more widely. We would particularly like to see a harmonised approach to DRS across the EU.

…plastics so they can be used more widely. We would particularly like to see a harmonised approach to DRS across the EU. Having a different scheme with different requirements for each Member State is challenging for businesses. • Design for recycling: We fully support the principle that care is taken during a packaging's design and development process to ensure the packaging is suitable for recycling after being used or reused. At innocent we have tested all our packaging against circpack's design for recycling criteria and will be making all the necessary improvements to score an “A “. • Recycled content targets for plastic packaging: This is an important step to decrease the use of virgin plastic. Most of our bottles contain 50% recycled content, and those that are not 50% are 30%.

…the use of virgin plastic. Most of our bottles contain 50% recycled content, and those that are not 50% are 30%. II) Measures where more consideration and flexibility are needed to recognise the difference between sectors Reuse and Refill Whilst we are working on removing virgin plastic from our bottles, at innocent we are also working on trying to move from single use plastic completely by trialling other solutions such as dispense on the go and refill at home. However, whilst we continue to make progress on our innovations, refill and reuse is unfamiliar territory for the juice and smoothie sector and will likely require a different supply infrastructure and operating/business model. This is a significant step change that we need time to address. There are several other reasons why juices and smoothies as a category, have specific and significant challenges to overcome: 1.

…several other reasons why juices and smoothies as a category, have specific and significant challenges to overcome: 1. Aseptically filled fruit juices and smoothies are highly sensitive products and have similar microbiological characteristics to milk, resulting in similar concerns for product spoilage and food safety for consumers. Consequently, they require very careful processing and strict levels of process and package hygiene to ensure sterility and safety. • Indeed, their microbiological nature is more fragile and less stable compared to some other beverages, which often contain chemical preservatives and carbon dioxide. Packaging performs the crucial role of providing a sterile receptacle for products and an effective barrier against entry of microorganisms and against oxygen, light and loss of aromas.

…for products and an effective barrier against entry of microorganisms and against oxygen, light and loss of aromas. • The microbiological integrity of chilled juice and smoothie products filled into lightweight PET bottles relies on the fact that the container is clean and sterile before the juice is filled into it as there is no post filling treatment. In non-sterile packaging, fruit juices spoil in a very short time, which would result in consumer food safety concerns and high levels of food waste. • There is currently no returnable container filling process, cleaning system, distribution network or wider supply chain that can manage safely a reusable system for aseptically filled, short shelf-life chilled juices.

…or wider supply chain that can manage safely a reusable system for aseptically filled, short shelf-life chilled juices. Historically returnable juice and smoothies were filled 3 into heavy returnable glass bottles using a hot fill, UHT process that used the high filling temperature of the liquid to sterilise the inside of the bottle and closure preventing fermentation and spoilage. This is incompatible with the gentler cold fill, aseptic process used to fill short shelf life, chilled juices and smoothies. 2. Due to these characteristics, the fruit juice sector uses a similar packaging mix as other sensitive products such as milk and alcohol, with no technical alternative to reusable packaging except refillable glass. • Because of the products’ characteristics, the fruit juice industry uses the packaging which best protects, transports and preserves its products.

…the fruit juice industry uses the packaging which best protects, transports and preserves its products. • The packaging mix in the sector is 60% cardboard, 30% is plastic, 8% is glass and the final 2% represent others such as cans, aseptic bag-in-boxes and pouches. • The only returnable packaging, technically feasible for fruit juices, is returnable glass. All others are unable to protect the product from spoilage. Whilst there are some facilities that can manage the cleaning and sorting of PET/rPET bottles for other beverages, this does not exist for juices. Current refillable PET bottles do not meet the level of sterility needed to avoid microbiological spoilage. • Our packaging must be completely sterile. The packaging we use is new, so the level of cleanliness is very high, and it also goes through a further disinfection process immediately before juice goes inside it.

…is very high, and it also goes through a further disinfection process immediately before juice goes inside it. This can’t be achieved through a returnable/refillable PET bottle process because the material cannot withstand the high temperatures and contact time required to kill pathogens and spoilage organisms effectively enough. Legacy returnable glass filling systems relied on the use of heavy glass bottles designed to withstand the refilling life cycle many times, and large amounts of heat and chemical cleaning agents were required to wash them resulting in very high energy usage and caustic effluent production. In addition, there is a need for twice as many vehicle journeys as empty glass bottles are returned to the factory. • If mandatory reuse requirements and targets are set for the fruit juice industry, the only current alternative is heavy returnable glass bottles.

…and targets are set for the fruit juice industry, the only current alternative is heavy returnable glass bottles. Suppliers are working on returnable PET for sensitive products, but more time is needed to understand if this is a feasible solution. We know from our own studies that transportation of glass has a significantly higher carbon emission than plastic. 3. The European fruit juice industry is too small a sector to ask for specific derogations. • As it is small compared to other beverage industries, representing in 2021 6,9% of the beverage market in the EU (8,5 bn litres in market volume out of 123,9 bn litres), it would be a-practical to have sector specific packaging rules. Achieving the scale needed to introduce the reuse and refill targets per market will be very difficult and will need a step change approach to supply chains.

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