TOMRA Systems ASA

Proposal for a Packaging and Packaging Waste Regulation (PPWR) TOMRA feedback on the European Commission’s proposal Summary TOMRA, the leading solutions provider for the collection and sorting of waste for reuse and recycling, welcomes the Packaging and Packaging Waste Regulation proposal by the European Commission, which sets ambitious but achievable goals during a timeframe to enable investment. Harmonisation across the European Single Market is needed to provide the necessary predictability for investors to scale up needed capacities and we support the proposal to replace the Directive with a Regulation with direct effect. In particular, we welcome the following measures: • Waste prevention and reusable packaging, as it is essential that we implement measures higher up on the waste hierarchy, as defined under the Waste Framework Directive, in our efforts to reduce waste.

…higher up on the waste hierarchy, as defined under the Waste Framework Directive, in our efforts to reduce waste. • Recycled content targets for packaging containing a plastic part, which will not only increase the uptake of secondary raw materials but will provide recycling players with the legal certainty they need to scale up needed infrastructure. • Recyclability criteria will help ensure that we meet the objective of packaging that is recyclable both by design and in practice – we believe this should be achieved by 2030 as set in the Circular Economy Action Plan. The delegated acts and the methodology to assess recyclability (at scale) should be available in due time to allow the industry to adapt with the new rules.

…to assess recyclability (at scale) should be available in due time to allow the industry to adapt with the new rules. • Strengthened separate collection requirement and, in particular, the introduction of well-designed Deposit Return Systems (DRS) for plastic and metal beverage containers which are proven to increase capture rates, reduce littering, and increase circularity of materials. At the same time, given the intention for all packaging to be recyclable by 2030, (energy) recovery and landfilling of recyclable packaging materials should no longer be tolerated. Welcoming the overall direction of this new proposal, we do however note that several significant aspects of the Regulation are left to secondary legislation.

…new proposal, we do however note that several significant aspects of the Regulation are left to secondary legislation. Given the strong impact this Regulation will have on stakeholders all across the value chain, it will be of key importance to include a wide variety of stakeholders in the elaboration of said delegated acts. Similarly, despite the complexity of the file, TOMRA insists on the importance of having it finalised in time by mid-2024 to create the legal certainty necessary to kick-start the foreseen changes. Ref. Ares(2023)2893486 - 25/04/2023 Below is a more detailed summary of our key proposals for further improving the Commission’s proposal to achieve the goals of reducing packaging waste and improving packaging circularity. Key proposals 1.

…proposal to achieve the goals of reducing packaging waste and improving packaging circularity. Key proposals 1. Prevention/ Reuse Given the growing amounts of packaging and associated generation of waste, TOMRA welcomes the ambition of the PPWR proposal of moving up the waste hierarchy, by introducing targets for the prevention of packaging waste and reuse of packaging. Such binding targets provide the necessary legislative framework to reverse the current trend. Further, the introduction of targets for reusable packaging sends a strong market signal and creates the appropriate environment to enable long-term investment. This is particularly true for the food and beverage take-away sectors, where the proposed targets could have a strong transformational effect, and greatly reduce waste generation.

…sectors, where the proposed targets could have a strong transformational effect, and greatly reduce waste generation. At the same time, TOMRA believes that it is important that reuse targets be focused on the sectors where they have the highest potential for proven environmental benefits, using an evidence-based approach. The regulation sets, for the first time, quantitative targets on the top two layers of the waste hierarchy – prevention and reuse. Although reuse does contribute to waste prevention, it is important to keep the targets consistent. In particular, reuse needs to be differentiated from refill: as outlined in recital (65), refill is a prevention measure and should therefore count towards the prevention targets set under Art. 38, it should not be included in the reuse targets under Art.26 paragraphs (2) to (6).

…targets set under Art. 38, it should not be included in the reuse targets under Art.26 paragraphs (2) to (6). With the current Directive Member States have the possibility to include reuse towards the achievement of their recycling targets, accounting for up to 5 percentage points. However, given that the Regulation now proposes to introduce separate and specific reuse targets, it is no longer justified to account reuse towards recycling targets – or at least not for those packaging types for which explicit targets are set under Art.26. Therefore, the text under Art.48 (1) needs to be adjusted accordingly for the 2030 targets. The proposal stipulates that the rules on how the reuse targets will be measured are to be defined in implementing acts by end 2028. We stress that such a timeline would leave only one year until targets need to be achieved and is too late.

…end 2028. We stress that such a timeline would leave only one year until targets need to be achieved and is too late. The rules on measurement must be available much earlier to allow sufficient time to industry to adapt their packaging and put in place efficient reuse systems and necessary infrastructure. 2. Recycled content TOMRA strongly supports the targets set on recycled content for all packaging containing a plastic part, as they will create the necessary conditions for the development of a functioning secondary raw materials market.

…part, as they will create the necessary conditions for the development of a functioning secondary raw materials market. These ambitious targets will not only increase the uptake of secondary raw materials (and thereby decrease reliance on virgin feedstock and consequently fossil fuels), they will also create the necessary conditions for long-term investment in recycling infrastructures as they provide the certainty recyclers need via stable demand for recycled materials. We also welcome the differentiation of targets according to categories of packaging which reflect the current regulatory and technical challenges of integrating recycled content into PET vs non-PET and contact-sensitive vs non-contact sensitive applications.

…of integrating recycled content into PET vs non-PET and contact-sensitive vs non-contact sensitive applications. Apart from the category of “single-use plastic beverage bottles”, placing the targets for the other categories on a per-unit basis is overly restrictive and in some cases technically unfeasible in the short to mid-term. A more flexible – yet robust – approach is therefore recommended to balance the possibility of using varying levels of recycled content in different applications while still keeping the intended overall market demand for recyclates. The intention should be to keep the maximum possible amount of plastic materials at their highest value, for as long as possible – therefore circularity should not necessarily be limited to the packaging sector once the quality is not suited for that sector anymore.

…should not necessarily be limited to the packaging sector once the quality is not suited for that sector anymore. TOMRA supports a resource hierarchy whereby materials are turned back to the same or similar application, employing the least energy and resource-intensive processes (mechanical recycling as priority: food contact – other contact-sensitive – non- contact sensitive – durable plastic applications; chemical recycling for degraded/ contaminated plastic waste). Exemptions from recycled content targets should not be granted to compostable plastics – apart from those packaging formats for which compostability is mandated under Art. 8 (1) – as this could be a loophole for avoiding the recycled content requirement and might lead to material substitutions. Compostable plastics are required to go for material recycling according to Art.

…lead to material substitutions. Compostable plastics are required to go for material recycling according to Art. 8 (3) and can thus generate recycled content to be integrated in new products. While we fully support the explicit focus on plastic packaging for recycled content targets given the challenge of low uptake for that material, we would recommend a material- neutral wording when it comes to general provisions related to recycled content. In particular, the modulation of EPR fees based on the percentage of recycled content should not be limited to plastic packaging only. To avoid unnecessary material substitutions and market disruptions, and at the same time expand the benefits of wider use of recyclates, we would advise an assessment of the situation and suitability of setting targets on other materials earlier than the 8-year timeline proposed under Art.7 (11).

30 → 12

originalus šaltinis (PDF) ↗

Contribution of TOMRA to the Public Consultation on the Review of the Packaging and Packaging Waste Directive Position Paper (December 2020) TOMRA is a leading provider of sensor-based solutions for optimal resource productivity. We are the market leader in sorting solutions for the recycling industry as well as reverse vending machines. We welcome many of the policy measures proposed by the European Commission in the public consultation on the revision of the Packaging and Packaging Waste Directive 94/62/EC (PPWD). This paper aims to contribute to the public consultation and highlights some of the key measures we believe are crucial to achieve the goals of the PPWD revision and transition to a circular economy.

…the key measures we believe are crucial to achieve the goals of the PPWD revision and transition to a circular economy. 1) Clarification of the term ‘recyclable’ The term ‘recyclable’ should be further clarified in order to avoid divergent interpretations and achieve the recycling targets. We support the Commission’s goal for all packaging to be reusable or recyclable by 2030, however in order to be able to achieve this objective, we need a clear definition of the term ‘recyclable’ to be set at the EU level. We believe that this definition should entail a combination of policy measures proposed by the Commission in the public consultation, including the use of recycling rate threshold and qualitative statements and design for recycling standards, ensuring that packaging is recyclable from both technical and practical/economic perspective.

…for recycling standards, ensuring that packaging is recyclable from both technical and practical/economic perspective. 2) Mandatory sorting prior to incineration and landfill to recycling targets Today, many valuable packaging materials that are recyclable end up in incineration or landfill. In order to extract these recyclable materials such as plastics and aluminium before they end up in incineration or landfill, we would suggest to put in place a requirement for mandatory sorting prior to incineration and landfill, which will also help reach the recycling targets. Without such mandatory sorting obligation it seems almost impossible that the member states reach the EU recycling targets.

…such mandatory sorting obligation it seems almost impossible that the member states reach the EU recycling targets. 3) Design for recycling with green and red lists and digital watermarks Design is key for improving waste collection, sorting and recycling. Currently, the essential requirements set in PPWD are too vague and not enforceable. Therefore, in order to improve sorting and recycling, new policy measures should be set as proposed by the Commission in the public consultation, such as requirements on the reduction of polymers used in packaging and on reducing the complexity of packaging materials, promoting mono-materials and mono-layers where possible. Furthermore, positive (green) and negative (red) lists should be established for packaging types and materials that facilitate and hinder recycling. In addition, the Commission should promote novel and groundbreaking technologies…

…technologies such as digital watermarking, which can lead to significant improvements in sorting and recycling. 4) Recycled content targets and promotion of deposit-return schemes We believe that setting recycled content targets for all packaging materials is one of the key measures to stimulate recycling and ensure a well functioning market for secondary raw materials and related climate and environmental benefits as recognized in the European Plastics Strategy and many other reports. Deposit-return schemes for certain types of packaging (in particular beverage packaging) have proven to be an effective instrument leading to very high collection and recycling rates. The Ref. Ares(2021)106946 - 06/01/2021 recycled content regulation in the SUPD is a very good step in this direction and shows first effects already. Hence, this mechanism should be extended to all packaging materials.…

…to allow recycled plastics beyond PET to be used in food contact materials and ensure the uptake of recycled materials. 5) Clarification of chemical recycling and its role in the EU waste hierarchy in relation to mechanical recycling Chemical recycling is still in initial stages of development and requires further research to prove its viability, in particular on its environmental impacts, as identified by the Commission as well as in a recent report of CHEM Trust1. Promoting chemical recycling without knowing all its impacts can thus be detrimental for mechanical recycling and can hinder circular economy. In this regard, EU legislation should clearly differentiate between mechanical and chemical recycling, in particular in view of setting recycled content targets. Mechanical recycling should be prioritised over chemical recycling and should be placed above chemical recycling in the EU…

…also help ensure that investments are indeed made into a circular economy without unwanted environmental consequences. 6) Mandatory reuse targets and other measures to promote reusable packaging Reusable packaging should be promoted as per the EU waste hierarchy by setting mandatory reuse targets, as proposed by the Commission in the public consultation, such as refill quotas for beverages and other items, mandatory reusable transport packaging and country level taxes on single-use packaging. In addition, deposit-return schemes can be an efficient instrument for increasing the uptake of reusable packaging. 1 https://chemtrust.org/chemical-recycling/ Contact person: Wolfgang Ringel Senior Vice President Governmental Affairs Phone: + 49 2173 4990 140 Mobile: + 49 175 596 8145 E-Mail: [email protected]

originalus šaltinis (PDF) ↗