UPM-Kymmene Oyj

UPM-Kymmene Corporation Tel. +358204 15 111 Domicile Helsinki Fax +358204 15 110 Business identity code 1041090-0 Alvar Aallon katu 1 www.upm.com PO Box 380 VAT No FI10410900 FI-00101 Helsinki Finland 1 (2) 2 March 2023 UPM position on Commission proposal for a Packaging and Packaging Waste Regulation UPM is one of the leading producers of sustainable packaging materials in the EU. Our renewable raw materials - pulp, wood-based naphtha and renewable mono ethylene glycol (MEG) – are used to produce recyclable fibre-based packaging and renewable plastics. Food and a myriad of consumer goods are packed safely in UPM’s flexible paper packaging materials. We also create high-performing labelling materials for branding and promotion as well as informational labels and labels with functionality.

…labelling materials for branding and promotion as well as informational labels and labels with functionality. Packaging and Packaging Waste Regulation (PPWR) proposal is a step into the right direction to boost circular economy in Europe and to tackle the alarmingly fast growth of packaging waste globally. With some amendments, PPWR can create opportunities for the European forerunners in the field of sustainable packaging materials. Positive elements in the proposal The proposal aims to harmonise the differing requirements set for packaging in Europe and limit the possibilities of Member States to make their own regulatory demands e.g. in recycling or labelling. This is an extremely positive development and will simplify the operating environment of companies selling their goods in multiple European markets.

…development and will simplify the operating environment of companies selling their goods in multiple European markets. Currently, an increasing number of EU Member States are setting different over-lapping national requirements which increases administrative costs and weakens the internal market. We strongly support the proposal’s approach to demand all packaging to be recyclable. Materials need to be recovered as much as possible from all packaging materials and types, including also reusable packaging. UPM welcomes the proposal’s demand for separate collection of all packaging waste. Separate collection is the key to greatly increase recycling rates of all packaging materials and the quality of recyclate. Today, the greatest barrier to increase paper and board recycling rates is the divergence among collection systems for paper and board at source.

…to increase paper and board recycling rates is the divergence among collection systems for paper and board at source. Paper and board should be collected separately from residual waste as well as from other recyclables such as plastic, metal or glass. Commission’s decision to propose Design for Recycling guidelines instead of detailed restrictions and bans of packaging characteristics gives possibilities for European companies to develop innovative and sustainable packaging also in the future. Innovation potential must not be hindered by dictating technical solutions in regulation. It is crucial to find a cooperative method, which would guarantee the strong participation of the industry in the preparation of the delegated acts. CEN should be commissioned to work on standards related to recyclability and recycling at scale.

…of the delegated acts. CEN should be commissioned to work on standards related to recyclability and recycling at scale. Industry’s efforts to boost recycling rates of different materials (like in 4evergreen project for fibre-based packaging) would provide an already well-developed basis for developing Design for Recycling guidelines. Ref. Ares(2023)1524956 - 02/03/2023 2 (2) How could the proposal be made better during the EU legislative process? UPM proposes that recycled content is required only from packaging consisting predominantly of plastics to make the requirement effective and possible to implement. By far most of the plastic in packaging is used in packaging made entirely of plastic.

…and possible to implement. By far most of the plastic in packaging is used in packaging made entirely of plastic. Extending the scope of mandatory recycled content to all plastic parts in all packaging doesn’t significantly boost the market demand of recycled plastic but would create unnecessary bureaucracy, technical problems, and unnecessary costs for the whole packaging value-chain. In fibre-based packaging, plastics are used especially in food contact to form a protective barrier against moisture and fat. Barriers form a very small part of the whole packaging but have a central function in food safety and hygiene. Adding recycled plastic to the protective coating is technically very difficult, if not impossible, and would require a lot of recycled plastic from highly energy-consuming chemical recycling.

…if not impossible, and would require a lot of recycled plastic from highly energy-consuming chemical recycling. Bio-based content should be considered as an equivalent option to comply with recycled content requirements in plastics. Bioplastics made of sustainable biomass are already available. These materials are chemically identical to their fossil counterparts, and they allow setting higher recycled or biobased content targets in all categories including contact sensitive packaging. As chemical recycling of plastics is still in its early stage, reducing use of fossil materials in contact sensitive plastic packaging would be significantly speeded up by allowing both recycled and biobased be included in the targets. Re-use and recycling are complementary solutions to achieve circularity. Therefore, recycling should have an equal position in legislation with reuse.

…solutions to achieve circularity. Therefore, recycling should have an equal position in legislation with reuse. Packaging achieving 90% recycling rate by 2030 should be exempted from the reuse obligation. Proposed re-use targets must be re-evaluated based on independent science-based proof to assess whether re-use is a feasible solution in each use case. Recyclable single-use packaging is still the most feasible and environmentally sound solution in many applications, such as industry’s transport packaging. Industry has invested more and more in new technologies and achieved very high recycling rate (> 80%) of paper and cardboard packaging in the EU. If adopted, the reuse targets provided in the Commission proposal will disrupt the highly performant recycling system that the paper and board industry has invested in and committed to further improve.

…highly performant recycling system that the paper and board industry has invested in and committed to further improve. Together with the entire value chain, fibre-based packaging industry has voluntarily set a 90% recycling target by 2030.

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