Sappi Europe SA

TVA/BTW BE 0449.654.386 - RPM/RPR Bruxelles/Brussel Ensuring a Sustainable Future for Packaging: Sappi's Perspective on the PPWR Proposal ➢ Increasing the Role of Innovation in Achieving the EU Environmental Objectives by Innovation Principle Check As the EU considers the Packaging and Packaging Waste Regulation (PPWR), it is crucial to ensure that proposals align with both the Green Industrialisation Plan and the Net Zero Industry Act. These initiatives drive research and innovation towards ecological objectives while maintaining European industry competitiveness. To achieve this balance, proposals must be evaluated based on the Innovation Principle, not solely on their environmental impact. It is especially critical to consider economic factors, given that European companies operate in both the Single and global markets.

…critical to consider economic factors, given that European companies operate in both the Single and global markets. Proposals must carefully balance the cost of supply and production to ensure that achieving ecological targets does not come at the expense of economic sustainability. Thus, it is essential to scrutinize whether the PPWR proposal achieves this crucial balance. ➢ Considering National Progress and Different Reuse and Recycling Markets & Moving Back to a Directive Reuse and recycling markets across the EU Member States have significant variations in their conditions. Therefore, it is crucial to consider national specificities and different approaches to packaging waste while formulating the PPWR. Such considerations are essential to avoid any potential setbacks and ensure that the already established national progress in waste management is not undermined.

…any potential setbacks and ensure that the already established national progress in waste management is not undermined. Sappi Europe Sappi, a leading provider of renewable fibre-based products, supports the goals of the Packaging and Packaging Waste Regulation (PPWR) proposal. However, we offer the following suggestions to improve the proposal: ➢ We recommend that the proposal be evaluated against the Innovation Principle to increase the role of innovation. ➢ We advise the consideration of national conditions for re-use and recycling while maintaining the format of a directive, which would provide greater flexibility for Member States to adopt the measures. ➢ We suggest placing the emphasis on reuse and recycling as complementary rather than mutually exclusive options.

➢ We suggest placing the emphasis on reuse and recycling as complementary rather than mutually exclusive options. ➢ We recommend avoiding the use of mandatory recycled content requirements for products that already have a well-functioning market with high recycling rates. ➢ We call for transparency and involvement of the Industry in drafting secondary legislation. By implementing these suggestions, we believe the PPWR will be better positioned to achieve its ecological objectives while maintaining competitiveness and innovation in the industry. Ref. Ares(2023)2893265 - 24/04/2023 Page 2 of 3 Given this context, adopting a directive instead of a regulation as the PPWR instrument seems preferable. A directive would provide greater flexibility for the Member States to adapt the proposed measures to their specific contexts and incorporate existing practices.

…for the Member States to adapt the proposed measures to their specific contexts and incorporate existing practices. This would enhance the likelihood of successful implementation and contribute to achieving the environmental objectives of the PPWR. ➢ Placing Reuse and Recycling as Complementary Solutions The PPWR's preference for reuse over recycling risks marginalizing fibre-based packaging, as it may replace renewable and recyclable packaging types with fossil-based alternatives. Fibre-based packaging is crucial for the circular economy, with an 81.6% recycling rate in Europe, owing to a well-functioning market for fibre-based secondary raw materials. We recognise that recyclable and reusable options are complementary towards a common goal of achieving a circular economy in the EU.

…that recyclable and reusable options are complementary towards a common goal of achieving a circular economy in the EU. Policy decisions (including reuse targets) should be founded on an evidence-based evaluation of the lifecycle impact of packaging, its system, and the evaluation of the economic and technological implications, and consequences for human health and food security. Importantly, fibre-based packaging has a critical function in protecting and preserving goods throughout the value chain, extending food lifespan,1 and preventing product and food waste2 which contributes to resource efficiency.3 Crucially, it safeguards consumer safety in logistics and on the shelf. In addition, it provides nutritional information and tells consumers how to store and prepare food safely.

…the shelf. In addition, it provides nutritional information and tells consumers how to store and prepare food safely. Paper-based products, particularly, contribute to expanding the shelf-life period of products often from hours to many days.4 Furthermore, packaging maintains the quality of sensitive products, such as milk and juices, which provide consumers with essential vitamins and nutrients. Therefore, all measures should be based on a lifecycle impact assessment of the specific application. Single-use, recyclable fibre-based products should not be penalized, and a case-by-case approach considering each material stream's recycling and environmental performance would help prevent unintended consequences of the reuse approach. In some sectors (e.g., in food service systems or logistic systems) recyclable fibre packaging has a better environmental performance than reusable options5.

…systems or logistic systems) recyclable fibre packaging has a better environmental performance than reusable options5. Moreover, optimal solutions should be backed by data that proves desirable economic, environmental, and social impacts while enabling industry-led product innovation. The PPWR should not hamper the progress made by the industry in investing in product innovations and recycling infrastructure. Reuse and recycling should be complementary, with an emphasis on the most suitable approach based on the specific application. ➢ Avoiding Mandatory Recycled Content Requirements for Products that already Have a Well- functioning Market with High Recycling Rates, such as Fibre-based Packaging Setting recycled content thresholds for fibre-based materials risks distorting a well-functioning market with high recycling rates.

…content thresholds for fibre-based materials risks distorting a well-functioning market with high recycling rates. Mandatory thresholds would compromise food safety and potentially lead to an increase overall in packaging mass. They would also limit the use of fibre-based packaging for food contact applications. With the fibre-based industry actively pioneering innovative fibre-based packaging solutions that offer barrier 1 Packaging's Role in Minimizing Food Loss and Waste Across the Supply Chain is well documented as in the often-cited publication in the International Journal Packaging Technology and Science by Verghese, Lewis, Lockrey and Williams.

…publication in the International Journal Packaging Technology and Science by Verghese, Lewis, Lockrey and Williams. 2 Helén Williams, Annika Lindström, Jakob Trischler, Fredrik Wikström, Zane Rowe, avoiding food becoming waste in households – The role of packaging in consumers’ practices across different food categories, Journal of Cleaner Production, Volume 265, 2020 3 Packagingdigest.com – How to Balance Food Waste Versus Packaging Waste 4 Siroli L, Patrignani F, Serrazanetti DI, Chiavari C, Benevelli M, Grazia L and Lanciotti R (2017) Survival of Spoilage and Pathogenic Microorganisms on Cardboard and Plastic Packaging Materials. Front. Microbiol.

Survival of Spoilage and Pathogenic Microorganisms on Cardboard and Plastic Packaging Materials. Front. Microbiol. 8:2606 5 EPPA, Jan 2021, “Single-Use Vs Multiple-Use: Using Science to Challenge the Misconceptions” Executive Summary of Ramboll LCA study Page 3 of 3 functionalities and that are recycled at scale, mandatory recycled content requirements should be avoided for fibre-based packaging. ➢ Involving the Industry in Drafting Secondary Legislation and Providing the Necessary Clarity to Encourage Investment Clarity regarding the content and preparation of the upcoming Delegated Acts is crucial for the industry to adapt and comply with the new packaging and packaging waste rules. As such, it is important that the EU takes into account feedback from industry stakeholders, such as Sappi, who are developing expert-led solutions.

…the EU takes into account feedback from industry stakeholders, such as Sappi, who are developing expert-led solutions. When drafting the Delegated Acts, it is essential to ensure that the regulations support rather than harm the industry and its competitiveness. We welcome the proposed, actionable and forward-looking, definition of recyclability applicable to all packaging. However, the recyclability of the packaging must be assessed while taking into account material specificities via Design for Recycling (DfR) guidelines which provide technically sound guidance for recycling. The DfR should be based on expert judgment and consultation with targeted stakeholders, including recyclers, waste management operators, and technology providers.

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