Valmet Oyj

…1/8 March 22, 2023 Valmet Oyj, Keilasatama 5, FI-02150 Espoo, Finland, tel. +358 10 672 0000, www.valmet.com Domicile Helsinki, Finland, Business ID 2553019-8, VAT FI25530198 Valmet’s first views on the proposal for a packaging and packaging waste regulation COM(2022) 677 final Valmet welcomes the Commission’s proposal to update the EU packaging and packaging waste directive1. Valmet believes it can provide innovative solutions for a more sustainable packaging sector and looks forward to being a part of a greener future in the packaging value chain. Our first messages on the proposal are: Accuracy and Origin of Data • In the Impact Assessment (Part 1/2, page 6), the greenhouse gas emissions (GHG-emissions) of paper & board production are reported as 809 kg/ton. The figure is not given any source reference.

…of paper & board production are reported as 809 kg/ton. The figure is not given any source reference. Confederation of European Paper Industries (Cepi) reports in its official statistics for 20202, direct GHG- emissions as 0,29 ton/ton of paper & board and market pulp and indirect emissions 0,09 ton/ton. In total, these add up to 0,38 ton/ton i.e. 380 kg/ton. The European Federation of Corrugated Board Manufacturers (FEFCO) reports3 that in 2021, the carbon footprint of corrugated packaging was (including the manufacturing of board and conversion of board to final corrugated packaging) 491 kg/ton of package. There is a great deviation in the figure of 809 kg/ton of paper/board presented in the impact assessment document compared to transparently reported figures from Cepi and FEFCO.

…paper/board presented in the impact assessment document compared to transparently reported figures from Cepi and FEFCO. As reduction of GHG-emissions is one of the main goals in the EU environment policies and one of the main targets behind the proposal, the information used in key background documents should be transparent and open for review. In case the figure presented in the Impact Assessment document is used by the Commission to quantify the GHG-emission savings achieved as a result of the regulation, for fiber-based packaging, the reduction is based on Cepi and FEFCO reported figures, a grave overestimate. Recital, point (2) • The text generalizes the use of virgin materials and recycling in a way which gives a false picture on the use of several key materials used for packaging. The text should be amended to reflect reality (see proposal in annex).

…use of several key materials used for packaging. The text should be amended to reflect reality (see proposal in annex). 1 COM(2022)677 2 Cepi Key Statistics 2020 3 Fefco Press release 19.7.2022 Ref. Ares(2023)2121295 - 23/03/2023 2/8 March 22, 2023 Valmet Oyj, Keilasatama 5, FI-02150 Espoo, Finland, tel. +358 10 672 0000, www.valmet.com Domicile Helsinki, Finland, Business ID 2553019-8, VAT FI25530198 Art. 7 - Minimum recycled content in plastic packaging • The proposal on minimum recycled content in plastic packaging would give an impetus to a larger uptake and development of recycling of plastics, especially chemical recycling. However, research and development are still needed before the market has enough viable alternatives to choose from. Therefore, it would be useful to ensure that R&D and demonstration money will be made available for this purpose in the EU R&I framework.

…be useful to ensure that R&D and demonstration money will be made available for this purpose in the EU R&I framework. Demonstrations require considerable capital, so reducing the risk for commercial operators is necessary. • For the investments to take off, clarity about the use of a mass balance chain of custody method to calculate the recycled content of plastics in products is required. Article 22 - Restrictions on use of certain packaging formats • According to the proposal, economic operators shall not place on the market packaging in the formats and for the purposes listed in Annex V. This would de facto mean a ban on certain single use packaging, including fiber-based packaging. The measure would have strong negative implications for the sectors in question.

…including fiber-based packaging. The measure would have strong negative implications for the sectors in question. Unfortunately, we are unable to find solid scientific evidence in the proposal or its accompanying documents that would warrant such a ban. Any measure aimed at changing the market to this level should be backed with clear and trustworthy evidence, as is required by the Better Regulation agenda. Therefore, in the lack of proper evidence showing that reuse is a better option than recycling, we cannot support the proposal to impose restrictions on the use of certain packaging formats. Unless credible supporting evidence is presented, these restrictions should be deleted. Art. 26 - Reuse and refill targets • We support the application of the waste hierarchy also on packaging waste.

Art. 26 - Reuse and refill targets • We support the application of the waste hierarchy also on packaging waste. However, we wish highlight that the waste hierarchy is not meant to be applied as an absolute but as a principle leaving flexibility to consider the best overall environmental outcome4. Therefore, we have reservations on the proposed approach whereby strict reuse targets are set to different packaging groups on a Member State level. Any reuse targets should be indicative and set at an EU level. 4 2008/98/EC, Art. 4(2) 3/8 March 22, 2023 Valmet Oyj, Keilasatama 5, FI-02150 Espoo, Finland, tel. +358 10 672 0000, www.valmet.com Domicile Helsinki, Finland, Business ID 2553019-8, VAT FI25530198 o Reuse does not automatically bring climate or energy efficiency benefits. Reusable packaging is very often resource intensive and made of fossil-based materials.

…or energy efficiency benefits. Reusable packaging is very often resource intensive and made of fossil-based materials. In addition, reusable packaging requires significant amounts of energy and water for cleaning. From a life-cycle analysis perspective, fiber-based single-use items can be more beneficial for the climate and resource-efficient than reusable packaging.5, 6, 7 o In the case of reuse targets, it would also be necessary to recognize geographical differences (e.g., long transport distances) between the Member States. • Where reuse and refill are warranted, it is imperative to ensure adequate hygiene requirements for the packaging material. This applies to materials in contact with food and to other packaging materials. Therefore, we support the revision of the relevant CEN standards8 for reusable packaging.

…to other packaging materials. Therefore, we support the revision of the relevant CEN standards8 for reusable packaging. • In connection with transport packaging and e-commerce, there is a specific need to ensure that insects/insect eggs are destroyed in the packaging so that invasive species are not transmitted into new areas due to the reuse requirements. • Any reuse requirements should not lead to increased release of microplastics to the environment. • Packaging materials in use and transported to the EU from third countries that cannot be reused or sent back for reuse should as a priority be recycled. These packaging materials should not affect the reuse and refill or recycling targets as they are not originally placed on the EU market.

…should not affect the reuse and refill or recycling targets as they are not originally placed on the EU market. Article 47(10) - Rules on the calculation of the attainment of the recycling targets • The proposal says that Member States may take into account the recycling of metals separated after incineration of waste in proportion to the share of the packaging waste incinerated provided that the recycled metals meet certain 5 Ramboll: “Life cycle analysis highlights the environmental benefits of single-use paper-based Packaging” https://www.eppa-eu.org/scientific-facts/lca-studies-new.html 6 IFEU: “Comparative Life Cycle Assessment of Tetra Pak® carton packages and alternative packaging systems for beverages and liquid food on the European market” https://www.tetrapak.com/content/dam/tetrapak/publicweb/gb/en/sustainability/documents/2020-lca-tetra- pak-european-market.pdf 7 VTT…

Especially EN 13429 Packaging - Reuse, EN 13428 Packaging - Requirements specific to manufacturing and composition. Prevention by source reduction, EN 14327 Packaging - Requirements for the use of European Standards in the field of packaging and packaging waste, and EN 1343 Packaging - Requirements for packaging recoverable by material recycling 4/8 March 22, 2023 Valmet Oyj, Keilasatama 5, FI-02150 Espoo, Finland, tel. +358 10 672 0000, www.valmet.com Domicile Helsinki, Finland, Business ID 2553019-8, VAT FI25530198 quality criteria laid down in Commission Implementing Decision (EU) 2019/1004. In line with the Circular Economy, sorting should be maximized, so that only waste that has no other use is incinerated.

…line with the Circular Economy, sorting should be maximized, so that only waste that has no other use is incinerated. Allowing such an easily removable material as metals to go into incineration would mean that the sorting is not done properly and that the waste may include also other materials that could be recycled. Therefore, Member States should not consider metals separated after incineration to the recycling targets.

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