The European Steel Association

April 2023 PACKAGING AND PACKAGING WASTE REGULATION (PPWR) proposal COM(2022)0677 position PAPER steel for packaging sector APEAL, representing the steel for packaging sector, fully supports Commission’s objective that all packaging on the EU market be reusable or recyclable in an economically viable way by 2030, as stipulated by the Green Deal and the Circular Economy Action Plan (CEAP) 2.0. Our sector welcomes the general approach taken by the Commission but believes that more is to be done to fully close the circular loop. Therefore, our sector has prepared a set of recommendations and amendments to improve the draft Packaging and Packaging Waste Regulation. Executive Summary

…set of recommendations and amendments to improve the draft Packaging and Packaging Waste Regulation. Executive Summary 1. Criteria for recyclable packaging: The current Commission proposal is a step in the right direction. However, to fully close the circular loop the steel for packaging sector recommends: a) Stricter qualitative criteria to label packaging as ‘recyclable’. b) The introduction of packaging recyclability performance classes or ‘grades’ for each packaging unit put on the market is timely and necessary. Non-recyclable packaging should be gradually phased out. Best performers should be rewarded via eco- modulation of EPR fees and by a higher recyclability performance grade. c) Packaging should be ‘recycled at scale’ by 2030 covering at least 90% of the Union’s population and applied in 2/3rd of the Member States

‘recycled at scale’ by 2030 covering at least 90% of the Union’s population and applied in 2/3rd of the Member States 2. Recycled content: The steel for packaging sector supports the current Commission proposal that recycled content targets should only apply to materials with a low demand and uptake of recyclates. 3. Prevention of packaging waste: Waste reduction targets should be set for each of the specific materials contained in packaging waste: plastic, wood, ferrous metals, aluminium and paper/cardboard. 4. Transport packaging: Steel pails, drums, canisters and kegs are sales packaging and not transport packaging. Consequently, they should not be subject to the re-use targets set for transport packaging.

…not transport packaging. Consequently, they should not be subject to the re-use targets set for transport packaging. 5. Legal instrument and legal base: APEAL supports the choice for a Regulation and a full ‘internal market legal base’ for the Packaging and Packaging Waste Regulation (article 114 TFEU). 6. Phase out landfilling of packaging waste: The steel for packaging sector believes that the review of the PPWR should be complemented by a review of the Landfill Directive 99/31/EC, aiming at accelerating the phase-out of landfill of packaging waste. Ref. Ares(2023)2878088 - 24/04/2023 2/6 1. Criteria for recyclable packaging (article 3, 6 and Table 2 Annex II): Packaging put on the market should be designed for recycling. Packaging plays an essential role in protecting and preserving resources such as food and reducing waste.

…recycling. Packaging plays an essential role in protecting and preserving resources such as food and reducing waste. But the value of this role can be obscured by the impact of poor recyclability and ineffective recycling. a) Article 6, paragraph 2 subparagraph 1 - point d: APEAL believes that Packaging shall be considered recyclable when it (a) it is designed for recycling, (b) it is effectively and efficiently separately collected c) it is sorted into defined waste streams without affecting the recyclability of other waste streams and (d) it can be recycled multiple times so that the resulting secondary raw materials retains its main material properties and is of sufficient quality to substitute the primary raw materials. Packaging materials should not be downcycled or recycled just once. They should have the ability to be recycled multiple times and stay in a permanent material loop.

…recycled just once. They should have the ability to be recycled multiple times and stay in a permanent material loop. Products that are produced from such materials and are properly collected and processed at their end of life, become the raw material for new and endless production loops.

…properly collected and processed at their end of life, become the raw material for new and endless production loops. This is in line with the European Parliament resolution of 10 February 2021 on the New Circular Economy Action Plan (2020/2077(INI)), paragraph 39: “…stresses the need to increase the availability and quality of recyclates, focusing on the ability of a material to retain its inherent properties after recycling, and its ability to replace primary raw materials in future applications; in this context underlines the need to stimulate both increased recyclability in product design and measures such as effective separate collection…” b) Article 3, point 32 and article 6, paragraph 2 subparagraph 1 - point d: the current PPWR proposal defines ‘recycled at scale’ as follows: “means that the packaging needs to be collected, sorted and recycled through installed state-of- the-art…

…state-of- the-art infrastructure and processes, covering at least 75 % of the Union’s population by 01.01.2035”. The Impact Assessment carried out by the Commission does not clarify what the rationale is behind the 75% threshold. This could mean that the objective is met if just the 8 largest Member States, in terms of population, ‘recycle at scale’. APEAL believes that the definition of ‘recycled at scale’ should be reviewed. In order to ensure that the Regulation is effectively implemented at EU-level, the threshold should be increased to 90% of the Union population and at least 2/3 of the Member States. Article 6 – paragraph 3: Moreover, our sector believes that all criteria listed in Article 6, paragraph 2 subparagraph 1 i.e. (a), (b), (c), (d) and (e) determining what is ‘recyclable packaging’ are to be met by 01.01.2030.

…subparagraph 1 i.e. (a), (b), (c), (d) and (e) determining what is ‘recyclable packaging’ are to be met by 01.01.2030. This is in line with the European Commission’s self- proclaimed ambition to ensure that all packaging placed on the EU market shall be reusable or recyclable in an economically viable way by 2030. If a packaging is not ‘recycled at scale’ by 2030 it should not be considered as ‘recyclable’. 3/6 c) Article 6 – paragraph 3 and Table 2 of Annex II: APEAL fully supports the introduction of a set of so-called ‘packaging recyclability performance grades’. To ensure a level-playing field, these performances grades should apply to all packaging types and materials put on the market. The introduction of a performance grading system is timely and indispensable to ensure the transition to a true EU circular economy.

…of a performance grading system is timely and indispensable to ensure the transition to a true EU circular economy. Depending on its recyclability, packaging should be awarded a grade ranging from A to E, whereby the A-grade is the best-performer and E the worst. When labelled as E, the packaging format would have to be phased out by 1 January

…the best-performer and E the worst. When labelled as E, the packaging format would have to be phased out by 1 January 2030. (*) in terms of weight of the unit of packaging APEAL suggests introducing an explanatory text for each of the performance grades comparable to what has been suggested in the PPWR Impact Assessment: - For grade A the packaging should be able to be recycled multiples times and is fully compatible with the design for recycling criteria. The generated secondary raw material is of comparable quality to feed a closed material loop scheme. - For grade B, the packaging may have some minor recyclability issues that slightly affect the quality of the generated secondary raw material. However, the majority of the generated secondary raw material from this packaging can still potentially feed a closed material loop. - For grades C, D and E the wording can be found in the…

…and have the lowest EPR-fees, whereas packaging under grade E should be penalised and have the highest EPR-fees. 2. Recycled content should apply to packaging with a low uptake of recyclates (article 7): Article 7: APEAL supports the current Commission proposal that recycled content targets should only apply to materials with a low demand and uptake of recyclates. Steel packaging put on the market is being collected, sorted and recycled, at a very high recycling rate, reaching 85,5% in 2020. It is used to substitute the use of primary raw material in a wide range of steel products, including, but not limited to, packaging. A ≥95% B ≥90% C ≥80% D ≥70% E <70% Packaging recyclability perfomance grade Score of compliance with Design for Recycling (DfR) criteria of a unit of packaging(*) 4/6 Disrupting a well-established and a well-functioning material-based circular loop by setting a…

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POSITION PAPER – PPWD IMPACT ASSESSMENT EUROFER AISBL • Avenue de Cortenbergh, 172 • B-1000 Brussels • Belgium +32 3 738 79 20 • [email protected] • www.eurofer.eu • EU Transparency Register: ID 93038071152-83 REVIEW OF THE REQUIREMENTS FOR PACKAGING AND OTHER MEASURES TO PREVENT PACKAGING WASTE: COMMENTS TO THE DOCUMENT ARES(2020)3041578 “INCEPTION IMPACT ASSESSMENT” INTRODUCTION The European Steel Association – EUROFER- welcomes the work done so far by the EU Commission to reduce packaging waste, promote recycling and to analyse potential packaging waste prevention measures. The Packaging and Packaging Waste Directive (PPWD) actively worked in the past to reduce the negative impacts of packaging on the environment.

Waste Directive (PPWD) actively worked in the past to reduce the negative impacts of packaging on the environment. But now a review is needed in order to make it aligned with the goals of the European Green Deal (GD) and of the new Circular Economy Action Plan (CEAP) towards waste prevention, design for re-use of and recyclability of packaging, inter alia, by reducing the complexity of packaging. This paper wants to present comments and opinions of the EU steel sector concerning packaging products and in relation to: (1) waste generation; (2) weight & recyclability; (3) products & sustainability; (4) end-of-life & recycling; (5) appropriate measures in relation to the Impact Assessment. Packaging Waste generation During the last two decades, the generation of packaging waste (PW) continued to increase due to demographic changes, market trends and packaging design.

…of packaging waste (PW) continued to increase due to demographic changes, market trends and packaging design. It should be highlighted that the share of PW going to landfill or incineration decreased and were limited to certain packaging types. This means that the packaging material staying in the loop increased, allowing the generation of secondary raw materials and substituting thus primary raw materials. However, analysing the different packaging materials and their end-of-life fate, it can be identified that the fraction of materials exiting the loop (landfilling and incineration) are majorly composed by: - packaging materials that lose their inherent properties after their recycling, and - packaging materials that are composed by multiple parts that cannot be separated and thus recycled.

…recycling, and - packaging materials that are composed by multiple parts that cannot be separated and thus recycled. On the contrary, materials that preserve their inherent properties after many recycling processes (i.e. multiple recyclable and theoretically infinitely recyclable1), like all steel products, are returned to the material cycle at the end of their life cycle and help to replace natural primary resources. For instance, steel for packaging (steel and tinplate) showed a very high recycling rate within the EU market, notwithstanding the separate collection schemes across EU MSs have margins of improvement which can be small or very large according to the MS. Therefore, a larger use of materials with such characteristics, called ‘permanent materials’2, will ensure a continuous increasing of the PW recovered and recycled.

…characteristics, called ‘permanent materials’2, will ensure a continuous increasing of the PW recovered and recycled. Light weighting & recyclability Nowadays, due to the actual EU goals imposed by the GD and new CEAP – e.g. design for recycling, reducing complexity of packaging and re-use –, it makes sense to support the use of 1 This kind of material, thanks to their characteristics, can be recycled again and again without losing their inherent properties (multiple recycling). Moreover, thanks to the existence of a material stewardship (mature recycling value chain), they are collected, treated and recycled. This type of materials can considered as permanently available to society and industry needs. 2 “A material is defined as permanent if its inherent properties do not change during use and through solid-liquid transformation, it can revert to its initial state.

…properties do not change during use and through solid-liquid transformation, it can revert to its initial state. This is the case when the material consists of basic components, which are either chemical elements or robust chemical compounds, making repeated use and recycling possible without change of inherent material properties”, report “Permanent Material a scientific background” prepared by Carbotech AG, Basel Swiss, 2014. Ref. Ares(2020)4150330 - 06/08/2020 POSITION PAPER – PPWD IMPACT ASSESSMENT 2 multiple recyclable (permanent) materials, whose properties and performance can be properly designed to satisfy final use requirements. The packaging design has always sought in the past decades to reduce the weight of packaging solutions for being more resource efficient, for reducing waste and impacts and for easing transport and logistic.

…solutions for being more resource efficient, for reducing waste and impacts and for easing transport and logistic. Therefore, recyclability and weight reduction should not be in contrast but optimised and integrated, in order to reduce trade-offs. For instance, steel packaging solutions (e.g. cans) have been engineered along the decades in order to reduce their thickness and improving their performance. As illustrative example, ‘3-piece food cans’ decreased their thickness by 50% from 1970s to 2010s3. During a similar timeframe, steel cans showed a progressive and continuous improvement of their recycling rates: steel cans recycling rates passed from around 25% in 1991 to 82.5% in 2018. It is thus possible through a proper design and material choice to integrate recyclability and weight optimisation.

It is thus possible through a proper design and material choice to integrate recyclability and weight optimisation. Reduction of the trade-offs and the optimisation of design options towards multiple objectives is at the core of the circular economy. Packaging products & sustainability When developing potential measures to avoid PW, it should also be pointed out that packaging is always to be regarded as a mean in order to bring the goods to consumers, safely and without loss. Packaging indeed has the great potential to reduce losses (including food losses), ensure food safety, extend the shelf life of products and optimize distribution and storage. Moreover, steel packaging for chemical-technical filling goods such as barrels also help to protect the environment from the filling goods, since they meet strict safety requirements and safe transport is not possible without them.

…from the filling goods, since they meet strict safety requirements and safe transport is not possible without them. Thus, the design of a packaging product should not be carried out in isolation from its content; the couple packaging-packed product should be considered. Therefore, according to the specific situation recyclable, disposable or re-usable solutions make sense. For instance, during this Covid- crisis, not solved yet, a meaningful juxtaposition of these packaging options works well. For instance, reusable options are useful only if it makes ecologically, sanitary and economically sense; disposable options are mandatory for destroying possible contamination; recyclable options can be safely used when the recycling process, such as for steel packaging, occurs at very high temperature destroying thus every possible source of contamination.

…such as for steel packaging, occurs at very high temperature destroying thus every possible source of contamination. The assessment of the impacts associated to packaging is a complex process that requires the industry involvement and experience. Firstly, this should analyse all the relevant effects (impacts) to the environment, targeting an optimal outcome for which the trade-offs among the different impacts are all minimised (e.g. greenhouse gas emissions, resource efficiency, pollution of soil, air and water or health protection). Then, this assessment should follow a holistic approach in which sustainability is at the core of the process: environmental impacts; material stewardship and operating conditions; expected performance in conjunction with the contained product; waste management.

…stewardship and operating conditions; expected performance in conjunction with the contained product; waste management. It is important to evaluate the sustainability of the different packaging options; but, for ensuring an optimal outcome, industry led and voluntary LCA integrated with sustainable principles should be promoted and supported due to the complexity of the task. Packaging End-of-life & recycling When defining and analysing potential PW prevention measures, it is worth to bear in mind the wider scope of waste prevention in general: to ensure recyclability and re-usability of the packaging solutions, aiming at ‘nothing goes waste’4. In particular, as well as to incentivise the use of permanent materials, it is fundamental to strengthen and optimise the recycling value chains where needed.

…the use of permanent materials, it is fundamental to strengthen and optimise the recycling value chains where needed. For instance, promoting optimized separate collection, both from household PW streams and industrial commercial ones, can ensure a cleaner material recovered 3 ESTEP-EUROFER Workshop, 19.10.2016, Brussels – Presentation by Thyssen Krupp “Steel Packaging Solutions for Europe” 4 ‘Nothing goes waste’ is associated to the outcome that waste disposal, landfill or incineration is not a viable and attractive option and all PW materials find their way back into the economic loop. POSITION PAPER – PPWD IMPACT ASSESSMENT 3 from waste streams. In this way, a high-quality input can be ensured to the recycling operations, generating increased recycling rates and enabling more resource efficiency.

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