Kemira Oyj

Position Paper [Nro] 1 (4) Kemira Public March 09, 2023 KEMIRA OYJ P.O.Box 330 (Energiakatu 4) FI-00101 Helsinki Finland www.kemira.com Europe, Middle-East and Africa Tel +358 10 8611 Asia-Pacific Tel +86 21 6037 5999 Americas North America Tel +1 770 436 1542 South America Tel +55 11 2189 4900 KEMIRA’S POSITION REVISION OF THE EU REGULATION ON PACKAGING AND PACKAGING WASTE (PPWR) With the proposal for the revision of the Packaging and Packaging Waste Regulation (PPWR), the European Commission aims to harmonize national measures on packaging and the management of packaging waste, provide a high level of environmental protection and ensure the good functioning of the internal market. Kemira supports this EU initiative, with Kemira’s business already today contributing to the development of more sustainable and better recyclable fibre-based packaging.

…business already today contributing to the development of more sustainable and better recyclable fibre-based packaging. Fibre-based materials, such as paper and paperboard, form the core of renewable and recyclable packaging. Kemira’s expertise in this field makes it possible reduce the amount of used plastic by giving fibre-based packaging the required properties and functionalities, such as strength, water and oil resistance as well as ensuring the hygienic and safe use in food packaging. With its average recycling rate over 80% across the EU, fibre-based packaging is the most recycled packaging type on the market.1 The high rate is enabled by the well-functioning extensive infrastructure already in place and the inherently easy recyclability of fibre-based materials.

…extensive infrastructure already in place and the inherently easy recyclability of fibre-based materials. Promoting the use of fibre-based packaging supports the transition to a circular economy and the sustainable use of natural resources. However, Kemira is concerned that the most successful recycling system in the EU could unduly be put at risk by the changes introduced by the PPWR. Through measures such as the mandatory re- use targets, many users, such as the restaurant and food industry, are likely to switch to plastics to replace their fibre-based products. Consequently, the proposal could in essence drive mass replacement of renewable materials with unsustainable fossil raw materials. The reuse targets may also pose challenges to food safety and transport packaging. Therefore, we call EU regulators to consider the following aspects:

…challenges to food safety and transport packaging. Therefore, we call EU regulators to consider the following aspects: 1. RECYCLING NEEDS TO BE EQUALLY VALUED TO REUSE 2. RESTRICTIONS ON THE USE OF PACKAGING FORMATS AND MANDATORY REUSE TARGETS NEED TO CONSIDER FOOD SAFETY ASPECTS AND FULL LIFE CYCLE THINKING a. Reuse in food service packaging can put food safety at risk b. Paper recycling can be equal to reuse considering their overall environmental impacts c. Mandatory reusability of transport packaging could risk the well-functioning logistical system, which is at the base of all modern commerce 3. RECYCLED PLASTIC CONTENT TARGETS ONLY TO ALL-PLASTIC PACKAGING

…system, which is at the base of all modern commerce 3. RECYCLED PLASTIC CONTENT TARGETS ONLY TO ALL-PLASTIC PACKAGING 4. A WIDE VARIETY OF RENEWABLE CARBON FEEDSTOCK SHOULD BE INCLUDED TO THE RECYCLED PLASTIC CONTENT TARGETS 1 Eurostat, Recycling rates for packaging waste 2009-2020, https://ec.europa.eu/eurostat/databrowser/view/ten00063/default/table?lang=en Ref. Ares(2023)2350605 - 31/03/2023 Position Paper [Nro] 2 (4) Kemira Public March 09, 2023 KEMIRA OYJ P.O.Box 330 (Energiakatu 4) FI-00101 Helsinki Finland www.kemira.com Europe, Middle-East and Africa Tel +358 10 8611 Asia-Pacific Tel +86 21 6037 5999 Americas North America Tel +1 770 436 1542 South America Tel +55 11 2189 4900 1.

…8611 Asia-Pacific Tel +86 21 6037 5999 Americas North America Tel +1 770 436 1542 South America Tel +55 11 2189 4900 1. FIBRE-BASED PACKAGING RECYCLING NEEDS TO BE EQUALLY VALUED AS REUSE EU waste policy is based on a concept known as the waste hierarchy, which lists the different options for managing waste from 'best' to 'worst' from an environmental perspective. On the top of the hierarchy are reuse and recycling. However, the Waste Framework Directive (WFD) also encourages the use of “…options that deliver the best overall environmental outcome. This may require specific waste streams departing from the hierarchy where this is justified by life cycle thinking on the overall impacts of the generation and management of such waste.” (Art.

…this is justified by life cycle thinking on the overall impacts of the generation and management of such waste.” (Art. 4, WFD) Therefore, the waste hierarchy should not be seen as a rigid prescription, particularly since different waste treatment methods can have different environmental impacts. In the PPWR, the Commission argues that it is necessary to introduce mandatory reuse targets for a number of packaging categories to reinforce the application of the waste hierarchy. However, the Commission’s reasoning, that “technically recyclable packaging is often not recycled because the processes needed …are not available in practice or not cost-efficient..” does not reflect the actual situation in Europe’s paper recycling industry. The EU already today has a very high recycling rate of paper and cardboard packaging.

…paper recycling industry. The EU already today has a very high recycling rate of paper and cardboard packaging. In 2019, 82% of paper and cardboard packaging was recycled (CEPI), whereas the recycling rates of plastic packaging waste accounts for only 38% in the EU (Eurostat). Also, the recyclability of fibre-based packaging is being developed even further through initiatives such as 4evergreen. Worryingly, the wrongly proposed rigid implementation of the EU waste hierarchy principles in the Commission’s draft proposal promotes further increasing the consumption of plastics predominantly produced from fossil feedstocks, which are overwhelmingly sourced from outside the EU. This will not only mean a drawback for EU’s climate ambitions but also an unjustified punishment for the European Paper Industry.

…only mean a drawback for EU’s climate ambitions but also an unjustified punishment for the European Paper Industry. As a further consequence, this clear regulatory push for plastics will hinder further European innovation in other, alternative packaging materials. Instead, Kemira calls for further innovation by setting targets, which are aligned with life cycle thinking and deliver the best environmental outcome. 2. RESTRICTED USE OF PACKAGE FORMATS AND MANDATORY REUSE TARGETS NEED TO CONSIDER FOOD SAFETY ASPECTS AND FULL LIFE CYCLE THINKING Reuse of packaging should only be considered where it is environmentally beneficial, safe for consumers, does not compromise food hygiene, is technically feasible, and where it makes economic sense. Hence, the best available and verifiable scientific analysis and life cycle assessments should be the basis of the PPWR’s approach to reuse. a.

…and verifiable scientific analysis and life cycle assessments should be the basis of the PPWR’s approach to reuse. a. Food safety and hygiene criteria should be at the heart of the PPWR. The mandatory reuse targets per packaging category proposed in the PPWR adds restrictions that could significantly hinder food safety, considering the proposed legislation is requesting to set up a wide-scale system that has not existed before. Single-use paper packaging protect consumers against food-borne illnesses, and they ensure the resilience of food supply chains against waste and disruption. Especially in context of the ongoing insecurity on the global food market, the EU should take all measures possible to ensure food is stored in ideal packaging in order to avoid food waste and thus also strengthening food security.

…to ensure food is stored in ideal packaging in order to avoid food waste and thus also strengthening food security. Position Paper [Nro] 3 (4) Kemira Public March 09, 2023 KEMIRA OYJ P.O.Box 330 (Energiakatu 4) FI-00101 Helsinki Finland www.kemira.com Europe, Middle-East and Africa Tel +358 10 8611 Asia-Pacific Tel +86 21 6037 5999 Americas North America Tel +1 770 436 1542 South America Tel +55 11 2189 4900 b. Paper recycling is environmentally friendly and should be seen as secondary raw material instead of waste. Reuse is not environmentally superior to paper recycling, but they should be seen as complementary measures. Products that are subject to consumption reduction measures under the Single Use Plastics Directive, such as cups for beverages and food containers, should not have further mandatory reuse requirements.

Directive, such as cups for beverages and food containers, should not have further mandatory reuse requirements. In the context of the Single-Use Plastics Directive, EU co-legislators have already agreed that for many of these products suitable alternatives are not yet readily available. Instead of bans, the revised PPWR should provide guidance for the development of recycling of single-use packaging. c. Transport packaging is another sector where fibre-based packaging plays an essential role. Containerboard is ideal for transportation due to its high recyclability rates, and it allows for flexibility for global use. The Commission’s proposal for a reuse targets up to 90% in 2040 for transport packaging will require a completely new market design for this type of packaging, whilst having almost no market experiences to refer to.

18 → 12

originalus šaltinis (PDF) ↗