JDE Peet's · Companies & groups · NL
…1 JDE Peet’s N.V. — Oosterdoksstraat 80 — 1011 DK Amsterdam — The Netherlands — +31 (0)20 558 17 53 Chamber of Commerce number: 73160377 JACOBS DOUWE EGBERTS (JDE) PEET’S Position Paper on the proposal for a Regulation on Packaging and Packaging Waste (PPWR) Focus on Single Serve Units (SSUs) Jacobs Douwe Egbert’s (JDE) Peet’s JDE Peet’s is the world’s leading pure-play coffee and tea company. Headquartered in the Netherlands, we are proudly European, with a portfolio of over 50 brands including L’OR, Peet’s, Jacobs, Senseo, Tassimo, Douwe Egberts, Old Town, Super, Pickwick, and Moccona. JDE Peet’s and the circular economy JDE Peet’s is fully committed to reducing packaging material where possible and where packaging is absolutely required, we aim to provide consumers with responsibly packaged products and optimised end-of-life solutions.
…required, we aim to provide consumers with responsibly packaged products and optimised end-of-life solutions. Our efforts are guided by our vision for our packaging sustainability “A Planet Free of Packaging Waste”. By 2030, we will: Save 12.5% packaging grams per cup, Design 100% of our packaging to be reusable, recyclable or compostable, Save 12.5% CO2 grams per cup. Delivering against our packaging commitments requires significant technical development and effort across our entire organisation. In this regard, the proposed PPWR will have a major impact on our sector, and it is critical the legislation delivers a framework that enables truly circular solutions. JDE Peet’s key positions on the PPWR 1. Ensuring packaging circularity is critical in achieving the desired long-term environmental goals set out in the European Green Deal.
…circularity is critical in achieving the desired long-term environmental goals set out in the European Green Deal. 2. Aluminium and plastic Single Serve Units (SSUs)1 which are recyclable are circular. Requiring all SSUs to be compostable undermines the goal of eradicating packaging waste and promoting a circular economy. 3. A circular economy requires that recyclable (aluminium and plastic) packaging be permitted. Tea bags and filter coffee pads should remain industrially compostable. 4. The EPR fee relevant to SSUs should be based only on the weight of that part of the SSU which is packaging material. Packaging contents are not recyclable and so should not be used to calculate EPR. 5. Industrially compostable tea bags and filter coffee pads (as not recyclable) should not constitute “packaging” within the meaning of the proposed PPWR.
…and filter coffee pads (as not recyclable) should not constitute “packaging” within the meaning of the proposed PPWR. 6. Adoption of the current PPWR proposal would lead to significant economic impacts on operators across the supply chain (loss/negation of significant R&D investments; direct and indirect employment impact; disposal of c. 140 million perfectly functioning single serve machines; etc.). 1 A Single Serve Unit (SSU) is a method for coffee brewing that prepares only enough coffee for a single serving. Ref. Ares(2023)1528035 - 02/03/2023 2 JDE Peet’s N.V. — Oosterdoksstraat 80 — 1011 DK Amsterdam — The Netherlands — +31 (0)20 558 17 53 Chamber of Commerce number: 73160377 JDE Peet’s detailed position on the PPWR General position
— +31 (0)20 558 17 53 Chamber of Commerce number: 73160377 JDE Peet’s detailed position on the PPWR General position 1. JDE Peet’s is fully committed to eradicating packaging waste and promoting a circular economy. That is why clear regulations on packaging and packaging waste are so important. By working in partnership with regulators, our industry (as well as other industries), and national and EU authorities, we believe we can collectively achieve the desired long-term environmental goals set out by the European Commission in the European Green Deal. Position 1: Ensuring packaging circularity is critical in achieving the desired long-term environmental goals set out in the European Green Deal.
…circularity is critical in achieving the desired long-term environmental goals set out in the European Green Deal. 2. The proposed EU regulation on packaging and packaging waste (PPWR) constitutes one step towards the implementation of the European Green Deal with the clear objective that to “ensure packaging circularity, packaging should be designed and manufactured in such a way as to allow for the increased substitution of virgin materials with recycled materials and that the increased use of recycled materials supports the development of the circular economy.” 3. The principle of “Reduce, Reuse, Recycle” is therefore at the center of the PPWR and, in fact, there is broad scientific consensus that recycling is consistent with the circular economy.
…of the PPWR and, in fact, there is broad scientific consensus that recycling is consistent with the circular economy. 4. That recyclable packaging is consistent with the circular economy reflects not only the broad scientific consensus but is indeed supported by the proposed PPWR’s own language (para. 26 of the preamble) which states: “To ensure packaging circularity, packaging should be designed and manufactured in such a way as to allow for the increased substitution of virgin materials with recycled materials. The increased use of recycled materials supports the development of the circular economy with well-functioning markets for recycled materials, reduces costs, dependencies and negative environmental 3 JDE Peet’s N.V. — Oosterdoksstraat 80 — 1011 DK Amsterdam — The Netherlands — +31 (0)20 558 17 53 Chamber of Commerce number: 73160377 impacts related to the use of primary raw…
…all SSUs to be compostable undermines the goal of eradicating packaging waste and promoting a circular economy. 5. Although the preamble to the PPWR reinforces the criticality of recycling as a vital enabler of a circular economy, the proposed PPWR’s prohibition against aluminium and plastic SSUs and requiring that such SSUs be compostable undermines the coffee industry’s proactive efforts to operate on a recyclability model. 6. Aluminium SSUs are part of the small high-quality aluminium recycling stream and are fully circular when sorting equipment is available. The presence of coffee residue is not problematic from a recycling point of view.
…sorting equipment is available. The presence of coffee residue is not problematic from a recycling point of view. 7. The coffee industry has been proactively supporting recycling management companies for the past 5 years to promote public collection of aluminium SSUs and get them equipped to sort small aluminium through the direct or indirect funding of equipment based on existing technology. Belgium, France and Germany have deployed (and soon The Netherlands will deploy) equipment on 50%-100% of their sorting sites. In those markets, consumers are now well used (or at least equipped) to discard aluminium SSUs in the recycle bin.
In those markets, consumers are now well used (or at least equipped) to discard aluminium SSUs in the recycle bin. 8. In line with the objective of ensuring packaging circularity, SSUs with no organic matter left after brewing should never be accepted into biowaste but rather be manufactured recyclable, unless made from organic matter themselves. Non-compostable but recyclable SSUs should be considered “packaging” and hence be designed for recycling. There is no reasonable, science-based argument for prohibiting recyclable aluminium or plastic SSUs.
…for recycling. There is no reasonable, science-based argument for prohibiting recyclable aluminium or plastic SSUs. 9. Compostability has an important role to play in reducing harmful environmental waste but can in no way be the exclusive go-to solution for all SSU materials, as confirmed by the preamble of the PPWR which “prescribes that filter coffee pods (…) shall be compostable (…) Other packaging shall (…) be eligible for material recycling”. Imposing the use of a particular material (compostable material) for a specific category (such as coffee capsules) goes against the principle of freedom of material that manufacturers should remain able to enjoy. All the more when there are many other single- dose products on the market for which there is no similar requirement to use compostable material. Position 3: A circular economy requires that recyclable (aluminium and plastic)…
(aluminium and plastic) packaging be permitted. Tea bags and filter coffee pads should remain industrially compostable. 10. A truly circular economy requires that SSUs (other than tea bags and filter coffee pads) be recyclable rather than industrially compostable. That this was the apparent proper original intent of the proposed PPWR is supported by the language of the preamble contained in the PPWR and, indeed, the press release, which was released by the EU Commission, in conjunction with the proposed PPWR, which states: “Industrially compostable packaging will only be allowed for tea bags, filter coffee pods and pads, fruit and vegetable stickers, and very light plastic bags. The products must always specify that they are certified for industrial composting, in line with EU standards.”
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