ECF · Trade and business associations · BE
EUROPEAN COFFEE FEDERATION Avenue des Nerviens 9-31, 1040 Brussels, Belgium +32 (0)2 549 56 41|mail: [email protected] www.ecf-coffee.org | EU Transparency register – 958482431512-92 ECF position on the draft Regulation proposal for packaging and packaging waste (PPWR) The European Coffee Federation (ECF) welcomes the European Commission’s proposal to update the EU legislative framework for packaging and packaging waste (PPWR) by giving Member States and businesses adequate support to achieve waste reduction targets to diminish the environmental impact of packaging. For over a decade ECF and its members have remained committed to ensure that Single Serve Units (SSU’s), referred to in the proposal as coffee bags and coffee system single serve units, meet a proper end of life that enables full circularity and maximization of resource efficiency for the category.
…meet a proper end of life that enables full circularity and maximization of resource efficiency for the category. Regretfully, all proactive proprietary and collective1 investments made over the years2 have been compromised by the wording of the Packaging and Packaging Waste Regulation proposal. Although the preamble to the PPWR reinforces the criticality of recycling as a vital enabler of a circular economy, the proposed PPWR’s explicitly prohibits recyclable coffee system single serve units being placed on the market. Moreover, it mandates that full after use SSUs be compostable, utterly undermining the coffee industry’s efforts to operate on a circular model. In the new PPWR proposal, coffee system single serve units are to be considered as packaging, becoming eligible to be collected by the recycled packaging waste stream.
…units are to be considered as packaging, becoming eligible to be collected by the recycled packaging waste stream. The PPWR ‘Reduce, Reuse, Recycle’ premise that the coffee industry has been single-handedly working towards for over 10 years would finally legally apply to coffee SSU’s. However, Article 8 specifically mandates compostable packaging for coffee bags as well as for coffee system single serve units used to be disposed of together with the coffee, despite there is: (i) no evidence of compostable outperforming recycling solutions in environmental terms, (ii) no bio-waste infrastructure in place across the EU today, requiring considerable investments and efforts from Member States to ensure an existing and well-functioning infrastructure, and (iii) no guaranteed access3 to the bio-waste stream for coffee SSU’s.
…existing and well-functioning infrastructure, and (iii) no guaranteed access3 to the bio-waste stream for coffee SSU’s. Capturing the essence of circularity, the coffee industry should have freedom to continue to work to find the best solution to ensure coffee system single serve units find an appropriate end of life. Moreover, effective circularity may only be achieved if a true legislative4 harmonization exists across the EU. Today, the overall environmental performance of SSU’s vs coffee brewed using other systems is comparable5. Because of the high extraction efficiency, less roast & ground coffee is required to brew the cup, compared to filter or expresso coffee. Due to the reduced use of coffee, the greenhouse gas (GHG) emissions of a SSU brewed cup is comparable to any other brewing systems, also reducing the amount of coffee waste.
…emissions of a SSU brewed cup is comparable to any other brewing systems, also reducing the amount of coffee waste. As for the potential plastic and aluminium waste, according to Euromonitor in 2021, 290,000 tonnes of SSU’s were sold in the European Market, out of which 70% corresponded to coffee system single serve units and 30% to coffee bags. A further breakdown within the coffee system single serve unit category would lead to 70% aluminium and 30% plastic. Considering the average weight of the plastic casing per plastic SSU, the total annual amount of plastic waste disposed of would amount to 18,100 tonnes.
…the plastic casing per plastic SSU, the total annual amount of plastic waste disposed of would amount to 18,100 tonnes. To better contextualize, around 26 million 1 Collective initiatives: Arecafe (Spain); Green Deal (Netherlands); Aluminium & Plastic Recovery Plan (Netherlands); Blue Bin (Belgium), Recycling capsule communication and Best in Class sorting technology (Germany), Alliance pur le Recyclage des Capsules en Aluminium, ARCA and Alliance Recyclage Petits Plastiques (France), Podback (UK), ReCap (Italy), etc. 2 Only in 2020, 24% of global coffee innovation corresponded to the SSU category. In 2022 15% of the EU coffee category volume and 40% of the value correspond to SSU’s. 3 As an exception, according to the German Biowaste Ordinance, "compostable capsules" may not be disposed of in the bio-waste bin. They are to be disposed of with the residual waste.
"compostable capsules" may not be disposed of in the bio-waste bin. They are to be disposed of with the residual waste. In the region of Flanders, Belgium, Vlaco explicitly forbids tea bags and coffee pads being disposed of in the bio-waste bin. 4 Spain as an example of a Member State with a specific legislation on home composting: Ley 7/2022, de 8 de abril, de residuos, y suelos contaminados para una economía circular and Real Decreto 1055/2022, de 27 de diciembre, de envases y residuos de envases 5 Quantis LCA on coffee consumption: https://lyonspc2019.files.wordpress.com/2019/03/pac0680-full-lca.pdf 6 https://ec.europa.eu/commission/presscorner/detail/en/MEMO_18_6 Ref.
…https://ec.europa.eu/commission/presscorner/detail/en/MEMO_18_6 Ref. Ares(2023)2842096 - 21/04/2023 EUROPEAN COFFEE FEDERATION Avenue des Nerviens 9-31, 1040 Brussels, Belgium +32 (0)2 549 56 41|mail: [email protected] www.ecf-coffee.org | EU Transparency register – 958482431512-92 tonnes of plastic waste6 are generated in Europe every year, out of which plastic capsule waste would represent approximately 0.07%, should no recycling exist, which is not the case. Additionally, the penetration of capsule coffee machines in the 197 million7 EU households is estimated at 55%. Should coffee system single serve units be mandated compostable, there would be a need for them to adapt to the 105 million existing coffee machines to ensure that they are not directly disposed of.
…a need for them to adapt to the 105 million existing coffee machines to ensure that they are not directly disposed of. Therefore, an appropriate transition time will be required to additionally ensure the development of compatible compostable capsules, also allowing non-compatible machines to reach the end of their expected service life. As referred to above, the proposal would be totally dependent on the promise of industrial composting technology and infrastructure which is currently limited in scale and scope. The estimation is that only 26%8 of food is collected as bio-waste and that less than 20% of EU consumers have direct access to biowaste infrastructure, as well as the fact that Germany and the region of Flanders (Belgium) explicitly do not accept any type of coffee capsules in their biowaste treatment facilities.
…of Flanders (Belgium) explicitly do not accept any type of coffee capsules in their biowaste treatment facilities. Moreover, mandating compostable SSU’s would only increase European dependency on new virgin raw materials. The Sector’s commitment and proposed way forward In line with the spirit of the EU Green Deal and Circular Economy Action Plan, ECF and its members will continue to be committed to SSU’s circularity, contributing to diminishing the impact of packaging in the environment. The European coffee sector respectfully requests the European Commission adequate support to achieve waste reduction targets to diminish the environmental impact of packaging by: • Ensuring that all coffee single serve units are classified as “packaging”. (Art 3 (f), (g), Annex I) • No material being mandated. Coffee single serve units should have the right to be recyclable or compostable (Art. 6, Art.
…material being mandated. Coffee single serve units should have the right to be recyclable or compostable (Art. 6, Art. 8). A multi-material approach that considers the benefits of all available options to meet the requirements for safety, functionality, quality and circularity would be today the best way forward. • A fair collective approach (industry + competent authorities + waste management) that promotes an enabling environment by the development of adequate infrastructures for the different waste streams and the harmonization of waste management requirements across the EU. • Launching consumer campaigns aiming to create awareness to boost consumer engagement in circularity and promoting harmonized EU-wide sorting instructions to bring further clarity to consumers. Clear labelling is to be ensured so there is no consumer confusion regarding disposal in the appropriate waste stream.
Clear labelling is to be ensured so there is no consumer confusion regarding disposal in the appropriate waste stream. • Appropriate time for the implementation of the new requirements. (Art. 8, Year 2030) • No disproportionate requirements for coffee single serve units such as a double regulatory burden resulting in coffee single serve units being required to be compostable and recyclable, at the same time. Notwithstanding, ECF and its members will continue to work collaboratively and invest accordingly, to ensure, that according to the chosen material there is an appropriate infrastructure in place and that consumers are provided with the necessary information to enable the full circularity of the SSU category.
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