Metsäliitto Cooperative

Corporate Affairs 10.03.2023 Metsä Group’s position on Packaging and Packaging Waste Directive revision Metsä Group welcomes the Circular Economy Action Plan and the aim to contribute to the circular economy through the review of the requirements for packaging and packaging waste. We believe it is important to ensure that the provisions set out measures that are meaningful, achievable and support the functioning of the internal market and free movement of goods while preventing the possible negative impact of packaging and packaging waste on the environment and human health. In particular, we believe that recyclable single-use and reusable packaging should be seen as complementary solutions, and that materials’ life-cycle impact assessments should be use as the basis to choose the best packaging solutions from environmental, end-use and context point of view case by case.

…as the basis to choose the best packaging solutions from environmental, end-use and context point of view case by case. The legislation should also guide Member Stats in the development of ambitious collection and recycling systems, which can be efficient alternatives to the Commission’s proposed bans. Fibre-based packaging supports circular economy, European resilience and climate change mitigation • The recycling rate of paper and cardboard packaging in the EU is high (> 80%)1. It is possible to increase it even further: the key would be to develop and harmonize the waste collection infrastructure so that in all EU countries packaging is collected separately per material. • A recent study confirms that the current paper-based packaging used in the quick service for takeaway offers significant environmental advantages.

…the current paper-based packaging used in the quick service for takeaway offers significant environmental advantages. Switching to reusable alternatives would double the CO2 emissions and increase freshwater consumption by 50% while demanding five times more mineral and resource extraction2. Recycling and reuse are complementary solutions • Recyclable single-use and reusable packaging should be seen as complementary solutions: o Recyclable fibre-based packaging is made from renewable raw material and can replace fossil based materials and solutions. o Detailed and binding reuse targets for various packaging solutions are partly unrealistic and favour non-renewable materials which are difficult to recycle.

…various packaging solutions are partly unrealistic and favour non-renewable materials which are difficult to recycle. • Businesses and operators should have the possibility to choose the best packaging solution from environmental, end-use and context point of view case by case, based on material’s life- cycle impact assessment. o This is an overarching principle in the EU waste framework directive. o There is no one size fit all solution. Actors should have the freedom to select case-by- case the best fit for purpose packaging having the lowest environmental footprint throughout the life cycle. 1 Eurostat (2022). Recycling rate of packaging waste by type of packaging, EU 27. https://ec.europa.eu/eurostat/databrowser/bookmark/d73804e4-e7d8-464d-9d5d-c9f1019d3fcf?lang=e 2 Ramboll (2022). Comparative Life Cycle Assessment (LCA). Packaging solutions for the food segment.

Ramboll (2022). Comparative Life Cycle Assessment (LCA). Packaging solutions for the food segment. A Technical report.: https://www.fefco.org/sites/default/files/2022/FEFCO_Comparative_LCA_study.pdf Ref. Ares(2023)2886092 - 24/04/2023 Corporate Affairs 10.03.2023 o For example, a recent study by the Fraunhofer Institute indicates that the value chain based on fresh fibre-based pulp has superior LCA results. One of the end products of this value chain is paperboard used in packaging3. o Further restrictions should always be proportionate and aimed at encouraging the options that deliver the best overall environmental outcome. Collaboration is key: industry actors should be involved in defining the criteria for recyclability • It is positive that the recyclability of packaging is approached through the Design for Recycling criteria.

…is positive that the recyclability of packaging is approached through the Design for Recycling criteria. Industry actors should be deeply involved in defining the Design for Recycling criteria: o The performance classes for recyclability ranging from A to E (where E would be banned from the market ) can lead to true development of recycling systems o Producer responsibility fees for packaging material grades based on recyclability is a good incentive to develop and improve recycling. Product safety and consumer protection is non-negotiable • Product and food safety cannot be compromised. o Single-use packaging has a key role in preventing food contamination and reducing the risk of cross-contamination between users. The increase in the number of reusable containers will therefore directly result in an increased risk of food-borne illnesses4.

…in the number of reusable containers will therefore directly result in an increased risk of food-borne illnesses4. • Mandatory recycled content requirement for the plastic part of packaging should not be extended to materials which already have high recycling rates and a well-functioning recycling system and market. Ensure uniform Europe-wide regulation on collection and sorting • Instead of bans the regulation should guide to the development of collection and recycling systems. o Separate collection of paper and board is the most effective way to increase the circularity of the product and its recyclability potential by keeping the materials clean. o Ensuring that materials end up in the appropriate recycling operation increases the valorisation of secondary raw materials and can support more efficient EPR schemes.

…recycling operation increases the valorisation of secondary raw materials and can support more efficient EPR schemes. o Mandatory take back scheme have proven to be very efficient in countries where they were implemented with very high collecting, sorting and recycling rates (France, UK). About Metsä Group. Metsä Group leads the way in the bioeconomy. We invest in growth, developing bioproducts and a fossil free future. The raw material for our products is renewable wood from sustainably managed northern forests. One of Metsä Group’s business areas, Metsä Board, is a leading European producer of premium fresh fibre paperboards which are used in consumer and retail packaging. 3 Wüstenhagen & Krombholz (2023). Life Cycle Assessment of fibres from bioproduct mill compared to fibres from average European and Latin America pulp mills. Fraunhofer-Institut.

…fibres from bioproduct mill compared to fibres from average European and Latin America pulp mills. Fraunhofer-Institut. https://publica.fraunhofer.de/entities/publication/72900699-a01d-4c5a-b9e7-613ad6ae0b2a/fullmeta 4 Professor David McDowell (2020). Food hygiene challenges in replacing single use food service ware with reusable food service items. Ulster University https://www.eppa- eu.org/uploads/Bestanden/FINAL%20EPPA%20Report%20-%20Professor%20David%20McDowell.pdf

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