4evergreen

Internal use Internal use Internal use 4evergreen technical assessment of the proposal for a Packaging and Packaging Waste Regulation 4evergreen, a cross-industry alliance bringing together the whole fibre-based packaging value chain, supports the overall goals of the proposal for a Packaging and Packaging Waste Regulation (PPWR). Fibre-based packaging is a key enabler of the circular economy. According to Eurostat, fibre-based packaging has the highest recycling rate in Europe compared to other materials – 81,6%. This is due to a well-functioning and well-developed market for fibre-based secondary raw material in Europe, especially as a sustainable and circular packaging solution. As a cross-industry alliance representing the whole value chain of fibre-based packaging, 4evergreen is committed to raising the overall recycling rate of fibre-based packaging to 90% by 2030.

…packaging, 4evergreen is committed to raising the overall recycling rate of fibre-based packaging to 90% by 2030. To achieve our technical goals of perfecting circularity and sustainability of fibre-based packaging, we require a future-proof EU legislation that takes into account the specificities of fibre-based packaging (including composite packaging predominantly made of paper) and its recycling, industry adopted and recognised design-for-recycling criteria, as well as concrete sorting and collection measures.

…industry adopted and recognised design-for-recycling criteria, as well as concrete sorting and collection measures. EU legislators should take into consideration the following elements to ensure that the PPWR supports the technical advancement of fibre-packaging based circularity: Industry expert-led solutions and initiatives for improving the recyclability of packaging should be taken into consideration 4evergreen welcomes the proposed introduction of performance grades and the Design for Recycling criteria as these approaches have the potential to lead to fully developed and efficient recycling systems. 4evergreen’s Recyclability Evaluation Protocol provides insights into which type of recycling process is suitable for a specific type of fibre-based packaging.

…provides insights into which type of recycling process is suitable for a specific type of fibre-based packaging. It is an essential tool for determining the technical recyclability of fibre-based packaging, as it enables an understanding of which recycling process is best suited for recovering high quality fibres in the most sustainable way. The lack of clarity regarding the preparation and drafting of the Delegated Act on the Design for Recycling criteria under Article 6 is concerning. It will be crucial to take into account input from industry stakeholders such as 4evergreen who are already working on expert-led solutions to ensure that the criteria support rather than hinder the industry and its competitiveness.

…on expert-led solutions to ensure that the criteria support rather than hinder the industry and its competitiveness. 4evergreen believes that CEN (The European Committee for Standardisation) is best placed to develop the Design for Recycling criteria as CEN provides for a technical and transparent process. Alternatively, the European Commission should establish an Expert Group to support the preparation of the Delegated Act with the participation of experts from the Member States, industry and academia. 4evergreen’s Circularity by Design Guideline for Fibre-Based Packaging includes specific design recommendations to help create new fibre-based packaging solutions that can be collected, sorted and recycled at scale. 4evergreen recommends the following: Ref.

…packaging solutions that can be collected, sorted and recycled at scale. 4evergreen recommends the following: Ref. Ares(2023)2890153 - 24/04/2023 Internal use Internal use Internal use - avoid setting recycled content thresholds for fibre and fibre-based materials, as these risk distorting a well-functioning market due to the already high recycling rate of fibre-based packaging - mandatory recycled content thresholds should not compromise food safety and hygiene, nor require an increase in overall packaging mass to ensure performance targets are maintained. Mandatory thresholds will limit widely accepted applications of fibre-based packaging for food-contact.

…are maintained. Mandatory thresholds will limit widely accepted applications of fibre-based packaging for food-contact. Investments already made by the industry should not be undermined The introduction of the proposed restrictions on single use paper packaging in Article 22 and Annex II risks undermining the industry’s efforts towards packaging circularity, especially as the fibre-based packaging industry has already made significant investments in recycling mills with specialised technology. Market prohibitions on certain types of packaging will have a strong negative impact on innovation. The proposed restrictions, as well as the possibility of further limitations under Annex 9 and Annex IV could lead to a de facto ‘negative list’ of packaging characteristics.

…further limitations under Annex 9 and Annex IV could lead to a de facto ‘negative list’ of packaging characteristics. Any future decisions to restrict products from the market should be made through primary legislation accompanied by a thorough impact assessment. Article 6(2)(d) should not lean towards a narrow concept of high-quality recycling, understood only as closed loop ‘product-to-product’ recycling. The PPWR should embrace an approach focused on material circularity which retains the value of packaging materials in the economy, enabling their reuse in other applications in a resource efficient manner. 4evergreen believes that recycling and re-use are complementary solutions towards reducing the overall environmental footprint of packaging. All measures should be based on a lifecycle impact assessment of the specific application.

…footprint of packaging. All measures should be based on a lifecycle impact assessment of the specific application. For example, in several logistics scenarios single-use fibre-based packaging has a better environmental performance over re-use. To avoid further disincentivising circular packaging, single-use fibre-based products that are recyclable should not be penalised by any additional charges (as mandated under Article 45). Regulation should guide the development of effective collection, sorting and recycling systems To secure the highest quality and yield of recovered material, the different paper and board grades must be carefully collected and sorted into the most suitable streams. Sorting at collection points such as households is fundamental for high quality recycling and for increased recycling rates.

…at collection points such as households is fundamental for high quality recycling and for increased recycling rates. 4evergreen endorses collection systems where fibre-based packaging is sorted by households – also called “source separation” – to facilitate recycling at the appropriate paper and board mills.

…by households – also called “source separation” – to facilitate recycling at the appropriate paper and board mills. 4evergreen’s Guidance on the Improved Collection and Sorting of Fibre-Based Packaging is aimed advising on how to organise collection and sorting for various types of fibre-based packaging, and in particular, makes the following recommendations: - legislative initiatives should incentivise investments and participation of all relevant stakeholders in separate collection and post-collection sorting - separate recycling targets for fibre-based packaging by source: >85% for separate household collection and >90% for packaging from industrial and commercial sources - mandatory separation of fibre-based packaging at sorting facilities from household collected lightweight packaging (LWP) - EPR fee structures should reflect to the largest extent possible the real net recycling…

…where necessary - 4evergreen also supports alternative infrastructures capable of meeting the recycling targets. Existing, well-functioning collection and recycling systems should not be hampered. Internal use Internal use Internal use Unfortunately, the general provision under Article 43 obliging Member States to set up systems for the return and separate collection of packaging waste from end users is not sufficient. The implementation of the Waste Framework Directive has shown that a general obligation on the Member States to collect packaging waste is inadequate. Additionally, Articles 11 and 12 only address the establishment of the harmonised label and the specifications for the requirements of labelling and packaging. This means that the necessary provisions for the establishment of a fully efficient collection and sorting infrastructure under the PPWR are lacking.

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