CO2 Value Europe AISBL

CO2 Value Europe AISBL VAT: BE 0695.818.117 Avenue de Tervueren 188A, 1150 Brussels, Belgium [email protected] www.co2value.eu Page 1 of 3 Brussels, March 2023 CO2 Value Europe’s response to the call for feedback on the EU proposal for a Packaging and Packaging Waste Regulation Background & context CO2 Value Europe is the European association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals in 2030 and 2050. We represent more than 80 stakeholders along the entire CCU value chain. Carbon Capture and Utilisation has a great potential in helping achieve a climate-neutral EU by capturing and transforming carbon thus providing a scalable alternative to fossil carbon as it is both available everywhere and does not put pressure on land uses.

…a scalable alternative to fossil carbon as it is both available everywhere and does not put pressure on land uses. The Packaging and Packaging Waste Regulation (PPWR) aims to modernise EU rules around packaging and packaging waste, waste collection, reuse, recycling, and reducing the carbon footprint of packaging in general. CCU can help to replace fossil feedstock with renewable carbon CCU technologies lead to reduction of CO2 emissions and eventually substitution of fossil resources by non-fossil resources. As such, CCU provides permanent alternatives to fossil resources by using recycled carbon in carbon-containing everyday products. The latest report from the IPCC indicates that “CCU has the technical potential to decouple chemical production from fossil resources, reducing annual GHG emissions by up to 3.5Gt CO2-eq in 2030”1.

…to decouple chemical production from fossil resources, reducing annual GHG emissions by up to 3.5Gt CO2-eq in 2030”1. In practice, it means that by reusing unavoidable emissions or direct air capture, the carbon footprint from chemicals – including packaging and plastic packaging – can be reduced dramatically by investing into replacing fossil feedstocks by renewable carbon. The PPWR focuses on downstream solutions: it should also include defossilisation objectives The European Commission, in its Communication on Restoring Sustainable Carbon Cycles published in December 2021, indicates that “reaching climate neutrality requires capturing carbon from the atmosphere for storage and for use as substitute to fossil carbon”. It adds that “at least 20% of the carbon used in the chemical and plastic industry should be from non-fossil sources by 2030”.

…that “at least 20% of the carbon used in the chemical and plastic industry should be from non-fossil sources by 2030”. We could not agree more with this vision and approach. While we fully support the ambitious targets from the PPWR proposal on downstream solutions (recycling, reuse, use of recycled content…), we believe that it should also look at how to defossilise packaging production – and plastic production in particular, which the current version of the PPWR proposal addresses only partially. The PPWR proposal makes the correct assessment that packaging, and plastic packaging in particular has an important carbon footprint: “plastic packaging is the most carbon-intensive material and, in terms of fossil fuel use, recycling of plastic waste is approximately five-times better than incineration with energy recovery” (recital 6).

…use, recycling of plastic waste is approximately five-times better than incineration with energy recovery” (recital 6). The proposal also indicates that “the more efficient use of resources would also bring substantial net savings for Union businesses, public authorities and consumers, while 1 Source: IPCC, 6th Assessment Report, Working Group 3, Mitigation of Climate Change, April 2022 Ref. Ares(2023)2278909 - 29/03/2023 CO2 Value Europe AISBL VAT: BE 0695.818.117 Avenue de Tervueren 188A, 1150 Brussels, Belgium [email protected] www.co2value.eu Page 2 of 3 reducing total annual greenhouse gas emissions” (recital 84).

Belgium [email protected] www.co2value.eu Page 2 of 3 reducing total annual greenhouse gas emissions” (recital 84). But the solutions brought forward in the proposal are essentially structured around the following elements (recital 5): - “making all packaging reusable or recyclable by 2030” - “consider (…) measures to reduce (over)packaging and packaging waste” - “reduce the complexity of packaging materials” - “introduce requirements for recycled content in plastic packaging” Essentially, the proposal looks at ensuring that from design until end-of-life, packaging can be recyclable or reusable, recycled, and used as recycled content. But it does not address sufficiently the question of where the feedstock is coming from, and whether the carbon used to produce virgin materials is fossil or not.

…of where the feedstock is coming from, and whether the carbon used to produce virgin materials is fossil or not. One key concept missing from the proposal is carbon circularity, meaning that rather than extracting additional fossil resources from the ground to use carbon in everyday products, our society should turn towards circular carbon solutions by reusing unavoidable emissions on one end to deliver essential products to another. This is why we strongly call EU policy-makers to reflect the 20% target into EU legislation by creating new quotas for packaging production to include products from alternative carbon feedstock.

EU legislation by creating new quotas for packaging production to include products from alternative carbon feedstock. While the proposal puts forward an objective to reduce the use of virgin materials in packaging and put the sector on track to climate neutrality by 2050, it fails to provide clear legal mechanisms to achieve it: it misses to include clear defossilisation targets, including by using carbon emissions to create alternative carbon feedstock for packaging. Similarly, the Communication on Biobased, Biodegradable, and Compostable plastics identifies that “carbon feedstock will continue to be needed”, which is correct. But it exclusively mentions that “renewable carbon from sustainably sourced biomass is an alternative to fossil carbon”.

…it exclusively mentions that “renewable carbon from sustainably sourced biomass is an alternative to fossil carbon”. This is true again, but it should be complemented by a specific inclusion of carbon captured that can be reused to provide alternative carbon feedstock for producing polymers and other chemical compounds that can replace fossil equivalents. We also believe that it is important to build on the ongoing work around sustainable activities and on the EU Taxonomy for sustainable finance in particular: in this instance, the EU Platform on Sustainable Finance, feeding and screening the criteria of the EU taxonomy for sustainable activities published its suggests for a delegated regulation (in March 2022 and supplementary October 2022) on the four remaining environmental objectives of the Taxonomy.

(in March 2022 and supplementary October 2022) on the four remaining environmental objectives of the Taxonomy. The Platform, under the activity “Manufacture of plastic packing goods” (activity 2.18, page 253 in the supplementary), refers to “use of circular feedstock: At least 85% of the packaging product by weight consists of mechanically recycled post-consumer material, chemically recycled, biobased or CCU (Carbon Capture and Utilization) based material”. We fully align with this objective and consideration and believe the Packaging and Packaging Waste Regulation should reflect such objectives. An additional element to consider is how to treat packaging that cannot be recycled.

…should reflect such objectives. An additional element to consider is how to treat packaging that cannot be recycled. Although the Commission aims – rightly – to make all packaging recyclable or reusable by 2030, some packaging will not be recycled because they have already been recycled multiple times or because they have been contaminated. In such cases, carbon recycling (meaning gasifying materials that cannot be recycled CO2 Value Europe AISBL VAT: BE 0695.818.117 Avenue de Tervueren 188A, 1150 Brussels, Belgium [email protected] www.co2value.eu Page 3 of 3 and capturing CO2 to valorise it) can play a role to limit the negative impact for packaging that cannot be recycled in a mechanical way. Whilst energy-intensive, it can help to reduce the negative impact from packaging that cannot be recycled infinitely.

Whilst energy-intensive, it can help to reduce the negative impact from packaging that cannot be recycled infinitely. This is why we invite EU authorities to create a subtarget, in complementarity to other recycling targets, for residual packaging to be valorised through carbon recycling in the final legislation. Our recommendations on the Packaging and Packaging Waste Regulation The PPWR proposal has been long awaited, new measures to reduce packaging waste and its environmental impact are urgent, and we commend EU authorities for addressing the issue. Focusing a packaging and packaging waste legislation only on the end-of-life of products misses an important point: reducing the impact from packaging and packaging waste is not only about what happens after a packaging is used, but also where it comes from.

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