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Expensive President Metsola,
Expensive President Michel,
Expensive President von der Leyen,
For a number of months we have now adopted, with rising concern, the progress of the proposal on a packaging and packaging waste regulation (PPWR). We’re companies from a large cross-section of the European financial system – producing billions of euros for the EU financial system and hundreds of thousands of jobs. Whereas we totally assist the general targets of the Inexperienced Deal, we’re anxious concerning the unintended penalties of the proposed PPWR laws for the atmosphere, the financial system, meals security and shoppers.
It’s due to these considerations that we have now determined to hitch forces to create a brand new cross-sector alliance: Collectively for Sustainable Packaging.
Whereas the Fee has performed an preliminary influence examine, we really feel it at present lacks depth and particularly doesn’t contemplate financial and meals security features. Nevertheless, there are actually a number of high-level unbiased research, performed by extremely recognised consultants resembling Kearney, and Ramboll, into the implications of the PPWR. All of them attain alarmingly comparable conclusions.
The thought of utilizing packaging again and again, versus simply as soon as, appears the plain resolution – nevertheless it’s not so simple as that. For reuse fashions to have a optimistic environmental influence, shoppers must return them – many times and once more. By their very nature, reusables should be washed each time they’re used. That requires vital incremental power and water. Europe’s
water provide is already underneath stress. Certainly, the Fee recognises water shortage and drought as a precedence within the Inexperienced Deal; the difficulty is highlighted in a number of main European methods, together with the 2020 Round Financial system Motion Plan. However reusable packaging mandates may end result within the consumption of an extra 4 billion liters of water annually[1].
Washing and drying requires extra power, and so may dramatically improve greenhouse gasoline (GHG) emissions. Figures present {that a} shift to 100% reusable packaging by 2030 may improve emissions by almost 50 p.c for dine-in eating places[2](84 p.c of greenhouse emissions in dine-in eating places are attributable to washing and drying)[3].
The same shift for takeaway may improve GHG emissions by 260 p.c.[4] Smaller eating places unable to deal with new necessities, would wish centralised cleansing services, resulting in an elevated transport infrastructure and a big environmental influence – for takeaway alone, transportation of reusables backwards and forwards may add 54 p.c to CO2 emissions.[5].
Packaging isn’t only for present both – it performs a elementary function in defending our meals. A number of research on the hygiene challenges of changing single-use packaging with reusables discover that round reuse methods current higher dangers of cross-contamination resulting from multi-location cleansing, sanitation and storage requirements and transportation.[6] Crucially, packaging additionally permits for handy and protected transportation. It facilitates supply to areas the place recent meals is in brief provide, making certain an extended shelf-life, guaranteeing the very best requirements for shoppers, and lowering meals waste. That is important, as virtually 30 p.c of meals is misplaced or wasted, contributing to roughly 10 p.c of complete CO2 emissions globally[7].
Notably worrying are the findings that reuse fashions may result in a pointy improve in plastic supplies.Reuse targets proposed within the PPWR may create 4 occasions the quantity of plastic packaging waste for dine-in eating places. This rises to 16 occasions for takeaway.[8] That’s much more plastic as an alternative of renewable, recyclable paper and cardboard – the other of what the EU desires to attain.
The research clearly present recyclable fiber-based packaging has the higher potential to learn the atmosphere, financial system, meals security and shoppers.
These are detailed reviews, performed by consultants and commissioned by main corporations and associations who share the EU’s local weather targets, and are innovating to attempt to obtain them – however who’re involved concerning the potential damaging influence of well-meaning however probably flawed laws.
Any regulation ought to consider the particular wants of advanced enterprise sectors, and the precise packaging options. We consider this implies permitting a mixture of options.
A rush to a simplified resolution for a sophisticated state of affairs will solely make the issue worse. It is because of this that we’re asking you all to pause, assess and mirror on the more and more vital knowledge, and upon one of the simplest ways ahead. We additionally ask that member nations not press forward with their very own laws – this may result in even higher complication for companies and shoppers, and will threat fragmentation of the one market.
Solely by doing this we consider, are you able to obtain the broad targets of the EU Inexperienced Deal that each you and we want to see enacted, earlier than the unintended penalties of the well-meaning PPWR laws have a long-lasting and damaging influence on the atmosphere, the financial system and on shoppers’ lives.
References:
[1] Kearney “No Silver Bullet” – Why a mixture of options will obtain circularity in Europe’s IEO sector 2023
[2] Kearney “No Silver Bullet” – Why a mixture of options will obtain circularity in Europe’s IEO sector 2023
[3] Ramboll in-store LCA examine 2021
[4] Kearney “No Silver Bullet” – Why a mixture of options will obtain circularity in Europe’s IEO sector 2023
[5] Ramboll takeaway LCA examine 2022
[6] McDowell Report (Printed March 2021) and others
[7] McDowell Report (Printed March 2021) and others
[8] Kearney “No Silver Bullet” – Why a mixture of options will obtain circularity in Europe’s IEO sector 2023
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