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20 May.2016 ,

The paper packaging industry’s on Directive 94/62/EC on packaging and packaging waste (PPWD) and Directive 2008/98/EC on waste (WFD)

Paper Packaging Coordination Group (PPCG)

Introduction
The Paper Packaging Coordination Group comprises the major European paper and board packaging associations representing the interests of a wide range of packaging products used in transport, retail and consumer packaging. Paper and board packaging is based on a renewable resource (the forest) and is recyclable. We support the concept of a circular economy in which raw materials are sourced from renewable, responsibly-managed resources and recycled after use.


1. Recycling targets for paper and board
Key messages:
• The proposed targets are ambitious, reflect technical and economic realities and can be achieved.
• Packaging recycling targets should be at comparable levels between different consumer packaging materials. High achievement of one packaging material should not compensate for another material’s lower achievement.
• We welcome the proposal that waste exported outside Europe should count towards the target of the Member State where it has been collected on condition that recycling takes place in equivalent environmental conditions.

We welcome the proposed targets for paper and board by the Commission. The paper and board packaging industry in Europe has achieved high recycling rates. In 2014, the average paper and board packaging recycling rate was 81.1% (CEPI). The EUROSTAT figure for 2011 was 79.9%. However, there are also significant differences between Member States, with the recycling rate ranging from 59% to 98% (EUROSTAT). Calculation methods for recycling vary between countries, making it difficult to compare existing data from different countries.


2. Recycling rate calculation
Key messages:
• We support quality recycling.
• We support the harmonised method based on “input to final recycling process”.
• Calculation formulas should be adapted and clarified with regards to “preparation for re-use and recycling” of “products and components” for packaging
We believe the “input” to the final recycling process is the correct basis for calculating the recycling rate and will improve the quality of recycling.

Recommendations:

Final recycling process
• Article 1(2f) of the proposal for amending the WFD with a definition of “final recycling process” should read as follows: “final recycling process” means the recycling process which begins when no further mechanical sorting operation is needed and when waste and waste considered to have ceased to be waste in accordance with Article 6 enter a production process and are effectively reprocessed into products, materials or substances”.
• Article 1(5a) (i) should be consistent with the new definition of final recycling process. Therefore Article 6 (1c) of the WFD should therefore be amended as follows: “the substance or object fulfils the technical requirements for the final recycling process and meets the existing standards and legislation applicable to products.”

Derogation
• The derogation article 11a paragraph 3(a) and (b) of the proposed amendments to the WFD and derogation article 6a paragraph 3 (a) and 3(b) of the proposed amendments to the PPWD should read as follows: “The weight of materials or substances that are not subject to a final recycling process and that are disposed or subject to energy recovery remains below the maximum threshold of impurities acceptable to operators carrying out a final recycling process in order to ensure quality recycling. These thresholds are outlined in Annex VII”. There should be a new annex VII on impurities limits per waste stream, in which the impurities limit for paper (non-paper components and other unwanted materials) should be set at 3% in line with the EN 643.

 

Packaging is different from the other waste streams, which the European Commission already acknowledges by having a dedicated directive for packaging and packaging waste. Packaging which is re-used in a closed loop is not considered as waste and only becomes waste when it leaves the loop. Mixing waste and non-waste (“products and components”) in one calculation formula will jeopardise the potential a harmonised method could have to deliver robust, comparable and accurate reporting. This, combined with an optional reporting on “products and components” will lead to increasing differences in the Member States’ reporting. It may also trigger cases where targets are met by clever calculations without an effective contribution to the circular economy. The resources needed from the European Commission to control the accurate implementation of the formula would be disproportionate to the potential benefits.

Recommendations:
Calculation method and formula
• The formula in Annex IV of the PPWD should be clarified to avoid misinterpretations, under claims or over claims and allow for fair treatment of packaging, considering the intrinsic differences among materials.
• For packaging, the proposed Article 6a), paragraph 1c) should be deleted. Member States should not be optionally allowed to include in the calculation “products and components prepared for re-use”.
• For packaging, “R” should be removed from the formula in Annex IV.
• The denominator “P” should be clearly explained by defining “packaging waste generated”, as, for example, “total packaging placed on the market”.


3. Minimum requirements for Extended Producer Responsibility (EPR)
Key messages:
• EPR systems should be transparent.
• The scope of EPR and roles and responsibilities of each actor involved in packaging waste management should be clearly defined.
• A minimum requirement for EPR systems to collect all (packaging) materials should be introduced.
• A reference to EPR systems needs to be made in PPWD (94/62/EC) to ensure the protection of the internal market, and in the WFD (2008/98/EC).

We welcome the Commission’s intention to make EPR systems transparent as well as the inclusion of three important elements in the Commission’s proposal for general requirements for EPR systems: Eco-modulation, optimised cost and secondary raw materials sales revenues. Recyclability is a key criterion in eco-modulation for EPR systems andensures the value from the sales of secondary raw material. As the additional cost for their collection can be covered by these revenues, the contribution of producers should be lower. Within every material category, criteria for eco-modulation should be carefully designed so they do not inhibit innovation, technical progress, the functioning of the internal market and specific requirements regarding the packed products.
The provisions on general requirements for EPR systems should describe the costs to be covered without using non-exhaustive lists.


Recommendations:
• Article 1(8) 4. (a) first paragraph of the proposal for amending the WFD should read as follows: “Cover the following cost of waste management for the products it puts on the Union market:…”
• The packaging sector should be recognised as a stakeholder in the EPR process so that it can share its expertise in managing the different materials


4. Separate collection, Landfill and Incineration of waste

Key messages:
• Recyclable packaging waste should not go to landfill. We support the ban on landfilling separately collected waste.
• Separate collection of all packaging waste should be strengthened and clarified.
• Incineration of recyclables should be restricted.

The requirement for separate collection of recyclable packaging waste is a precondition to avoid landfilling. The proposal aims in the right direction by linking the provisions on landfill restrictions to the separate collection requirement in the WFD and by introducing a methodology to measure the recycling rate at the input to a final recycling process, and by defining this final recycling process.

Despite the existing capacity for reprocessing paper in Europe, up to 10 million tonnes of all paper, including packaging, are currently being landfilled or incinerated in Europe. This situation has to be addressed, otherwise ambitious recycling targets cannot be achieved.

Paper and board should be collected separately from other recyclables such as plastics, metal, glass – or any combination thereof - and residual waste. Separate collection of all packaging and packaging waste is crucial in order to promote a circular economy and guarantee a high quality of secondary raw materials. The WFD formulated a separate collection target in 2008, but this has been interpreted in different ways by Member States. Beverage cartons (consisting predominantly of board) should be collected in the most optimal way for further recycling, which may differ from country to country.

Recommendations:
• Article 11(1) of the WFD should be amended by changing ”for the relevant recycling sectors” to “for the relevant final recycling processes”.
• Article 11(11) of the WFD should be amended to clarify that paper shall be collected separately from metal, plastic and glass.


5. Unlock the potential of Renewable, Bio-Based Materials
Key message:
• EU circular economy policies and measures should promote and encourage the use of bio-based materials as an essential solution to achieve a real circular economy.

The increased use of packaging made from bio-based materials fosters the establishment of a truly circular economy by taking into account an efficient use of renewable resources (biomass), integrated production and efficient use of bio-based feedstock in integrated bio-refineries. A true circular economy needs to be built on renewable carbon.
This logic should be extended to the legislative proposals under the circular economy package, in particular for sectors where solutions are already available, e.g. packaging. Therefore, the signatories request the recognition and encouragement of the use of materials from renewable sources in the PPWD.
Furthermore, using renewable, bio-based materials decreases Europe’s dependence on the import of raw materials and supports green development within the EU, leading to green growth and jobs.
 

Recommendations:
• Amend the PPWD with the explicit requirement for Member States to encourage the use of bio-based materials for the manufacturing of packaging, where appropriate.
• Introduce a clear definition of what is meant by ‘bio-based’ to ensure coherent interpretation and a level-playing field for producers. The signatories recommend using existing definitions of the CEN Technical Committee TC 411 on bio-based products which define ‘bio-based’ as “derived from biomass” and ‘biomass’ as “material of biological origin excluding material embedded in geological formations and/or fossilised”.


6. Food waste
Key messages:
• We support the efforts of the Commission to reduce the generation of food waste.
• Cooperation among all stakeholders in the food supply chain and the Commission is needed.
Packaging prevents food loss and food waste in a sustainable way. UN studies support the fact that a substantial reduction of food losses can be achieved by providing and using the right packaging solution.

Recommendations:
• The methodologies (paragraph 4) developed by the Commission should consider the positive role of packaging in the prevention of food waste.
• The packaging sector should be among the stakeholders consulted on the subject.

Currently, the following organisations participate in the PPCG:

CEPI, Confederation of European Paper Industries
CITPA, International Confederation of Paper & Board Converters
ACE, The Alliance for Beverage Cartons and the Environment
ECMA, European Carton Makers Association
EMBALPACK, European Association of Makers of Packaging Papers
EMFA, European Moulded Fibre Association
CEPI EUROKRAFT, European Producers of Sack Kraft Paper and Kraft Paper
CEPI CONTAINERBOARD, European Producers of corrugated case materials
EUROSAC, European Federation of Multiwall Paper Sack Manufacturers
FEFCO, European Federation of Corrugated Board Manufacturers
PRO CARTON, European Association of Carton and Cartonboard Manufacturers

 The position paper can be downloaded here.

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09 May.2016 ,

ETS Review: Five comments and proposals on the ITRE draft opinion

On 26 April the ITRE rapporteur published the draft opinion on the Commission proposal to review the Emission Trading System. While the report includes some positive proposals, other aspects still need to be improved. In some cases, some proposed solutions would need to be thoroughly thought through, as they would have the unintended consequence of negatively impacting industrial competitiveness and destabilising the regulatory framework.

The following five aspects are of primary importance:


1. Availability of free allowances for industry

On the positive side, the report seeks to increase the availability of free credits for new entrants and production increases. On the other hand, the report does not address the fundamental question of how to ensure enough free credits to meet industry’s needs.

CEPI proposal: as future industry demand for free credits is subject to many uncertainties, any firm decision taken now will likely result in either excess of unused free credits or an excessive shortage of these. We would thus suggest focusing on:

  1. Re-balancing the share free credits/auctioning to 47.5% /52.5%, to take into consideration free credits originally allocated to industry but unused due to the economic crisis.
  2. Stimulating and rewarding investments in low-carbon technologies: this would be the most cost-effective way to meet the free credits cap while improving industry’s competitiveness.
  3. Defining in the legislation a process whereby the availability of free credits is constantly monitored and, in case of upcoming shortage, the legislator is called to take the most informed decision, exploring all available options.


2. Carbon Leakage

The proposal from the rapporteur is simply unacceptable. The motivation that such a “tiered” approach would support the “sectors in greatest need” is arbitrary and lacks any evidence that such a system would target “those sectors genuinely and most exposed to carbon leakage”. Such a discriminatory approach, if approved, would inevitably entail legal challenges in courts, leading to an unstable and unpredictable regulatory framework. Moreover, it would increase the risk of carbon leakage for most sectors in the economy, putting millions of jobs across industries and local communities at risk.

CEPI proposal: keep the Commission proposal.


3. Benchmarks update

The proposal from the rapporteur is heading in the right direction. Building on the Commission proposal, it stresses the need to use real data and tries to accommodate the need of those sectors moving at a slower pace in emission reductions.

On the other hand, the slower reduction pace should be enlarged to any type of emission, not only to “unavoidable process emissions”. Moreover, the proposal does not address the risk for a sector of remaining “trapped” into one reduction pattern, independently of technological progress. The report also does not address rules for assessing progress in installations not covered by product benchmarks (so-called fall-back approaches), which are responsible for one third of industrial emissions.

CEPI proposal:

  1. Build on the rapporteur’s proposed amendments.
  2. Assess progress in comparison to latest benchmark value set in the legislation.
  3. Broaden the 0.3% category to any type of source of emissions.
  4. Specify in the legislation the rules for assessing progress in installations not included in product benchmarks (fall-back), based on energy intensity improvements.


4. Indirect carbon costs passed on in electricity prices

Although we strongly support the need to reduce the impact of carbon costs in electricity prices, the proposals will have little or no impact in this respect. This is because most industrial installations purchase electricity on the wholesale market. Differing levels of compensation will not impact the way the electricity market operates, thus the way carbon costs are passed through in electricity prices. Suggesting that no compensation should be paid if the carbon price is less than 15 euros would expose industrial sectors to real costs in the short to medium term and is based upon the same flawed “tiering” approach proposed in the carbon leakage policy area.

The proposals would therefore increase the carbon cost exposure for industries while not addressing the shortcomings of the current state aid regime, namely the lack of compensation in all Member States and the unpredictability of the rules. It should also be noted that, in some countries, the lack of compensation for indirect costs coupled with no free credits for electricity produced and consumed on-site (as in the case of CHP) is already leading to up to 40% shortage in compensation for on-site emissions.

CEPI proposal: the ETS review needs to ensure 100% compensation for both direct and indirect carbon costs throughout the whole trading period, at benchmark level.


5. Innovation Fund

We welcome the rapporteur’s attempt to increase and facilitate access to the financing of innovative projects in the industry. We also welcome the attempt to clarify the parameters already upfront in the text of the directive; this will accelerate the process by timely releasing the first funding opportunities.

CEPI proposal: build on the rapporteur’s initiative. Strengthen provisions on the share of financing support, ensuring all industrial sectors can really benefit from this opportunity.

 

Download here

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19 Apr.2016 ,

Reaction to the tiered approach to carbon leakage protection

The signatories (see below), energy-intensive industries express concerns regarding the so called “tiered approach” to carbon leakage protection under the EU ETS

The tiered approach1 would reserve free allowances for some sectors at the expense of others. It goes against the principle set in the October European Council Conclusions that best performing companies in ETS carbon leakage sectors should not bear further carbon costs. Indeed, it would ensure that even best performers in most sectors would bear significant carbon costs and expose them deliberately to carbon and investment leakage.

The proposed tiering has no environmental or economic justification and is based on flawed assumptions (“cost pass-through”) of in reality unpredictable market dynamics. Depriving sectors of carbon leakage provisions would not deliver decarbonisation through investment and innovation. Moreover, it could well prove to have been entirely unnecessary. All forecasts, including the Commission’s Impact Assessment, predict that there will be sufficient allowances available to ensure full free allocation to benchmark levels at least until 2025: and there are other proposals for ETS reform that would deliver full and effective carbon leakage protection without the need for arbitrary discrimination.

To that end, we continue to support an approach based on realistic benchmarks, allocation based on more recent production data and an adequate reserve that ensures full allocation to benchmark levels. The proposed share of allowances to be auctioned shall also be recalculated downwards, as analysis of the EC proposal shows, it does not properly include the number of allowances which were to be given out for free (i.a. unallocated and left-over NER allowances).

In the circumstances, the “tiered approach” would introduce an unnecessary and unfair discrimination between sectors. Fairness and solidity should become key principles of policy making. Jobs in one sector are neither more nor less important than those in other sectors. The signatories fully share and support the BusinessEurope views on tiered approach as expressed in a statement on April 14th.

We ask you to create a framework that gives all sectors an equal opportunity to compete and thrive in Europe, and not to pick certain sectors to stay in Europe. It would undermine our industry’s faith in, and support for, the ETS as a means of reducing carbon emissions.

For further information please contact Peter Botschek, Cefic Director Energy & HSSE, e-mail pbo@cefic.be

1 i.e. as presented in a Non-paper on a Tiered Carbon Leakage List in Phase IV of EU ETS (authored by France, the United Kingdom)

 

 

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18 Apr.2016

Global Forest Products Industry is Part of the Solution to Climate Change

São Paulo – The International Council of Forest and Paper Associations (ICFPA) and its members welcome the signing of the landmark United Nations agreement to tackle climate change, set to take place on April 22. The agreement urges countries to implement policies that would allow them to keep a global temperature rise below 2 degrees Celsius. The global forest products industry has a highly significant role to play in the implementation of these targets.

“The global forest products industry has made significant strides in reducing its carbon footprint, stocking carbon, and generating greenhouse gas removals – all helping to mitigate climate change”, said ICFPA President and Brazilian Tree Industry (Ibà) President Elizabeth de Carvalhaes. “This agreement is crucial to implementing some of the policies that consider biomass as carbon neutral when harvested from sustainably managed forests and to further recognize all positive contributions that forests and forest products provide in combating climate change.”

The inherently-renewable global forest products industry remains committed to mitigating climate change for the benefit of the green economy and society at large. ICFPA members have achieved an impressive 5% reduction in their greenhouse gas emissions intensity since 2010/2011 and 17% since the 2004-2005 baseline year (2015 ICFPA Sustainability Progress Report).

The European pulp and paper industry has been a global champion in mitigating greenhouse gas emissions. It has set itself in 2011 a clear vision of becoming carbon neutral by 2050 and since then, taken concrete steps to reach that goal,” said Jori Ringman, Acting Director General of Confederation of European Paper Industries (CEPI). “Thanks to responsible sourcing practices and sustainable forest management, the forest area is growing in Europe by an area of over 1,500 football pitches per day. CEPI is pleased to see development in the same direction globally”, he added.

The forest industry’s significant role in mitigating climate change was highlighted in the ICFPA-commissioned report Analysis of Forest Contributions to the INDCs by acclaimed researcher Paulo Canaveira. Having looked at the contributions of forests in the national targets of ICFPA member countries (INDCs) and global mitigation effort from 2020 onwards, the report concludes that many countries identify forests and the land-use sector as relevant to policies and measures implemented to meet their targets. Reducing emissions from deforestation, but also sustainable forest management, afforestation and reforestation are commonly mentioned as key mitigation practices. In some developing countries, they even constitute the country’s main contributions.

Other climate change mitigation efforts of the global forest products industry include supporting national and regional climate policies and programs; investing in technologies with low carbon footprints and ones that improve carbon sequestration; and developing bio-based technologies to find innovative ways to use wood fiber and substitutes for goods traditionally made from fossil fuels.
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Note to the editor:

The ICFPA represents more than 30 national and regional forest and paper associations around the world. Together, ICFPA members represent over 90 percent of global paper production and more than half of global wood production.

For more information about the global forest and paper industry, visit icfpa.org.
 

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12 Apr.2016

Bioeconomy 2.0 will help lead the EU’s renewable revolution - with the right support

On the occasion of ‘BioEconomyUtrecht2016’, the fourth Bioeconomy Stakeholders’ Conference, the European Bioeconomy Alliance (EUBA) calls on the EU to lead a worldwide transition towards a renewable, low-carbon economy. Europe has all of the means necessary to become a global leader in the bioeconomy, if its potential is realised and embraced by European policy makers.

The bioeconomy encompasses the sustainable production of renewable resources and their conversion into food, feed, fibres, materials, chemicals and bioenergy through efficient, innovative technologies. It is already worth €2 trillion annually and employs 22 million Europeans, but holds the potential to significantly further boost competitiveness and long-term economic growth. At a time when the pressure is on to deliver on post-Paris climate commitments, the bioeconomy offers a viable solution to today’s fossil carbon equivalents and has the potential to save up to 2.5 billion tonnes of CO2 per year.

In advance of today’s conference, EUBA members, together with other stakeholders in the growing bio-based community have produced a set of recommendations on how Europe can promote bio-based products in public procurement. The report, which will be launched today in Utrecht, outlines what needs to be done at EU, regional and national level to create dynamic new markets for home-grown, EU-sourced bio-based products.

Speaking on behalf of the EUBA, Pekka Pesonen, Secretary General of Copa and Cogeca commented: ‘We are at a pivotal moment in the development of the European bioeconomy. The EU’s strategy is currently being reviewed and we find that we have both great achievements to celebrate as well as some much needed new measures to put in place. Financial tools are needed to boost innovation and investment in existing and new bio-based value chains. In addition, boosting public procurement of bio-based products is one example of how Europe can develop renewable product markets and accelerate the move towards a circular bioeconomy.’

Also speaking on behalf of the Alliance, Jamie Fortescue, Managing Director of Starch Europe, a member of the Primary Food Processors added: ‘Europe has, in abundance, the renewable resources, industrial base and know-how to lead its own bioeconomy revolution. What we now need, to attract more contributors and investment, is open and inclusive discussion underpinned by unwavering, cross-sectoral, political commitment. We want to look back at Utrecht in five years’ time and marvel at what has been achieved in the interim.’

EUBA member EuropaBio’s Industrial Biotech Council Chair, Stephan Tanda, concluded: ‘With the steadfast support and leadership of the European Institutions, the Member States and their regions, huge progress has been made over the past five years with many national authorities setting out their own tailor-made roadmaps towards vibrant and regenerative home-grown bioeconomies. In addition, thanks to the development and launch of the EU’s first ever Bio-based Industries Joint Undertaking for €3.7 billion, ground-breaking cross-sectoral innovation has been given a new lease of life. As a result, we will see new partnerships forming across borders and disciplines in the development of smarter, more sustainable products and processes. The potential is there to be harnessed and, with the right support, Europe will lead the way in the development of a world leading bioeconomy.’

Note to the Editor

BioEconomyUtrecht2016 is taking place 12-13 April in Utrecht, the Netherlands, and is hosted by the Dutch Ministry of Economic Affairs and the European Commission, under the auspices of the Dutch EU Presidency. The aim of the conference is to explore how Europe can enhance its bioeconomy and input into the review of the European Bioeconomy Strategy that will take place in 2016.

Commission Expert Group for Bio-based Products, Working Group Public Procurement of Bio-based Products, Recommendations 2016:
http://ec.europa.eu/growth/tools-databases/newsroom/cf/itemdetail.cfm?item_id=8767

Innovating for Sustainable Growth: A bioeconomy for Europe: http://ec.europa.eu/research/bioeconomy/pdf/bioeconomycommunicationstrategy_b5_brochure_web.pdf
 

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