22 Dec. 2022: The industry has invested heavily in sustainability by improving recycling and using the recycled paper as secondary raw material, with corrugated cardboard containing 88% recycled content on average, says Eleni Despotou.
The corrugated cardboard sector can achieve climate neutrality before 2050 if a set of enabling conditions are met, including a stable and predictable regulatory framework to steer investments in clean technologies, Eleni Despotou told EURACTIV in an interview.
Eleni Despotou is the secretary general of FEFCO, the European Federation of Corrugated Board Manufacturers.
The European Commission has tabled a long-awaited revision of the EU’s packaging and packaging waste directive on 30 November. In your view, what are the main positive points of this proposal and the main shortcomings?
The first positive point is that the directive was changed to a regulation. This may sound like a technicality but it is positive because it will allow greater harmonisation on packaging across EU member states and facilitate a level playing field within the EU single market.
Less positive though is that the proposal provides EU member states with the possibility to go beyond the requirements of the Regulation, which could lead to divergent targets across EU countries and undermine the ambition on harmonisation in the EU’s internal market.
Another positive development is that ambitious recycling targets for packaging were retained. The proposal provides a balanced approach to ensure that packaging is “designed, manufactured and commercialised in such a way as to allow for its re-use or high-quality recycling”. This recognises the complementarity of both reuse and recycling systems in improving circularity, and we welcome this.
Finally, we also support the introduction of waste reduction targets established by the proposal as a necessary step towards improving waste prevention and packaging sustainability across the EU.
On shortcomings, the regulation aims to prevent or reduce “….the adverse impacts of packaging and packaging on the environment…” and sets reuse targets as part of this approach.
However, reuse is not always more beneficial for the environment, as several peer-reviewed LCA studies have indicated. Reuse targets should be established where they are technically feasible, economically viable and environmentally beneficial considering the entire supply chain. Setting targets for large groups of materials and sectors risks leaving the main ambition of the legislation unaddressed, which is to improve the sustainability of packaging.
Another unforeseen consequence of reuse targets is that they will require standardisation for reusable packaging in order to optimise transport and reuse systems that will need to be put in place to meet the objectives. Taking into consideration the amount of packaging sizes that must be placed on the market to meet the needs of products, there will need to be a large range of reusable packaging options, leading to an exponential increase in the number of packaging units placed on the market and an inevitable increase in packaging waste.
In addition, standardised packaging will have difficulties adapting to the excessive packaging limits set by the regulation, potentially leading to more overpackaging.
Finally, when it comes to the policymaking process, we regret the removal of the Public Forum on Packaging for the development of secondary legislation from the final proposal. In practice, this means that any implementing rules – or “delegated acts” as they are called – will be completed by the European Commission behind closed doors.
As a result of this, stakeholders in the packaging value chain as well as civil society groups will not have the opportunity to participate in the elaboration of policy. This is a missed opportunity because industry feedback and knowledge is always crucial in facilitating these delegated acts and we believe stakeholders should not be excluded.
Packaging manufacturers have expressed concerns about reuse targets in some earlier drafts of the proposal. Those targets were watered down in the final text, so have your concerns been addressed?
The reuse targets in the earlier drafts were simply unrealistic, so we are positive about the direction the proposal has taken. However, as previously stated, setting ‘blanket targets’ will fail to ensure that packaging will become more sustainable.
We were also happy to see that existing circular systems, like corrugated cardboard recycling schemes, were considered to have a role to play in the future circular economy.
The industry has invested heavily in sustainability by improving recycling and using the recycled paper as secondary raw material, with corrugated cardboard containing 88% recycled content on average. So we were glad to see this recognised.
Packaging makers 'still concerned' about reuse targets in new EU law
The European Commission’s new packaging law has drawn criticism from manufacturers, who warn against a shift of focus from recycling to reusing materials. While the new proposal is watered down, concerns remain.
The headline target of the proposal is to reduce packaging waste by 15% by 2040. What can be the contribution of cardboard manufacturers to this objective?
The corrugated cardboard industry has decreased the weight of its packaging by 9% over the last 20 years, with some countries achieving even bigger reductions locally. And the industry continues to innovate and work with suppliers to further improve the packaging offered on the market.
It is critical, however, to understand that the functionality of packaging will remain a key aspect for packaging design, as it is the sole reason for its existence.
The industry will also contribute by further increasing the recycling of paper and board packaging on the market. Our product is 100% recyclable, comes from a renewable source and is recycled. What the European Commission and other organisations consider “packaging waste” we see as a valuable secondary material for packaging production.
The proposal contains some new restrictions on overpackaging or unnecessarily bulky packages. What solutions can manufacturers propose to address this?
Overpackaging is an issue that needs to be addressed throughout the entire supply chain – from packaging producers to manufacturers, packer fillers, retailers and e-tailers, logistic companies and delivery services.
It is easy to blame the packaging producer for excessive packaging, but they have no influence over how products will be packed. The decision of which packaging to use for which product if often dependent on many factors beyond the control of the packaging producer, such as the availability of different size boxes, the amount of storage space available with the retailer, the cost of logistic services and so on.
Many corrugated companies are already working with their customers to advise them and provide custom-made solutions to ensure products have “fit-for-purpose” packaging. For instance, some machinery companies can provide right-sizing technology to perfectly adapt the corrugated box to its content.
The Commission proposal is now being forwarded to the European Parliament and Council for adoption. What is your message to policymakers? How can the text be improved?
The packaging and packaging waste regulation must be realistic and achievable. We therefore ask the Parliament to recognise the importance of industry and stakeholder feedback and utilise their expertise in the development of delegated acts.
Additionally, the Parliament should ensure that the legislation strikes a balance between the importance given to recyclability and reusability and recognises the benefits of both. Highly recyclable packaging is sometimes a more sustainable than reusable solutions.
FEFCO presented a roadmap earlier this year to reach climate neutrality by 2050. What are the main avenues to get there?
The European corrugated cardboard sector has the ambition to achieve climate neutrality by 2050 at the latest. This ambition covers the sector’s full carbon footprint – i.e: scope 1 to 3 – and requires to work with the entire value chain to achieve this goal.
Different pathways have been explored to reach carbon neutrality, in close collaboration with CLIMACT, a consultancy. The pathways look at material efficiency and circularity, energy measures such as energy efficiency and decarbonised energy supply, and engaging with suppliers, including the paper industry.
If the paper sector reduces its carbon footprint by 80% by 2050, this would allow the corrugated cardboard sector to achieve climate neutrality. We could even become climate negative – withdrawing CO2 from the atmosphere – if the paper sector fully phases out its fossil emissions.
But the ambitions of the Climate Neutrality Roadmap can only be achieved if a set of enabling conditions are met.
First, a stable and predictable regulatory framework is required to support and steer investments in clean technologies like electric boilers and fuel switches as the corrugated sector will have to make significant investments to achieve climate neutrality.
Second, achieving climate neutrality will significantly increase the sector’s demand for clean energy, such as renewable electricity and bio-based fuels. Policymakers will therefore need to put measures in place to ensure a sufficient, secure and affordable supply of carbon neutral energy.
Finally, as most of the corrugated cardboard’s carbon footprint comes from indirect emissions within its value chain, key policies and measures are needed to improve the quality of waste streams and to enable the decarbonisation of the paper and transport industry.
Can the industry reach climate neutrality earlier than 2050?
It is possible to reach climate neutrality earlier than 2050. But this can only be done if the paper sector accelerates its low-carbon transition, if decarbonised energy supply is made available at scale, if the logistic chain is decarbonised and if the other levers like circularity, material efficiency and design are activated at the same time.
So it will be a formidable challenge.
By Frédéric Simon, https://www.euractiv.com