The Beverage carton industry calls for a 90% mandatory collection target

The Alliance for Beverage Cartons and the Environment, ACE, welcomes the appointment of Frédérique Ries MEP (Renew Europe, Belgium) as rapporteur for the Packaging and Packaging Waste Regulation (PPWR). While the beverage carton industry supports the European Commission’s vision that by 2030 all packaging should be recyclable and/or reusable – as demonstrated by the sector’s Roadmap to 2030 and Beyond - we consider the following additions to the draft legislation as essential to meet the goals of an ambitious PPWR revision and look forward to an open dialogue with our stakeholders in the EU institutions:

1) The need for a 90% mandatory collection target

The first step to recycling is collection. The industry needs enabling conditions to ensure beverage cartons are recycled at scale by 2035. A mandatory collection target for packaging formats would provide predictable packaging waste flows that would incentivise investments in recycling infrastructure and technologies.

2) Exemption from reuse targets for microbiological sensitive products

Microbiological sensitive products that cannot maintain their qualities through the addition of preservatives (i.e. 2011 juice directive) need to be packed in aseptic packaging to maintain the hygiene and nutritional value of the product. This is especially important for products with a long shelf life. ACE believes mandatory reuse targets should exempt sensitive beverages with these specific needs.

3) Feasibility assessment of the recycled content targets for contact sensitive packaging

The European Commission’s proposal defines recycled content targets for contact sensitive packaging of respectively 10% and 50% by 2030 and 2040. ACE members are keen to include recycled plastic in their cartons provided it is available on the market at an economically viable price and authorised for use in food contact applications. These two conditions are currently not met at scale. ACE expects that ambitious recycled content targets included in the PPWR will make market availability even more challenging, therefore, we encourage the European Commission to re-assess the availability of such recycled content prior to the enforcement of these targets.To help mitigate the challenge of the availability of recycled content on the market, an equivalent should be established between biobased/renewable plastic content and recycled plastic content as sustainably sourced renewable materials are a low-carbon, circular and food safe solution.

4) Design for Recycling (DfR) Guidelines – need for sound, technical input by industry

DfR Guidelines are technical documents that need to be evidence-based, robust and take account of industry innovation. The beverage carton industry’s latest DfR Guidelines provide expert recommendations to optimize their recyclability. To ensure DfR Guidelines duly reflect in-depth technical knowledge and latest innovation, it is important to include experts from the industry and technical institutes in the development of the DfR Guidelines.
We call for The European Commission to mandate CEN (The European Committee for Standardization) to develop the DfR Guidelines. As an alternative, the creation of a stakeholder/industry advisory body to help with the development of the delegated acts would be necessary.

Beverage cartons are a sustainable and essential packaging solution allowing the safe transport, storage and use of sensitive products such as milk, plant-based products and juice (beverage cartons pack ca. 75% of milk and 59% of juice in the EU). Their composition and lightness allow easy transport and long shelf life. Beverage cartons have the lowest carbon footprint in their category of milk and juice as demonstrated by several LCA studies, including by NGOs.