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Roundtable on the PPWR

"Increasing the clout"

Curse or blessing? How do companies and associations rate the PPWR? Its advantages and disadvantages - and challenges - were hotly debated by company and association representatives at the first packREPORT roundtable in Frankfurt. Simone Mosca (CEO Mosca Group), David Rapp (KraussMaffei), Dr Zaid B. Jildeh (Koch Pac-Systeme), Dr Isabell Schmidt (IK Industrievereinigung Kunststoffverpackungen), Henning Schmidt (PlasticsEurope Deutschland) and Alexander-Christian Root (PreZero Foundation) took part in the roundtable.

Harald Wollstadt: To what extent are the associations helpful in overcoming the challenges surrounding the PPWR? Alexander-Christian Root: Associations have the great advantage that they deal centrally with many topics that are of interest to member companies. This gives them a bigger picture. This is particularly important when we are talking about the circular economy. Suddenly we have to bring together many different sectors that have different, possibly divergent interests. And suddenly we have to learn to work much more closely together. Associations are one of the first major points of contact that can help us build the bridges we need to enter into dialogue in a meaningful and focused way. Simone Mosca: Associations also provide antitrust-compliant foundations. Competitors can exchange information here on topics in which they have a common interest, which can then be addressed via the associations. Harald Wollstadt: When we look at the work of the associations, the problem with the PPWR is that we have to consider the entire value chain, i.e. materials, the development side of the packaging materials through to the machines that ultimately have to process them. Would it be possible for associations to work together across the board in the interests of their members?

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Isabell Schmidt: As an example, I can mention the initiative "We are plastics", an initiative of the plastics industry that tries to bring different parts of the value chain together in the value creation cycle. Of course, we are not exactly of the same opinion on all topics and a willingness to co-operate is required. We have to look at how and where we can come together. Last year, for example, we organised a parliamentary breakfast on the topic of "plastic tax". I don't think it's surprising that we quickly came together there. This year, the topic was "PPWR - How can we do it?" For example, the topic of "recyclate" was discussed, which in our view is fundamentally a positive thing. It also shows that if you go to Berlin as an individual company, depending on the size of the company, it is difficult to be heard. And when several associations come together, politicians are more likely to listen. Together, the clout simply increases.

Simone Mosca: Exactly, if a medium-sized company like us goes to Berlin: who cares? Who cares if there is one less medium-sized company in the Odenwald? But if we all get together and then it's about a lot of jobs and then we'll be heard. But back to the PPWR. There are always two hearts beating in my chest because I think that what is happening is actually a good thing. Something had to happen. Of course it's tedious and exhausting and I'm glad that the associations exist. Because there are many pitfalls with the PPWR and there are people in the associations who know all about it.

Isabell Schmidt: We are already well known in Brussels. But what we must not forget is that it is always important to make the customer industries, i.e. those who place packaged goods on the market, our mouthpiece. Be it those who use packaging, be it in the industrial sector or in the household sector. They, too, must formulate their interests and say where things are possible and where they are not. One of our tasks as an association is to nudge them. And that, I have to say, is not easy.

David Rapp: I would like to mention one key point where different associations may have different approaches. This is chemical recycling and the acceptance of quotas within the PPWR. What is the position of the Industrievereinigung Kunststoffverpackungen (IKV)? Isabell Schmidt: In principle, we stay out of the technology competition. We are generally in favour of a level playing field. What we are critical of, however, is the 10 per cent quota for food packaging, which is intended as a vehicle to promote chemical recycling. But what is an opportunity is also a risk: namely that they don't get any PCR (post-consumer recyclate) at all. Now we have the 10 per cent. Originally it was even supposed to be 30 per cent. We are really worried that this can be achieved. With chemical recycling, you could theoretically exclude PCR and go for PR. This is not permitted because the law stipulates that it must be post-consumer. What we are seeing is that there is already a large migration from plastic packaging to coated paper, which is exempt from regulation. We have fought against the exemptions that exist for these paper composites. Firstly, to prevent migration effects, which are also unecological. Secondly, this coated paper has no environmental benefits whatsoever. It may be perceived positively by consumers, but it has no environmental benefits whatsoever. This is neither in the interests of our members nor in the interests of ecological transformation.

Harald Wollstadt: I'd like to throw the keywords material flows and mandatory recyclate utilisation quotas into the roundtable.

Alexander-Christian Root: If I may use the example of LyondellBasell: the 50,000 tonne plant that was built there is explicitly designed for the streams of recyclable materials that cannot be recycled to a high standard. And if we look at the market in Europe, we can see that there is a market for high-quality recyclates. The commodity sector, however, tends to be sluggish because the markets there are not price-dominated. The added value of chemical recycling lies in focussing on the streams that cannot be recycled into high-quality materials. And to return these streams to an almost virgin quality, which would otherwise be lost to the European market. Simone Mosca: Mechanical engineering in particular has to work with precisely these material flows. And if we take up the topic of "innovations", I can say that they mainly come from machines and systems, from process engineering. I believe that it is precisely in this area that associations need to be much more involved and supportive so that these innovations can also take place. Mechanical and plant engineering also has many other issues, such as the shortage of skilled labour. We all have to be honest about this: Where should and where can innovation still take place? David Rapp: As a mechanical engineering company, I don't really care about these regulations, because our machines sell with or without recycled content. If we have to invest because of regulation, that's actually positive for us. It is understandable that the VDMA is taking a less clear position here.

Alexander-Christian Root: You are certainly right that this affects a mechanical engineer differently. But when I think about Schwarz production, we have plants in Europe and even worldwide where we use recyclate that deliver top performance. We may not have the Virgin cycle times, at least not on the first cast, that we get with recycled material. But the machine manufacturer has a certain role to play in finding solutions to maintain these cycle times. If we take a look at retail: In terms of the CO₂ footprint, packaging usually accounts for a third or less of the total CO₂ footprint. However, if the intended use of the product is no longer possible because the packaging means that the product is no longer protected - I mean the breakage rate or the spoilage rate increases - then I am effectively ruining the entire life cycle assessment. The machine manufacturer simply has a decisive role to play in the whole thing. That's what I said at the beginning: the industries need to talk to each other more because they have diverging interests that are suddenly coming to the fore. Zaid B. Jildeh: I'm right there with you. As machine manufacturers, we have to sell machines. Of course, we can't sell a machine without the material being prepared for it. But if a Chinese machine manufacturer comes in with machines at a third of the price and says it works, then we here in Europe have no chance of offering anything like that. Alexander-Christian Root: You just said it yourself: customers don't just want a machine, they also want service. Let me give you an example: If I pack a sausage, I can use a multi-laminate film. But instead of using less material in a highly technical composite pack, I can also use a slightly thicker pack, even if this means using more plastic. This can mean that the packaging runs wonderfully on my machine, even on existing systems, that I can make the packaging super recyclable and that it is an absolutely ecologically expedient way for everyone involved. Simone Mosca: Exactly, and if I can then keep it in the cycle because I've worked with other materials, then I'm on the right track. Of course we want to sell machines and systems, of course. That's our livelihood. But if we don't go along with the transformation and don't succeed, we'll be out of business and won't even need to hand anything over to a third generation. The fact is, the PPWR is here and it's not going anywhere. The transformation has begun.

David Rapp: I think I've been misunderstood. I am not at all denying the need to exchange ideas with each other. Mechanical engineering also has a significant input, of course. What I mean is that you don't necessarily have to be active politically. Don't get me wrong: we earn our money with complexity. The more difficult the task, the more work we have. And the less the mechanical engineers from Asia get. Harald Wollstadt: The automotive industry has been left behind, that's a fact. Is there a danger that this could happen to packaging machine manufacturers as well? Henning Schmidt: If we want to secure the industrial location, politicians need to ask themselves this question from a strategic perspective. So do we want to secure production here and if so, how? For a long time, we were able to argue very convincingly and persuasively that we have an advantage when it comes to carbon leakage. We were able to promote our location from a sustainability perspective and demand that production should take place here in Germany or Europe, because production in other parts of the world is not as sustainable. Let's take the topic of "green steel". China can already supply enough at a third or half of our price.

In the plastics sector, we are considering how it is possible to protect the internal market. The key question is: how do we want to maintain our industry here and create a basis for keeping production here in the long term? One example: there is always criticism of chemical recycling, which ensures that important political framework conditions are not established. However, I am convinced that there is ultimately no alternative to chemical recycling if we finally want to defossilise our industry and no longer burn the raw materials, but instead use them and keep them in circulation here at the site. If we really want this technology to be established here, then we have to take a risk. That is one of the reasons why we as Plastic Zero ultimately campaigned in favour of the PPWR, albeit reluctantly. If chemical recycling doesn't get off the ground here, it will catch on elsewhere. The only question is how long this will take and where it will be set up. Once again, you have to look to China. In terms of technology and the business case, they are further ahead than we think. And they are ready to go through with it. We are not at the moment. That is why, despite all the criticism, which we can well understand, we have also spoken out in favour of the "contact-sensitive" quotas in the PPWR. However, I would also like to point out that this will not be sufficient if it is not flanked, for example, by the possibility of flexible mass balancing. If the development does not work quickly enough due to criticism and a lack of trust, it will become a vicious circle, as these same critics will then be proven right and say "you can't do it anyway". Which is not true - because we are doing everything we can for successful scaling here in Germany. There is still the possibility, although we are not uncritical of this in principle (issue of planetary boundaries), that biomass can also be used as a raw material basis for quota fulfilment. This is not yet clear, but will be reviewed. Zaid B. Jildeh: I know what Mr Schmidt said from my own experience. I talk to a medium-sized company that only produces for the food industry and the medical market. His PP material could also be of interest to the consumer goods industry, but they only use virgin material. What we often hear is that you would never - and the emphasis is on "never" - use post-consumer recyclate. The reason is the food and medical certification. The customer's opinion is often that he can only use PCR material if it is approved for the food industry. And this raises the question of how quickly this will happen. We are talking about a period of five years to develop a completely new production process.

Simone Mosca: We have now decided that - as we also work with post-consumer - we will no longer serve our customers in the food sector who work with direct food contact. The customers are not happy, of course, but it's just too dangerous. That's why some companies are saying: "If you no longer supply me with this and no one else does either, then I'll have to completely change my packaging". That is partly disruptive. On the other hand, the packaging market is huge and, in a sense, a saviour for the paper industry. It is currently seizing the moment and has lobbied, very successfully, for many exemptions in the PPWR. For example, if a coating accounts for less than 5 per cent of the mass of paper and no PCR has to be used in the plastic coating, then this is an advantage. There are exceptions to the reusable quotas that apply to many types of transport packaging if they use cardboard packaging. This is precisely where we would really have opportunities for reusable plastic packaging. Cartons or trays are disposable in the sense of the PPWR and are also completely okay. Where there would be opportunities for reusable plastic packaging, we now have to fulfil quotas - in places where they make no sense. However, I have the impression that the big companies are doing it anyway: Those who are well positioned in in-house logistics are going for reusable. Harald Wollstadt: What role does the consumer play in all of this? Alexander-Christian Root: We need to become much clearer about how people act unconsciously in their daily activities. And we need to learn to integrate ourselves much more into people's lives. But trying to re-educate people usually leads nowhere. There are many studies on this and it leads to the exact opposite of what you want to achieve. Simone Mosca: So I'm often in schools and the students don't even realise what they are doing or how they can influence it. For example, not buying fast-fashion clothes for €2.99 every day. It's a social responsibility to keep providing information in this area and to take the children with us.

Alexander-Christian Root: "I am a consumer, I make my own decisions." That's nonsense when it comes to optimising sustainable solutions. As a consumer, I have other problems than researching the sustainability claims for each individual product or packaging. I want to be offered solutions that are ecological. If I am only offered ecological solutions, then I can't help myself. I clearly see the responsibility as lying with industry, retailers and packaging. Isabell Schmidt: That's the issue. The industry naturally reacts to consumers and decades of NGO work have led to plastic having such a terrible image. And reversing this narrative is a challenge. Consumers will always opt for the supposedly better paper packaging - because they don't know any better. Simone Mosca: This will change with clear regulation. To emphasise something positive about the PPWR: It does make sense if all packaging for design is recyclable from 2030 and must be at least 70 per cent recyclable. This should actually apply to all materials. Consumers can then also be confident that no matter what they choose, they will buy recyclable packaging because there is nothing else available across the EU. I would be delighted to see similar endeavours in America and Asia. The baby has a different name there, but both Asia and America are also moving in this direction. Whether it ends up being chemical recycling remains to be seen. But the simple fact is that we are on the right track. The PPWR is also important and right, because we currently have very different requirements: in Spain, Italy or England, for example. It is easier for me if I know that I have a regulatory framework that applies throughout the EU. Then I can organise my production sites accordingly - just like in the USA or Asia. And I believe it is important that trust in the plastics industry is rebuilt, especially by politicians. Harald Wollstadt: Thank you for the lively discussion and I would like to continue the thread in a new roundtable, possibly around FACHPACK. (mns)