Food and Beverage Carton Alliance

The Food and Beverage Carton Alliance (FBCA) welcome the opportunity to provide feedback on the draft Implementing Regulation establishing the registration and reporting formats under the Packaging and Packaging Waste Regulation (PPWR), as regards extended producer responsibility (EPR) registration and reporting obligations.

The beverage carton industry acknowledges the need to revise the rules on packaging and packaging waste management to align them with the overall objective of the EU Green Deal. We believe that the current PPWR draft contains positive developments, but that additional consideration is needed for some elements.

Date: 15 July 2020. REPLY TO THE CONSULTATION ON THE INCEPTION STUDY ON REVIEW OF THE REQUIREMENTS FOR PACKAGING AND OTHER MEASURES TO PREVENT PACKAGING WASTE ACE supports an ambitious implementation of the Packaging and Packaging Waste Directive, as well as the new Circular Economy Action Plan.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ACE supports an ambitious EU Climate Law aimed at reaching climate neutrality by 2050. To achieve this goal, it is crucial to address the climate impact of materials and to link climate, circular economy and the bioeconomy.

ACE The Alliance for Beverage Cartons and the Environment provides a European platform for beverage carton manufacturers and their paperboard suppliers to benchmark and profile beverage cartons as a safe, circular and sustainable packaging solution with low carbon benefits. Thanks to their composition, beverage cartons allow to safely pack, transport, shelve and use sensitive products such as milk and juice.

POSITION PAPER Brussels, 22 February 2022 European beverage carton industry views in light of the call for evidence on the environmental impact of waste management – revision of EU waste framework The Association f or Beverage Cartons and the Environment (ACE), together with its members BillerudKorsnäs, Elopak, SIG Combibloc, Stora Enso and Tetra Pak, welcomes the European Commission’s initiative’s objective to…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

POSITION PAPER Brussels, October 2021 ACE reply to the European Commission inception impact assessment (IIA) consultation on food waste – reduction targets The Alliance f or Beverage Cartons and the Environment (ACE) and its members BillerudKorsnäs, Elopak, SIG Combibloc, Stora Enso and Tetra Pak, welcome the European Commission initiative to tackle food waste via regulatory action.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Our full position paper is attached. Our key points are summarised below. Considering the possible implications of the proposed certification framework for carbon removals for the forest-based downstream value chain and forest-based products, we would like to recommend the following: • Recognise the key role of the sustainable circular bioeconomy in removing carbon from the atmosphere.

The Alliance for Beverage Cartons and the Environment (ACE) and its members Billerud, Elopak, SIG Combibloc, Stora Enso and Tetra Pak acknowledge and support the European Commission's efforts to promote sustainability and combat greenwashing through the proposed Green Claims Directive.

REPLY TO THE CONSULTATION ON THE INCEPTION STUDY ON ENVIRONMENTAL PERFORMANCE OF PRODUCTS AND BUSINESSES – SUBSTANTIATING GREEN CLAIMS ACE contribution to the consultation on the inception impact assessment ACE acknowledges the fact that existing claims are not always reliable and in some cases are greenwashing the reality.

The ongoing review of the Single-Use Plastics Directive (SUPD) provides a timely opportunity to assess its implementation and effectiveness in reducing single-use plastics while ensuring regulatory consistency across the EU Single Market. However, it is appropriate to assess the extent to which the current measures of the Directive contribute to the reduction of littering.

Biodiversity supports healthy and resilient ecosystems, keeps the climate in balance, provides essential resources for communities and a stable supply of raw materials for our industry. ACE supports measures that promote the sustainable use of forest, agriculture, marine, freshwater and urban ecosystems, and integrate biodiversity considerations, such as sustainable sourcing and supply chain requirements into all…

The Food and Beverage Carton Alliance (FBCA) supports the proposal by the European Commission to amend the EU Climate Law with a 2040 interim greenhouse gas reduction target by 90% compared to 1990 levels. We consider a legally binding, intermediate target to be vital to mitigating the impact of climate change while providing the necessary long-term policy stability and legal certainty the industry needs to direct…

ACE welcomes the European Commission’s initiative to revise the current EU regulatory framework on food contact materials (FCMs), an endeavour which benefits the health and safety of consumers and supports the resilience of the European food supply system. The EU has successfully developed a regulatory system that ensures food safety since decades.

The Food and Beverage Carton Alliance welcomes the opportunity to contribute to the development of the recycled content calculation methodology under Article 7 PPWR and ensures that the implementing act supports both circularity and competitiveness.

ACE contribution to the consultation on the inception impact assessment: All the materials used in beverage cartons are recyclable. 49% of all beverage cartons sold in Europe were recycled in 2018. The recycling rate of beverage cartons will continue to increase thanks to the new EU waste legislation’s requirement to separately collect all packaging materials and the industry’s investments and the industry’s newly…

The Food and Beverage Carton Alliance (FBCA) welcomes the opportunity to contribute to the EU Commissions public request for feedback on the Draft Implementing Act that aims to establish criteria to determine when plastic waste ceases to be waste.

The beverage carton industry strongly supports the use of due diligence systems for operators placing timber and timber products on the European market, together with a robust traceability system for operators along the supply chain. These due diligence and traceability systems help prevent the risk of illegally harvested timber and timber products entering the EU.