FoodDrinkEurope’s contribution to a circular economy FoodDrinkEurope represents the interests of Europe’s food and drink industry [1]. Our members work to optimise resource efficiency in its operations and across the entire value chain. Food and Drink industry’s contributions to resource efficiency and sustainable growth thus coincides with European Commission’s desire to move towards a resource efficient economy. In view of the upcoming Commission proposals to promote the circular economy, FoodDrinkEurope is pleased to contribute with its preliminary views including on the Waste Framework and Packaging and Packaging Waste Directives. Key messages: 

         A circular economy for the food and drink industry means making an efficient use of resources (water, energy, raw materials), from the sourcing of agricultural raw materials up to the consumption of our products, and the optimized management of waste.

         FoodDrinkEurope fully supports the continuous improvement of the environmental performance of products along their life-cycle. The food and drink industry’s assesses the impact that our products have on the environment through a science based and life cycle approach, from ingredient sourcing, to processing and manufacturing, to consumer use of the product and its packaging. Here eco-design represents a key tool for the industry contributing to the efficiency of resources.

         In order to develop scientifically reliable, consistent, non-misleading, and understandable communication along the food chain The Food SCP Round Table (RT) [2] has developed the ENVIFOOD Protocol[3], the first harmonised sectorial environmental assessment methodology for food and drink products.

         On the  upcoming proposal to review the Waste Framework Directive (WFD) and Packaging and Packaging Waste Directives (PPWD), the European Commission should take into account:o    Packaging’s contribution to food and drink safety and presentation and food wastage

avoidance as an integral part of our productso    The implementation and enforcement of current WFD and PPWDo    Define a harmonized methodology for target calculation prior to reviewing waste

management targetso    Maintain the waste hierarchy as a principle for waste management with exceptions

allowed  when technically or economically justifiedo    A shared responsibility approach for collection, recovery and recycling

systemsinvolving all relevant actors in the value chain is  essential to optimize the efficiency of collection, recovery and recycling systems

o    Product design through the implementation of the PPWD essential requirements and related CEN and ISO standards by Member States

o   Focus on consumer education and changing public attitudes to promote litter prevention               

 

 The food and drink industry’s contributions to a circular economy Rising and more volatile food prices are making investment decisions tougher and access to resources more difficult. Raw materials, water, air, biodiversity and terrestrial, aquatic and marine ecosystems are all under pressure. This pressure will only continue to increase with the global population expected to reach 8.2 billion by 2030 [4]. In a world where demand and competition for scarce resources will continue to increase, and pressure on resources is causing greater environmental degradation, Europe can benefit economically and environmentally from making better use of those resources. As a result the environmental repercussions of resource use are also a priority for the food and drink industry. 

Europe’s food and drink industry is firmly committed to continuous environmental improvement in particular through increased resource efficiency and the promotion of a circular economy. Our overall goal is to continuously improve our environmental performances at every stage along the food supply chain, including waste management, without undermining food safety at any stage. To this end, FoodDrinkEurope issued in 2012 its fourth environmental sustainability report setting a Vision and concrete actions for 2030 [5]. In 2013, the Industry delivered on the commitments set out in the ‘Every Crumb Counts’ Initiative[6] including a tool kit on the prevention of food wastage prevention for the industry. Also in 2013, the Food SCP RT launched the first harmonised sectorial environmental assessment methodology for food and drink products, the ENVIFOOD Protocol. In addition, many food and drink sectors are currently participating in the Commission Environmental Footprint pilots[7] which will run until the end of 2016. 

A circular economy helps manage core business risks, such as sourcing, by ensuring supply security for the long term. Our contributions towards a circular economy prioritises hygiene and food safety requirements inherent to our industry practices [8]. The below gives concrete examples how we work towards a circular economy:

 -          Significant steps have been taken to set commitments, actions and targets for the

sustainable sourcing of key commodities. Many food and drink companies are integrating sustainable sourcing into their overall business strategy, product design and corporate policy[9]. 

-          FoodDrinkEurope fully supports the continuous improvement of the environmental performance of products along their life-cycle. Eco-design represents a key tool for the food and drink industry contributing to the efficiency of resources along our value chain taking into account sustainable and efficiency sourcing of raw materials, product formulations and packaging design amongst others. Industry’s resources are being invested in finding ways to streamline, harmonize and simplify eco-design and life cycle assessment for food and drink products, such as the ENVIFOOD Protocol [10], developed, tested and validated by the Food SPC RT. Currently, significant efforts are being devoted to the Commission’s Environmental Footprint Pilots, running on twelve different food and drink product groups. 

-          Increasingly by-products and waste are used as a source of renewable energy and investments in low carbon technologies, such as Combined Heat and Power (CHP) which contribute to further emission reductions. 

-          In light of the anticipated increase in demand for water worldwide, significant efforts have been made to work with food chain partners to improve water management as well as the quality of waste water. Where allowed by food hygiene laws, investments have been made in technology to allow water recovery and re-use, such as recuperating water from steam, without compromising on food safety.   

-          Addressing waste and, in particular, food waste, is an important  priority for the food and drink sector given that when a food is wasted, the resources that were invested in its production are also wasted. Manufacturers are striving to use 100% of the agricultural resources they put into food production and are increasingly finding uses for by-products not only as food but also as animal feed and for other industrial use [11]. In addition, re-use, recycling and recovery by producing bioenergy from waste, helps to achieve optimal raw material utilisation and waste management optimisation.

  

 

Revised proposal on the waste review   The ongoing European Commission work on a revised proposal on the waste review, and in particular on the WFD and the PPWD, should take into account the following considerations.  

 The role of packaging in the food and drink industry Our industry is constantly taking measures to transform fresh raw materials into safe, nutritious and tasty food and drinks suitable for human consumption in a sustainable and efficient manner.  Packaging is essential to this aim as it preserve the food and drink products’ strict hygienic standards and quality from production to consumption. Packaging also contributes to preventing and reducing food waste. Packaging design needs to be assessed through the adequate environmental assessment tools (e.g. Life Cycle Assessment) on a case by case basis. Packaging needs to be considered as an integral part of the packaged product and its value chain. Policies should therefore allow for further optimisation of packaging, which in certain product supply chains for instance may mean more or less packaging use, or alternative packaging designs[12]. Industry will continue improving both performance and functionality of packaging whilst working towards its optimisation so as to minimise the adverse impacts on the environment. Member State implementation and harmonised target calculation methodology FoodDrinkEurope supports the need to improve progressively the waste management targets in WFD and PPWD so that they continue to deliver high levels of waste management across the EU. Implementation and enforcement of the current EU targets at Member State level should however be ensured beforehand. The impact of setting a common methodology for target calculation and reporting along with any changes to definitions should be assessed prior to revising the current targets. The defined methodology should be applied without differentiation across member states. The lack of a methodology for data monitoring and reporting makes it difficult to understand the full picture of waste management performance and recycling today and poses a great challenge to set meaningful targets for the future. The methodology for calculating recycling rates should be standardised so as to ensure consistency and comparability, thereby possibly leading to better informed policy measures and targets. Once a common methodology for targets calculation is defined, the setting of recovery and recycling targets should follow a “step-by-step” approach in line with the process followed for the previous revisions of the WFD and PPWD. Establishing periods for revision of the targets and building on the implementation results of the previous review will help to define more accurate, robust and achievable targets. FoodDrinkEurope supports harmonisation on the implementation of waste management targets in Europe. In the short term providing laggard member states with interim targets may eventually set the basis for an EU harmonisation of waste management targets.  Waste hierarchy as a principle with exceptions allowed FoodDrinkEurope supports the full range of waste management options to maximise the resource value from all materials used for packaging. The waste hierarchy approach to waste

management should be followed. However, deviations should be permitted where this is justified by life cycle thinking on the overall impacts of the generation and management of such waste including technical feasibility and economic viability in accordance with Article 4.2 of the current WFD. On this basis, we believe that incineration with energy recovery must remain available as a waste management option for member states given that for some food and drink packaging this represents the best overall environmental outcome or the only available recovery option taking into account Art 4.2. of the current WFD.  Promotion of shared responsibility approach involving all relevant actors in the value chain Overall, the food and drink industry believes that the existing collection, recovery and recycling systems for used packaging waste will continue to make an important contribution to the achievement of the EU recycling and recovery targets for used packaging. Through implementation of the current WFD and PPWD it has been demonstrated that shared responsibility involving the close cooperation of all the partners in the operating and financing of the value chain delivers incentives for the system to perform efficiently, at lower cost to consumers and to society as a whole. This approach requires full participation by all parties involved. Financial contributions from producers should be used to achieve the packaging recycling and recovery targets also involving public authorities and their contractors.  Protection of the single market The food and drink industry believes that the current PPWD legal base and essential requirements have already and will continue to deliver important results in the context of the EU recycling and recovery targets for used packaging. The Directive’s dual objectives — to protect the environment whilst securing the free movement of packaging and packaged goods throughout the EU, as well as avoiding divergences in national policies — remain valid today. The free movement of packaged goods in the internal market is a fundamental principle of the EU. The PPWD ensures regulatory security and predictability for companies investing in the packaging recycling and recovery value chains. Moreover, in transposing the Directive, national legal frameworks have been set up, enabling industry to carry out its collection, recovery and recycling responsibilities and so help Member States meet national recycling/recovery targets laid down in the Directive. To this aim the PPWD Article 21 Committee serves as a forum for Member States to agree on a harmonised implementation of the PPWD and, in this light, it should be maintained. The essential requirements along with their associated CEN and ISO standards on packaging optimisation should remain the leading set of legally binding EU design requirements for packaging placed on the EU single market as these provide certainty for companies operating in the EU through harmonised requirements. Member States measures on the design of packaging should be strictly addressed towards the implementation of these essential requirements.  Litter prevention: focus on consumer education and changing public attitudes FoodDrinkEurope fully recognises that littering is a serious societal issue which needs to be addressed through a comprehensive and holistic approach. Industry is therefore taking action to encourage our consumers not to litter through various communication activities and

channels. For example packaging recovery organisations in many countries support consumer communication and education campaigns for better waste sorting and litter prevention, such as Tidyman, a Keep Tidy Britain initiative[13] in the UK andAn Taisce[14] in Ireland.  We believe that a key part of the solution to the problem of littering should focus on consumer education and changing public attitudes towards littering.  

Europe’s food and drink industry is looking forward to pursuing its ongoing dialogue with the European institutions and stakeholders in order to progress towards a circular economy.

   

 

[1] http://www.fooddrinkeurope.eu/S=0/publication/data-trends-of-the-european-food-and-drink-industry-2013-2014/[2]  http://www.food-scp.eu/node/25[3] http://www.food-scp.eu/files/ENVIFOOD_Protocol_Vers_1.0.pdf[4] http://www.un.org/esa/population/publications/WUP2005/2005WUP_FS4.pdf[5] http://www.fooddrinkeurope.eu/S=0/publication/fooddrinkeurope-launches-environmental-sustainability-vision-for-2030/[6] http://everycrumbcounts.eu/[7] http://ec.europa.eu/environment/eussd/smgp/pef_pilots.htm[8]http://www.fooddrinkeurope.eu/uploads/publications_documents/ONLINE_VERSION_Safe_food_farm_fork_infographic_1403-01.png[9] See Sustainable sourcing chapter at FoodDrinkEurope Environmental Sustainability Vision report (page 16) (http://sustainability.fooddrinkeurope.eu/uploads/section-images/USE_SustainabilityReport_LDFINAL_11.6.2012.pdf)[10] http://www.food-scp.eu/files/ENVIFOOD_Protocol_Vers_1.0.pdf[11] As described in FoodDrinkEurope Food Wastage Toolkit (http://www.fooddrinkeurope.eu/industry-in-focus/maximizing-food-resources/)[12] http://everycrumbcounts.eu/[13] http://www.keepbritaintidy.org/home/481[14] http://www.antaisce.org/