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Brown-Forman Netherlands BV

The responsible production, sale, and marketing of spirits and wines around the world.

Lobbying Activity

Meeting with András Tivadar Kulja (Member of the European Parliament)

18 Nov 2024 · EU economy and infrastructure, sustainability

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

20 Mar 2023 · PPWR

Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

9 Feb 2023

Brown-Forman is a global spirits producer, and a proud member of SpiritsEurope. We support legislation via a Regulation, to protect the Single Market. Additional national requirements should be strictly limited. We believe the spirits industrys greatest opportunity to contribute to emissions-reduction targets is to optimise the circularity of our glass bottles by Closing the Glass Loop: by weight-optimising our bottles, which means reducing as much weight as possible (while retaining our iconic designs - see further below); by increasing the use of recycled glass in our bottles, as opposed to virgin glass; by working with our suppliers to reduce emissions in the glass production process, leveraging technology and renewable energy; and by supporting recycling schemes, to improve supply of high quality recyclate. The use of glass recyclate is key to achieving circularity, and the production of high quality recyclate should be subject to policy incentives, to accompany industry efforts. We have calculated that the increased use of recyclate will produce proportionately greater emissions savings than weight reduction. Producers already optimise weight, to reduce costs, and weight can only be reduced so much, for safety reasons. One of our leading brands bottle will have a lower GHG per unit when the proportion of recyclate is increased to 50%, as opposed to a 58g weight reduction, which may be structurally impossible. Brown-Forman is already capitalising on these opportunities. In a recent whisky bottle engineering project, we reduced weight by 8%, and increased recycled content by 31%. We now use between 25%-69% recycled glass in our EU-sourced bottles. By contrast, the application of a re-use/refill packaging model to spirits would be counterproductive to the aims of the Regulation. First, it would add emissions to the supply chain, via heavier bottles, using more raw materials, and increased energy and water usage for cleaning. Second, it would require new consumer sorting and collection schemes, with increased rotational transport emissions over long distances. Most particularly, it would be impractical. Spirits production is tied to place (sometimes, bottling in-country is prescribed by law), and immobile. Spirits commonly enjoy the protection of EU Geographical Indications (GIs), or equivalent protections designated in their country of origin. Products bottled at source travel long distances between the place of production and the place of consumption, and the emissions produced by such transport render the concept of returning empty bottles from the place of consumption to the bottling facilities counterproductive. We therefore welcome the exclusion of distilled spirits from the Re-use Targets set out in Article 26. It is well-justified on legal and practical grounds, and note that any requirement for re-use would likely constitute a trade barrier on an intra-EU Single Market and external WTO basis in any event. We have noted the important difference between weight optimisation and weight minimisation in the context of design differentiation.The logical endpoint of an obligation to minimise packaging is to impose a standard bottle for all spirits. Leaving no room for packaging design or functional innovation would inadvertently eradicate the concept of brands, limit progress, reduce consumer choice and deplete our culture and heritage. Standardised bottles would also reduce the competitiveness of EU-origin spirits in export markets. We do not believe it is the intent of the Regulation to prohibit brands and competition, and therefore urge the EU to find the right formulation to allow proportionate aesthetic design differentiation of primary packaging. This means a drafting adjustment to expand the tolerance currently provided in Recital 40 and Article 9 to products registered and protected under the EU GIs scheme, to cover products more generally.
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Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis)

14 Sept 2022 · PPWD, labeling

Meeting with Elina Melngaile (Cabinet of Executive Vice-President Valdis Dombrovskis), Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and

23 Jun 2021 · EU-US trade relations; Trade relations with other third countries

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan), Peter Power (Cabinet of Commissioner Phil Hogan) and Suntory Global Spirits

28 Jan 2020 · EU-US relations and effects on whiskey industry