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GROW INTERNATIONAL

GROW int

The aim of our organisation is to raise awareness of the advantages of lightwood packaging for consumer safety, and for the the environment considering the negative carbon footprint.

Lobbying Activity

Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

GROW International welcomes the opportunity to provide feedback on the call for evidence published by the European Commission to review Waste Framework Directive (WFD). We fully support the objective of improving separate waste collection and in particular for wood packaging to yield optimal recycling results. In order to explain further our position also linked to the upcoming review of the packaging and packaging waste directive (PPWD), we have developed a detailed position in the attached document. The European Green Deal has imposed that by 2030 all packaging placed in the EU market needs to be reusable or recyclable. The upcoming revision of the PPWD will look into what are the new essential requirements in order to place packaging in the EU market aiming to make this target a reality. The discussion will be focused on what is considered ‘reusable’ or ‘recyclable’ in the framework of the PPWD. Several European standards cover recyclability and compostability and some are being reviewed to make them compatible with the PPWD. At the same time, the latest revision of the WFD includes new targets for the recycling of municipal waste (where wood waste is currently included). Increased separate targets are set for specific packaging materials, such as paper and cardboard, plastics, glass, metal and wood. The WFD mentions that Member States should set up separate collection at least for paper, metal, plastic and glass, and, by 1 January 2025, for textiles and by 31 December 2023 for bio-waste. However, no separate collection is imposed for wood and it is the only material with a specific target where this is the case. The WFD says Member States may allow waste with similar biodegradability or compostability properties which comply with similar European or any equivalent national standard to be collected together with bio-waste. The European Union's current target is for a 32% share of renewable energy across the bloc by 2030, and it is proposed to be increased to 40%. This will not be able to be reached if the use of biomass is not actively promoted as Bioenergy currently represents the largest renewable energy (RES) source in the EU. Within bioenergy, woody biomass is by far the biggest feedstock for energy which includes postconsumer recovered wood (including lightwood packaging waste). By 2025, at least 55% of municipal waste (from households and businesses) should be recycled. The target will rise to 60% by 2030 and 65% by 2035. 25% by the end of 2025 and 30% by the end of 2030. Key messages Considering that bio-sourced sustainably managed materials should always be preferred to non-sustainable materials (which includes fossil-based ones), GROW would like to highlight the following topics and we hope these elements will be considered by the European Commission: First, we think that it is necessary to collectively think about new solutions and propose new ways for the separate collection and treatment of ‘natural’ or bio-based untreated packaging which does not include paper and cardboard. Second, it is crucial to adopt a lifecycle approach and promote the use of the LCA and/ or Product Environmental Footprint to understand the whole environmental impact of packaging materials and adopt the most adequate policy measures. Third, we support that essential requirements for packaging should be different for sustainable materials that for non-sustainable ones Fourth, a clear and realistic definition of recyclability as well as a compostability and biodegradability should be developed with the aim to have legal clarity updating the current definitions. Fifth, a certain harmonisation of the fees from national extended producer responsibility schemes per packaging material is very much needed. Eco-design should also be encouraged by eco-modulation schemes. Sixth, wood packaging industries are all SMEs and it is important not to impose a disproportionate administrative burden on them.
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