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The Food and Beverage Carton Alliance

FBCA

The Food and Beverage Carton Alliance promotes carton packaging as part of sustainable food systems using renewable materials with reduced climate impact.

Lobbying Activity

Response to European Climate Law amendment

16 Sept 2025

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 investments towards clean technologies and R&D and innovation in the transition towards a climate neutral economy.
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FBCA urges harmonized packaging rules to protect single market integrity

28 Jan 2025
Topic — This consultation addresses the development of the EU Single Market Strategy 2025.
Message — The alliance calls for harmonized rules and a mandatory 'Single Market test' for new laws. They demand better enforcement of procedures that notify the EU about national trade barriers.12
Why — Harmonization would prevent the high costs of redesigning packaging for different national markets.3
Impact — Sustainability suffers when national rules divert resources from recycling research and development.4
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Meeting with Kristoffer Storm (Member of the European Parliament)

8 Jan 2025 · Food and Beverage Industry

Meeting with Mariateresa Vivaldini (Member of the European Parliament) and SHEIN Group

14 Nov 2024 · Meeting conoscitivo

Meeting with Pietro Fiocchi (Member of the European Parliament)

13 Nov 2024 · Packaging

Meeting with Stefano Bonaccini (Member of the European Parliament)

13 Nov 2024 · Meeting with The alliance for Beverage Cartons and the Environment

Meeting with Isabella Tovaglieri (Member of the European Parliament, Committee chair)

13 Nov 2024 · Politica europea sul packaging

Meeting with Nicola Zingaretti (Member of the European Parliament)

26 Sept 2024 · Packaging

Meeting with Mireia Borrás Pabón (Member of the European Parliament)

26 Sept 2024 · AGRI

Meeting with Jorge Buxadé Villalba (Member of the European Parliament)

25 Sept 2024 · Environment

Meeting with Giorgio Gori (Member of the European Parliament) and BASF SE and European Electronic Component Manufacturers' Association

25 Sept 2024 · Presentation of priorities

Meeting with Benedetta Scuderi (Member of the European Parliament)

24 Sept 2024 · Beverage Cartons

Meeting with Flavio Tosi (Member of the European Parliament, Shadow rapporteur) and Confederazione Nazionale Coldiretti

24 Sept 2024 · WFD

Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

15 Apr 2024

The Alliance for Beverage Cartons and the Environment (ACE) is the beverage carton industrys European platform with a mission to protect essential food and beverages. We work hand-in-hand with diverse partners across Europe to progress EU Green Deal Ambitions and provide expert insights on the essential protection and low carbon benefits of beverage cartons to regulatory officials and other EU stakeholders. Circularity, resource efficiency and innovation are at the heart of our industry which provides a safe, secure and sustainable packaging solution that consumers rely on daily. ACE members comprise of three European beverage carton producers Elopak, SIG Combibloc and Tetra Pak and their two paperboard suppliers Billerud and Stora Enso. Together they employ roughly 24,000 people across Europe, using ~95% renewable energy, to produce an estimated 44 billion beverage cartons annually which are recycled throughout ~20 facilities. ACE welcomes the European Commissions (EC) 18th Amendment of Regulation (EU) 10/2011 on plastic materials and articles intended to come into contact with food which is essential to ensuring the safety of consumers and the well-functioning of the internal market. We support strong and enforceable rules on plastic FCM to preserve our industry's ability to deliver high levels of food safety, while protecting public health and ensuring consumers access to essential goods. Please find enclosed our contribution.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Nov 2023

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. ACE is committed to continue its sustainability journey as demonstrated by the sectors 2030 Roadmap (www.beveragecarton.eu). ACE welcomes the European Commissions (EC) revision of food waste and textile aspects of the Waste Framework Directive (WFD) and call for additional measures to: 1. We support the legally binding food waste reduction targets, in line with Sustainable Development Goals and SDG target 12.3 to halve per capita food waste at the retail and consumer level and reduce food losses along production and supply chains by 2030. Setting ambitious mandatory targets are key to effectively reducing food waste along with data and measurements to provide necessary insight into where food loss and waste is occurring. 2. Recognize the contribution of packaging innovation in reducing food waste. Legislation should recognize the key role that food processing and packaging play in reducing food waste by providing higher efficiency, longer food shelf-life, traceability, and more circular supply chains 3. Foster separate collection. ACE calls for mandatory 90% collection target for all packaging formats by 2030. EU-wide minimum requirements and a target for separate waste collection at 90% are necessary to further increase recycling, support investment in new recycling infrastructure by securing the supply of inputs and demand for recycling capacity, and enhance the quality of the secondary raw materials. 4. Ensure secondary raw materials find their way into new products with the least environmental impact. We support the Commissions intention to optimise recycling in order to achieve higher recycling rates and ensure high-quality secondary raw materials. However, we believe that a definition of high-quality recycling should not penalize already well-functioning recycling processes. Recyclability and high-quality recycling should not be linked with closed product loop requirements but with the quality of recycled materials and their potential to substitute primary raw materials. 5. Ensure legislative coherence and alignment across waste policy to achieve Green Deal objectives. To achieve high ambitions and streamline policies, the WFD needs to be the dedicated instrument setting waste-related overarching principles and definitions. The objectives set in the WFD must also be reflected and aligned across other policies.
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Beverage carton alliance seeks mandatory collection and reuse exemptions

20 Apr 2023
Topic — The Commission is revising rules to reduce packaging waste and improve recycling.
Message — ACE requests a 90% mandatory collection target and exemptions from reuse targets for juice products. They also want recycled content targets to be conditional on material availability.123
Why — This would create a level playing field and prevent unfeasible recycled content requirements.45
Impact — Glass manufacturers lose potential market growth if juice remains exempt from reuse requirements.6
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Meeting with Catherine Chabaud (Member of the European Parliament)

29 Mar 2023 · Discussion sur les emballages et déchets d'emballages

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and SEC NEWGATE EU

10 Nov 2022 · Draft proposal of a Regulation on Packaging and Packaging Waste (PPWR)

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Confederation of European Paper Industries and

26 Oct 2022 · Circular economy and the revision of the EU packaging rules

ACE Urges Mandatory 90% Collection Target for Beverage Cartons

1 Aug 2022
Topic — The Commission evaluates Member States' progress toward achieving 2025 recycling and 2035 landfill targets.
Message — The industry calls for a 90% mandatory collection target for beverage cartons by 2030. They also want cartons included in deposit return schemes unless national collection rates are already high.12
Why — Guaranteed collection volumes would provide investment predictability and create a level playing field with competitors.34
Impact — Plastic packaging manufacturers may lose their current regulatory advantage over the beverage carton industry.5
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Confederation of European Paper Industries and

30 May 2022 · Meeting with Fibre Packaging Europe

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius), Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius) and

3 Mar 2022 · EU circular economy implementation

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and APCO Worldwide and

3 Mar 2022 · EU circular economy implementation

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

22 Feb 2022

Thank you for the opportunity of providing feedback to the call of evidence. Please find our views in the document attached.
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Response to Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

18 Jan 2022

Thank you for the opportunity of submitting comments on the draft Regulation. Please find our views attached in the document below.
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Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager) and Confederation of European Paper Industries and

11 Jan 2022 · Sustainable Products Initiative

Response to Food waste reduction targets

29 Oct 2021

Please find our contribution attached below.
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Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

Please find our contribution attached below.
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Response to Sustainable food system – setting up an EU framework

26 Oct 2021

Please find our submission attached.
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Response to European Bioeconomy Policy: Stocktaking and future developments

31 Aug 2021

ACE welcomes the opportunity to provide feedback to the European Commission Roadmap “European bioeconomy policy: stocktaking and future developments”. Please find our contribution attached below.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

11 May 2021 · European Green Deal and carton industry’s vision for sustainable packaging

Response to Revision of EU rules on food contact materials

28 Jan 2021

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. However, the lack of harmonised rules for all FCMs, as well as the process of developing positive lists for FCMs has created issues in their implementation and management, for both national authorities and the value chain. Risk assessment and management of substance migration from the final FCM is critical to ensure consumer safety, and should be strengthened through a robust and systematic process which ensures adequate information flow and clarity along the supply chain. It is important to underline that FCMs do not represent a risk for consumers. The FCM legislation is already underpinned by a risk-based approach which ensures safety, and in this context we fully support the Commission in its ongoing evaluation of harmful substances. In line with the Chemicals Strategy for Sustainability, when evaluating and prioritising substances, FCMs should be regarded as essential for society. Sufficient time should be allowed by regulators so that the industry can adapt to the new changes, particularly in terms of final article approvals and product design. Food safety is the highest priority for our industry, therefore all materials used in packaging need to be fully assessed for their suitability for and safety in food contact applications. Currently, there are no existing EFSA approvals on the suitability of recycled content of LDPE / HDPE for use in beverage cartons. Any recycled content targets envisioned for FCMs applications should be also feasible, result in positive environmental impacts and avoid disturbing well-functioning recycling loops. In line with the European Commission’s commitment to review all policies based on their contribution to climate neutrality , renewable materials in packaging should be incentivised. Bio-based materials ensure long-term access to resources and reduce the EU’s dependency on finite fossil resources. In turn, they contribute to reducing the greenhouse gas (GHG) emissions associated with the use of polymer barriers needed to protect food and beverages. Consequently, bio-based plastics can help the EU to meet its 2030 targets of greenhouse gas emissions reduction and its circular and bio-economy ambition. We support the Commission’s efforts to ensure the sustainability of packaging in the context of food safety, which should be tackled through a holistic approach that ensures the highest food safety standards, while increasing the recyclability or reuse of packaging. In this context, the fact that the inception impact assessment mentions that packaging should be both reusable and recyclable (instead of reusable or recyclable) by 2030 is worrisome, as it may have detrimental impacts on the well-functioning of the Internal Market, is incoherent with the goals of the ongoing revision of the Packaging and Packaging Waste Directive and incompatible with current European Union food safety standards. This approach also goes further than the mandate of the 2018 Packaging and Packaging Waste Directive, European Green Deal and Circular Economy Action Plan, which aim to ensure that all packaging placed on the market in 2030 is either reusable or can be recycled. The revised FCM regulation must ensure a well-functioning internal market. A well-designed EU FCMs Regulation based on a harmonised approach taking into consideration sustainability and health aspects is better fit to ensure a well-functioning internal market than a patchwork of national legislations. In this sense, we support option 1 which would build on the existing FCMs framework instead of proposing a new one. Please find attached our full position paper.
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Response to EU Forest Strategy

27 Nov 2020

The beverage carton industry is proud to claim accountability for its fibre sourcing. Our industry is a leader in the responsible sourcing of primary materials. In 2007, Tetra Pak, Elopak and SIG Combibloc signed a voluntary industry-wide global commitment to achieve 100% chain of custody certification for all paperboard purchased by 2015. In addition, we committed to 100% certification of our own packaging material manufacturing plants by 2018. This means that each and every beverage carton, which the ACE member companies manufacture and which then find their way to people’ tables, is verified independently for the wood fiber to come from legal and acceptable sources according to the strictest international standards. These commitments were achieved, in less than ten years and are verified by an external third party. ProForest has recently verified our commitment again and will continue to do so every two years. According to the FAO, the Food and Agriculture Organization (FAO) of the United Nations, sustainable forest management is: "The stewardship and use of forests and forest lands in a way, and at a rate, that maintains their biodiversity, productivity, regeneration capacity, vitality and their potential to fulfil, now and in the future, relevant ecological, economic and social functions, at local, national, and global levels, and that does not cause damage to other ecosystems." In Europe, LPB (liquid packaging board) comes from Nordic forest resources. Nordic forest management follows periodic cycles through which forests are regenerated continuously. After regenerating, forests are managed so that about every 20 years a thinning takes place where part of the trees are removed to give more light and space for the remaining trees that they can grow faster. The thin trees are used for pulp production to make LPB. Thicker trees harvested in thinning are used in saw mills to produce lumber and by-products (wood chips and saw dust). The wood chips are used for pulp production – this represents ca. 50% of the material used to produce LPB product. Sustainably managed forests preserve biodiversity through different measures such as the preservation of high conservation value areas or trees. Managing forests adds value to forest owners, avoiding conversion and provides valuable raw material with great carbon benefits. Experts are currently developing the metrics to properly assess the impact of wood production on biodiversity. Proxies are being adopted. The beverage carton industry is closely involved in these developments through their board suppliers.
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Response to Protecting biodiversity: nature restoration targets

20 Nov 2020

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 circular economy policies. Forest based materials are renewable and contribute to climate neutrality when the raw material comes from sustainably well managed forests. We encourage all value-chains to take actions to ensure sustainable sourcing of all raw materials to internationally recognized and credible, sustainable forest management standards that promote and protect biodiversity. ACE is committed to: • Promoting the use of credible sustainable forest management standards, which are instrumental to support the protection of biodiversity, and continuing to demonstrate full traceability of all wood supply to certified sustainably managed forests. • Ensuring transparency and credible traceability of wood fibre flow by third party chain of custody certification, from carton to forest. • Ensuring responsible sourcing for all materials, not just wood fibre, demonstrated by third-party certification, credible sustainability standards as the basis for preservation of biodiversity and showing industry leadership. • Supporting the development of a coherent and growth-oriented EU Forest Strategy which links and recognises biodiversity management and decarbonization, fills knowledge gaps to keep the industry competitive, sets biodiversity targets and ensures Member States meet these targets. ACE calls on the Commission to include such measures in the aforementioned Strategy. The use of internationally recognised sustainable forest management certification systems is crucial for sustaining biodiversity and minimising future loss. Lastly, we call for a more solid knowledge base that could make a positive contribution to the general debate on how the bio economy should best develop. We therefore support efforts to ensure solid data in this field is included to realize this competence in ecology and information technology needed to cooperate.
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Response to Environmental claims based on environmental footprint methods

14 Aug 2020

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. ACE supports using the PEF methodology in the policy framework in complement to other existing tools to ensure credible and reliable information to the consumer and thus prevent greenwashing. However, ACE believes that a number of issues need to be addressed to ensure that the tool is robust: • PEF methodology: some of the categories need further accuracy and supportive science such as the land use impact category. • Data gaps and data updates – the data available need to be robust and updated. • The benchmark approach is in our view not robust as it entails too much uncertainty and sensitivity elements. It should not be promoted as a mandatory requirement. • Verification procedure: how will verification be implemented to assure the robustness of claims and PEF methodology compliance/ PEFCR compliance? Experience with EPDs could provide a sound way forward. • How will “additional environmental information” by treated if it supports an environmental claim? ACE believes that the following should apply: • The use of PEF should be voluntary, notably because of the above weaknesses. If PEF is used clear guidance needs to apply securing accuracy and robustness (to prevent confusing application). The policy framework must ensure that the use of data/quantitative information following the PEF methodology is verifiable, credible, scientifically reliable, comprehensive, clear, not misleading, and transparent, be it linked to a PEFCR or not (Product Environmental Footprint Category Rules). • The use of the PEF in the context described above must be embedded in a reliable and flexible EU policy framework. Such framework should provide the tools on how to translate PEF results to communicable data along the chain and stakeholders. (ie. percentages, aggregation, indexes, indicators per impact category, hierarchisation of data per impact categories…). It should support all possible ways of communicating quantitative environmental information existing in the value chains today. • Whenever quantitative information on environmental performance of a product is communicated or required for public purchase, the correct use of the PEF methodology according to the policy framework and provision of data according to the PEF methodology shall be controlled by the relevant authorities in a full and transparent way. • The policy framework should always take into account and promote innovation to improve the performance of products, including their environmental performance along the life-cycle. • Where the policy framework considers the application of the PEF methodology for the communication of a comparative assertion between products, robust requirements need to safeguard fair product comparison to avoid misleading and confusing consumers, particularly by oversimplification. • The communication of any results to consumers or other stakeholders should remain voluntary with mandatory conditions of use. The policy framework should therefore not prescribe any favoured communication tool. In essence, a mix between option 2 and 3 would be desirable.
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Response to 2030 Climate Target Plan

15 Apr 2020

ACE supports increasing the EU climate ambition to reach 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. Even though energy efficiency and renewable energy are fundamental to reach this objective, climate neutrality will only be possible by cutting the emissions associated with the production, use and disposal of materials. According to the Ellen McArthur Foundation - materials, products and food account for around 45% of the global emission. The substitution of high carbon materials with low carbon materials, such as sustainably-sourced renewables that store carbon dioxide while replacing carbon intensive fossil-based resources, is an important and effective element to reach climate neutrality. Both the EU Bioeconomy Strategy and the EU 2050 long-term Strategy echo this finding by acknowledging that sustainable renewable raw materials are key to achieve climate neutrality. In the words of the long-term vision, “sustainable biomass has an important role to play in a net-zero greenhouse gas emissions economy”. A recent report stresses that the substitution of carbon intensive fossil-based materials with low carbon materials produced from Swedish forest lead to a saving of around 42MtCO2, which represents more than the total CO2 emissions of a country like Denmark. The 2030 Climate Target Plan should, therefore, include: • A review of the existing EU pieces of legislation on materials and products to assess how they can be revised to promote the use of low carbon materials, including through incentives for the use of products made from responsibly sourced renewable materials that contribute to climate neutrality, preserve biodiversity and have positive social impacts. • A review of EU climate legislation to recognise the potential of material substitution in achieving climate neutrality. As a way to encourage the substitution of high carbon materials with low carbon materials, both GHG accounting rules and National Climate and Energy Plans (NCEPs) should take into full account the climate benefits of material substitution.
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Response to Farm to Fork Strategy

16 Mar 2020

ACE supports an ambitious EU Farm to Fork Strategy aimed at achieving sustainable food systems. As the latter contribute to about 25%-30% of the EU greenhouse gas emission, the Farm to Fork strategy is an essential tool to enable the EU transition to a climate neutral economy. Renewable food packaging materials, such as beverage cartons, have an important role to play in both reducing greenhouse gas emission and in achieving a circular economy. Circularity starts with the use of renewable materials made from sustainably-sourced biomass that replenishes and regrows over time. By enabling the replacement of finite fossil-based sources, such materials secure raw material supply for the long term. At the same time, they contribute to climate neutrality by acting as carbon sinks and replacing carbon-intensive fossil-based materials in certain applications. To scale up the contribution of food systems to the climate and environmental ambitions outlined in the Green Deal, ACE supports a future Farm to Fork Strategy that: - Recognises the role of packaging in protecting food all along the value-chain: it contributes to minimise food waste and spoilage, while protecting consumers health. Functionally relevant packaging solutions are an essential tool to achieve the Green Deal objectives to reduce over packaging, minimize food waste and facilitate portion control for a healthier and sustainable diet. - Secures sustainable practices in food distribution, allowing logistic efficiencies, better information sharing between food supply chain players to detect deficiencies and an improved traceability system to identify losses and waste. - Incentivises the use of sustainable packaging: in the same way as recycling, the use of low-carbon circular materials should be embedded in the Essential Requirements of the Packaging and Packaging Waste Directive. The use of low carbon packaging materials, such as sustainably-sourced renewable materials, contributes to climate neutrality, preserves biodiversity and has positive social impacts. Both the EU Bioeconomy Strategy and the EU 2050 long-term Strategy acknowledge that sustainable renewable raw materials are key to achieve climate neutrality. In addition, a recent report stresses that the substitution of carbon intensive fossil-based materials with low carbon materials produced from Swedish forest lead to a saving of around 42MtCO2, which represents more than the total CO2 emissions of a country like Denmark. - Ensures that all food packaging raw materials are sustainably sourced, based on legally binding provisions on due diligence and globally recognised certification standards. - Supports further harmonisation of rules on food contact materials, including specific measures for those materials that are not covered yet, such as paper and board. This will: ensure that the same rules apply all over Europe; strengthen the internal market; improve the competitiveness of the European industry that will have to comply with a unified legal framework, instead of a patchwork of national legislations.
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Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

27 Feb 2020

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. By doing so, industry can continue to ensure that the wood used for production is sourced from sustainably managed forests. A combination of an ambitious nature conservation policy with sustainable harvesting allows the production of sustainable forest-based materials, which have a positive impact on climate change and respects biodiversity. Internationally recognized forest certification standards, such as the Forest Stewardship Council (FSC ®), or the Programme for the Endorsement of Forest Certification (PEFC), helps ensure there is greater transparency as to the sourcing of raw material and contributes to consumers’ awareness to make well-informed purchasing choices. The industry supports mandatory compliance with these systems, and the setting up of similar systems for all other non-forest-based materials entering the EU market. Should materials enter the market without lack of transparency from operators, the industry calls on an EU defined action to guarantee a level playing field. In this context, there is a need for traceability systems to further develop sustainable forest management indicators to explicitly capture the benefits on biodiversity and in mitigating climate change. In view of the European Commission’s intended framework on deforestation free value chains, ACE strongly calls for a clear definition of deforestation, the geographic regions that are targeted, and of illegal deforestation practices outside Europe to ensure forest-based materials come from sustainably managed forests. We believe third-party verified traceability of wood is the first and indispensable step to ensure wood-based products used in EU supply chains follow fair and transparent practices.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

27 Feb 2020 · Green Deal and circular economy

Response to Climate Law

5 Feb 2020

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. The substitution of high carbon materials with low carbon materials, such as sustainably-sourced renewables, is an important and effective element to reach climate neutrality and reduce the need for fossil-based resources. Both the EU Bioeconomy Strategy and the EU 2050 long-term Strategy echo this finding by acknowledging that sustainable renewable raw materials are key to achieve climate neutrality. The EU Climate Law policy should, therefore, include: - Regulatory incentives for the use of products made from responsibly sourced renewable materials that contribute to climate neutrality, preserve biodiversity and have positive social impacts. In this context, we support the EU Commission’s ambition to reinforce sustainable sourcing of all raw materials as part of the future EU Circular Economy Action Plan: all raw materials should comply with globally recognised standards, such as FSC® for forest-based products. - Recognise the potential of material substitution in achieving climate neutrality under the EU climate regulatory framework (see a recent report published by initiative of the Swedish Forest Industries on the contribution of material substitution to climate neutrality- available at https://www.forestindustries.se/news/news/2019/10/swedish-forestry-sectors-climate-contribution/). As a way to encourage the substitution of high carbon materials with low carbon materials, GHG accounting rules should take into full account the climate benefits of material substitution.
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

ACE supports an ambitious Biodiversity Strategy 2030 to halt global biodiversity loss. The Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) report launched in summer 2019 clearly states the importance to give biodiversity high focus. The report identifies the five most important factors behind the negative trend: climate change, changes in land and water use management, exploitation of organisms, pollution and invasive species. It highlights the importance to combat climate change to avoid detrimental impacts to ecosystems, including the loss of biodiversity (see IPBES report). High wood production in combination with high ambitions regarding nature conservation produce sustainable forest-based materials that have a positive effect on both climate change and biodiversity. In view of the Biodiversity Strategy 2030, ACE supports measures that promote the sustainable use of forest, agriculture, marine, freshwater and urban ecosystems, and to integrate biodiversity considerations, such as sustainable sourcing and supply chain requirements into all Circular Economy policies. Forest based products are renewable and climate-positive when the raw material origins come from growing, well managed forests. We encourage all value-chains to take actions to ensure sustainable sourcing of all raw materials – both renewables and non-renewables to recognized sustainable forest management standards, like the Forest Stewardship Council (FSC), or the Programme for the Endorsement of Forest Certification (PEFC). The beverage carton industry has long been at the forefront of promoting sustainable sourcing of its raw materials: in 2016 ACE Members achieved their voluntary commitment to only use wood fibres from legal and acceptable sources which are covered by certified traceability systems. The companies also voluntarily committed to secure 100% Chain of Custody certification for all their production sites. Europe already demonstrates its leadership with regards to sustainable sourcing of forestry-based resources. This is a competitive advantage to further build on. Good experiences from forestry practices on national level in Europe should be utilized and acknowledged as an important element in EUs biodiversity strategy. Building on existing and credible certification systems, like FSC or PEFC, is a key to success for a positive biodiversity development. The broad stakeholder engagement in credible certification systems guarantees inclusion of stakeholder views in the decisions on forest management. The beverage carton industry is committed to work actively with its stakeholders to promote sustainable forest management and the wider use of certification systems. Furthermore, these systems contribute to clarity in the marketplace. It is important to create good conditions for consumers to make the best possible choices, and in this way support a positive biodiversity development. We see a need to further increase the knowledge base on the state of biodiversity and how it develops over time in Europe. A more solid knowledge base could also make a positive contribution to the general debate on how the bio economy should best develop. We therefore support efforts to produce solid data in this field is included as an element in EUs biodiversity strategy – to realize this competence in ecology and information technology need to cooperate. Forest based products are renewable and climate-positive when the raw material comes from growing, well managed forest. The EU - Biodiversity Strategy 2030 must consider all aspects and take all the influencing factors into concern to halt global loss of biodiversity.
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Response to A new Circular Economy Action Plan

20 Jan 2020

ACE supports an ambitious new Circular Economy Action Plan. This is a unique opportunity to scale up the contributions of a circular economy to climate neutrality by incentivising use of low carbon and circular products. The use of materials with the lowest carbon impact, such as sustainably-sourced renewables that reduce the need for fossil-based resources, are key to reach climate neutrality. The future Sustainable Product policy should, therefore, encourage the use of products made from renewable materials with low environmental impacts, including on climate and biodiversity. New rules to ensure sustainable sourcing of all raw materials should also be part of the future EU product policy. We recommend using internationally recognised standards and certification mechanisms, such as FSC for forest-based products, to demonstrate compliance with requirements on sustainable sourcing. Increased recycling is key to keep valuable resources in the economy. We support an ambitious implementation of waste legislation, with particular regard to separate collection. Separate collection is essential to achieve a circular economy, as it increases the volume and the quality of materials available for recycling. To ensure compliance with the legal obligation on separate collection, we support EU-wide mandatory collection targets for packaging formats such as beverage cartons. By ensuring the legal certainty that beverage cartons are collected, mandatory targets provide a strong incentive for further investment and innovation in the recycling infrastructure, while increasing consumer awareness on the need to separately collect beverage cartons. For instance, Belgium and Germany set up ambitious mandatory targets driving up the recycling rate of beverage cartons. Lastly, we recommend basing all future legal measures on a comprehensive and evidence-based impact assessment, in line with Better Regulation principles. Before setting new requirements on waste prevention and reuse, the Commission should assess their overall environmental impacts. In addition, the Commission should consider mandatory provisions on recycled content only for products or materials for which the use of recycled content is technically and environmentally meaningful (i.e. it leads to overall positive environmental impacts and does not disturb well-established and functioning recycling loops), is safe for consumers based on EFSA assessment of its suitability in food contact materials, and does not decrease the recyclability of the new product.
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Response to Reducing marine litter: action on single use plastics and fishing gear

20 Jul 2018

ACE, representing the beverage carton industry in Europe, supports the ambition of the European Commission to address the most littered plastic items found on European beaches and reduce their negative impact on the marine life and the environment. However, ACE believes that the Commission’s proposal lacks clear definitions and therefore brings ambiguity with regard to the scope of the directive. This has the potential to create legal uncertainty both for Member States and industry, leading to different interpretations, disproportionate implementation far beyond the stated objective (address the ten most found items on European beaches) or the impact of different scenario assessed. It would also distort the single market for packaging and packed goods. In particular, the proposed definition of “plastic” (art.3.1) and recital 8 which is meant to clarify the definition remain open for interpretation that would extend the scope of the directive to any single-use food packaging item, reaching far beyond the intended objective. Paper, board or beverage carton container packaging systems commonly use polymer coatings, linings or layers for functional, hygiene or food protection purposes. The plastic coating, liner or layer do not function as a “structural“ element of the products. Those products are considered on the market as paper products, are covered by the EN 643 standards for paper for recycling and contribute to the high recycling rate of paper-based packaging (90% target set under the revised Packaging and Packaging Waste Directive). As per European Environment Agency latest records, no paper or board articles whether using or not some polymers, are listed amongst of most commonly found items on European beaches and they only account for 3% of the littered items. Having these products covered by the proposed directive is therefore fully disproportionate. For the purpose of this Directive, industry considers it is indispensable to provide a clear definition of what are plastic products, to avoid unwarranted classification of some paper and board products as plastics otherwise raising conflicting interpretations and blurring the implementation of long established EU Internal Market legislation. Products using polymeric layers and liners that do not function as “main structural“ element of the product should therefore be more clearly excluded from the scope of this Directive (Article 3) on Single-use plastics. We call on the Commission to define clearly the scope of the directive, limiting it to the targeted most littered “single use plastic products”; to specify clearly the definitions, avoiding possible multiple interpretations; and to clarify that the PPWD remains the overriding lex specialis for the packaging items covered by this proposal.
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Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

The Alliance for Beverage Cartons and the Environment (ACE) represents the European beverage carton industry that operates within the bio-based economy. Our industry is committed to being a frontrunner when it comes to using renewable resources and increasing the use of bio-based materials by seeking and applying the latest innovative technologies. ACE welcomes the revision of the 2012 EU Bioeconomy Strategy as an opportunity to provide a more coherent policy framework in support of a sustainable, circular bioeconomy. ACE believes that the bioeconomy is fully complementary to Europe’s aim to achieve a circular economy. The input of primary materials will always be needed in a growing circular economy, meaning the sustainability, circularity and renewability of such materials should be given adequate weight, alongside the recyclability of products at the end of their life. The members of ACE only source wood fibre that is verified to come from legal and acceptable sources, having achieved full Chain of Custody in 2015. Sustainable forest management is equally important, with its contribution to the protection of biodiversity, security of material supply, a reduced climate impact and jobs and growth in sometimes remote areas of Europe. ACE would like to stress the following key areas for action under a revised Bioeconomy Strategy: • Ensure the availability of bio-based materials and incentivise their use to enhance their competitiveness and reduce Europe’s dependency on finite raw materials through existing instruments such as green public procurement, ecodesign, the Packaging and Packaging Waste Directive, the Plastics Strategy and through national bioeconomy strategies in the Member States. • Increase support for innovation in and deployment of bio-based materials to upscale innovative solutions and achieve a low carbon economy through financial mechanisms such as Horizon 2020 or the EU’s structural funds. • Actively promote a global shift towards more sustainable sourcing of primary renewable materials by providing competitive advantages to materials from socially and environmentally acceptable sources and setting a level playing field that can reward business frontrunners. The beverage carton industry is committed to further get involved in discussions on the revision of the Bioeconomy Strategy and enhance its contribution to a sustainable, circular bioeconomy.
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