FoodDrinkEuropes contribution to a circular economy

FoodDrinkEurope represents the interests of Europes food and drink industry[1]. Our
members work to optimise resource efficiency in its operations and across the entire value
chain. Food and Drink industrys contributions to resource efficiency and sustainable growth
thus coincides with European Commissions 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 industrys 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 Packagings contribution to food and drink safety and presentation and food wastage
avoidance as an integral part of our products
o The implementation and enforcement of current WFD and PPWD
o Define a harmonized methodology for target calculation prior to reviewing waste
management targets
o Maintain the waste hierarchy as a principle for waste management with exceptions
allowed when technically or economically justified
o 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 industrys 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.

Europes 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. Industrys 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
Commissions 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, reuse, 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 Directives 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.

Europes 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-industry2013-2014/
[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-environmentalsustainability-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_far
m_fork_infographic_1403-01.png
[9]
See Sustainable sourcing chapter at FoodDrinkEurope Environmental Sustainability Vision report
(page 16) (http://sustainability.fooddrinkeurope.eu/uploads/sectionimages/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-infocus/maximizing-food-resources/)
[12]
http://everycrumbcounts.eu/
[13]
http://www.keepbritaintidy.org/home/481
[14]
http://www.antaisce.org/