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ACE Ireland’s response to the draft National Food Waste Prevention Roadmap

The Irish Government in its Waste Action Plan for a Circular Economy committed to introducing a National Food Waste Prevention Roadmap. In March 2022, ACE Ireland made the below submission to the Department of Environment, Climate and Communications (DECC) ‘public consultation on the draft National Food Waste Prevention Roadmap’.

The Alliance for Beverage Cartons and the Environment Ireland (ACE Ireland) represents Tetra Pak, Elopak and SIG Combibloc, the leading manufacturers of beverage cartons for the Irish and European markets.

ACE delivers sector-wide environmental initiatives on behalf of its members. Its objective is to provide a platform in Ireland to benchmark and profile beverage cartons as a circular, recyclable, and sustainable packaging solution with low carbon benefits.

As set out in the ‘ACE Beverage Carton Roadmap to 2030 and Beyond’, the beverage carton industry will strive for its packaging to continue to actively contribute towards the ambitions of the EU Green Deal, specifically climate neutrality, circularity, biodiversity and resilient food systems, and food waste reduction while never compromising the health and safety of consumers.

Do you think the approach as outlined in the draft Roadmap will deliver the reductions necessary to reduce Ireland’s food waste by 50% by 2030?

ACE Ireland supports the overall approach taken in the draft National Food Waste Prevention Roadmap and recognises this as an important step in reducing Ireland’s food waste by 50% by 2030. Key to the success of this will be setting and communicating realistic interim targets and milestones for each part of the supply chain up to 2030, as well as overall targets for the supply chain as a whole.

The Roadmap specifies that the EPA is currently working to establish measurement and reporting methodologies for each sector. As part of this process, the EPA should directly engage with all stakeholders to ensure that the measurement and reporting methodologies established are fit for purpose, and that they account for the unique circumstances of each sector. Food packaging has a critical role in reducing food waste, for example, and must be recognised as part of the solution. This also applies to single-portion packs, which deliver only as much food or drink as is required in one consumption event, thereby avoiding excess consumption and possible product wastage. We would be keen to support the EPA in developing methodologies for measuring the impacts of packaging.

Separately, we welcome the inclusion of research and innovation in the Roadmap. ACE members remain committed to supplying the Irish food and drink industry with packaging that protects food and drink and delivers functionality whilst being recyclable, low-carbon and made mainly from bio-based materials.

What additional actions do you think would be effective in helping Ireland reduce its food waste?

While food packaging is referenced in the Roadmap, this is mainly based on wider commitments set out in the Waste Action Plan for a Circular Economy. Greater emphasis should be placed within the Roadmap on the role that packaging plays in reducing food waste and therefore in reducing carbon impacts – particularly packaging that is in itself low-impact, low plastic and circular, such as packaging is made mainly from renewable materials.

The beverage carton industry’s ‘Roadmap to 2030 and Beyond’ sets out the industry vision to deliver the most sustainable packaging for resilient food supply systems which is renewable, climate positive and circular. The industry fully supports the ambition to provide food packaging solutions which meet the needs of food safety and preservation whilst minimising carbon impacts and packaging waste. We fully agree with the emphasis placed on collaboration and research between the food and packaging industries. We believe this will have positive impacts along the supply chain, particularly for the ‘retail and distribution’ and ‘household’ sectors.

What are the most effective awareness raising measures that could be taken to reduce food waste?

A mass communications campaign across mainstream and digital channels will be required to secure consumer awareness and buy-in around the ambitions to half food waste in Ireland by 2030.

From a consumer perspective there needs to be:

  • clear communication on the simple steps they can take to reduce food waste and to highlight resulting positive impacts;
  • clear communication on date marking and the differentiation between ‘best before’ and ‘use by’;
  • links between other communications programmes and food waste reduction, such as those on waste and recycling;
  • support from all public facing stakeholders across the food supply chain to amplify messaging on food waste reduction from DECC and the EPA;
  • greater exposer of the Stop Food Waste programme to households;
  • ramped up messaging within schools and educational settings to motivate and mobilise future generations to champion food waste reduction;
  • clear annual updates on progress made and where there is room for future improvement.

In terms of the food supply chain, there needs to be an emphasis on training and skills to help industry develop and implement its own programmes that contribute to reducing food waste.

This will require the obligations of each part of the food supply chain in working towards a 50% overall reduction to be identified and communicated, in addition to the measurement and reporting framework set out by the EPA.

Which sectors or stakeholders do you think should play a key role in the implementation of the Roadmap?

ACE Ireland agrees that the EPA, as the environmental regulator, is best placed to manage the overall implementation and monitoring of the Roadmap. Communications relating to the implementation of the Roadmap should be driven by both the EPA and DECC, supported by public and private stakeholders within the food supply chain and waste management industry.

Are you satisfied with the proposed Roadmap monitoring and evaluation arrangements?

The monitoring and evaluation arrangements set out in the Roadmap make sense. However, it is not clear how effective they will be until we have full sight of the monitoring and evaluation framework being developed by the EPA, including the reporting methodologies. Again, we strongly encourage the EPA to engage with all sectors of the food supply chain as part of this process, to ensure that best outcomes are delivered.

Have you any other comments or feedback on the content of the draft Roadmap?

ACE welcomes the commitment to establish a Food Waste Prevention Task Force to identify and maintain a register of priority research topics on food waste, informing the different research funding calls that may cover aspects of food waste. We encourage DECC to ensure that this task force and its sub-groups have representation from all sectors across the food supply chain, including packaging.

ACE Ireland’s response to the consultation on the legislative framework and scope of Ireland’s proposed Deposit Return Scheme (DRS)

The Irish Government in its Waste Action Plan for a Circular Economy committed to introducing a Deposit and Return Scheme (DRS) for Ireland. In May 2021, ACE Ireland responded to an Irish Government consultation on the legislative framework and scope of the proposed Deposit Return Scheme (DRS).

ACE Ireland strongly advocates for consideration to be given for the inclusion of Beverage Cartons in any DRS for Ireland. See below our response to the questions asked as part of the consultation.

ACE Ireland supports the preferred producer owned and led, centralised model proposed by the Department of Environment, Climate and Communications (DECC) for the Scheme. We believe that a DRS owned and operated by industry will help deliver DECC’s objective of a circular economy and will help achieve recycling targets as referenced in the Waste Action Plan for a Circular Economy. We would also strongly recommend that the DRS is designed to take advantage of the digital monitoring and collection technologies now being developed, to increase the quantity and quality of materials collected and to improve convenience and ease of use for citizens.

ACE Ireland’s call for an ‘all-in’ model

We recognise that the initial scope of the DRS will be limited to the inclusion of Polyethylene Terephthalate (PET) bottles up to three litres in size and aluminium beverage cans to allow DECC prioritise delivery of obligations under EU legislation. However, we reiterate that we would support a comprehensive, ‘all-in’ model that considers all materials and products for inclusion, including packaging formats such as beverage cartons that are currently out of scope. This would provide a level playing field for all packaging materials and would help avoid unintended consequences.

ACE Ireland’s position on an ‘all-in’ model aligns with environmental groups such as VOICE Ireland and Friends of the Earth. Results from a consumer survey run by VOICE Ireland in October 2020 also supports this position with 88% of respondents indicating that they are in favour of an ‘all-in’ model. With opinion relatively consistent across age ranges of those polled, the results echo growing consumer trends to prioritise sustainability.

Why DECC should consider a digital DRS

To achieve an ‘all-in’ model quickly and inexpensively, ACE Ireland believes that the DECC should consider a digital or smart DRS rather than the conventional ‘return to retail’ scheme. A digital DRS would ultimately provide a more flexible and adaptable system for accepting additional materials such as beverage cartons.

We believe the adoption of a digital DRS would result in a more user-friendly system, where consumers could access the scheme through placing materials in their mixed dry recycling (MDR) bins collected at kerbside. A digital DRS would remove the burden on consumers to store used packaging materials in their homes and having to return them in bulk to the shop or supermarket during their next visit. We suggest that this system would secure greater consumer buy-in and in turn would increase presentation rates in the MDR kerbside system with the potential to drive up recycling rates across multiple materials including beverage cartons as listed on the MyWaste.ie household recycling list rather than just two material types as proposed in the current scheme.

While we acknowledge that digital DRS is a relatively new concept, we have seen this trialled in Northern Ireland and in North Wales using smartphone technology and applications. We believe this is the natural progression from the traditional manual and relatively low-tech systems and it offers exciting potential for future upgrading, which would otherwise prove very expensive to implement, for example if the scope of materials in the scheme was to be extended.

Why beverage cartons should be included in the DRS

Life cycle analysis by the Heidelberg Institute for Energy and Environmental Research shows that beverage cartons are among the best environmental performers of all drinks packaging formats; fully recyclable, low carbon and primarily made from wood fibre – a renewable, bio-based material. The inclusion of beverage cartons within the DRS would support and reward their strong life-cycle performance, thus helping Ireland to meet its objective of building a circular economy.

In summary we welcome DECC’s intention to consider options to incorporate other materials in the Scheme later, following a period of successful operation of the DRS focusing on plastic bottles and aluminium cans. However, as outlined above we believe due consideration should be given to the introduction of a digital DRS which could include a wider range of drinks packaging. Additionally, as part of the legislative framework around the Scheme, there should be a commitment to set specific timelines and frequencies for reviewing the Scheme and a commitment to actively consider additional materials.

Response to details of the Scheme to be set in regulations

Producer responsibility

The DRS will be a mechanism for producers to comply with the overall Extended Producer Responsibility (EPR) legislation. Therefore, producers whose packaging is in scope of the deposit system should be subject to the same requirements as producers whose packaging is not in scope of the deposit system.

DRS system operators

ACE Ireland supports the proposed DRS operator framework, consisting of relevant producers, or a corporate body acting on their behalf. This approach has worked well in terms of other EPR systems in operation in Ireland and will help ensure transparency and accountability for the implementation of a DRS system. We do not believe the responsibility of operating the Scheme should fall to the retailer, but retailers and producers should be involved through representation on the board of the designated operator.

Retailer obligations

The retailer obligations as set out in the framework align with what ACE Ireland envisages for the DRS. To achieve full support and engagement, it is important that the designated operator ensures the DRS works for smaller retailers as well as larger retailers, and that participation in the DRS does not impact on their overall business operations, for example because of having less floor space in store.

The deposit

While ACE Ireland does not have a specific view on the deposit rate, we would encourage the Minister, DECC and the DRS operator to ensure a balance is struck in setting an appropriate rate which provides an incentive for citizens to use the scheme but not one that adversely impacts on sales.

We support the preferred option, arising from the previous consultation, to have variable deposits based on volume of the product, and we welcome the commitment to provide for this in the regulations. In this regard, ACE Ireland believes specific provision needs to be given for setting rates for multi-packs. Failure to address this will result in significant price increases for products in multi-packs compared to – for example – those in large plastic bottles. 

Citizen / consumer role

For a DRS to work effectively it must be accessible and enable easy use for citizens. The opportunities offered by digital DRS systems – which can also be integrated into existing kerbside collections – should be explored.

An extensive citizen information campaign should also be activated by the designated operator to align with the launch of the DRS. The campaign should be driven by clear and concise messaging on how the DRS works and how citizens should use it.

The beverage carton industry releases ten-year roadmap outlining vision and commitments for its sustainable packaging

ACE, the Alliance for Beverage Cartons and the Environment, and its members SIG Combibloc, BillerudKorsnäs, Elopak, Stora Enso and Tetra Pak, have set the industry’s vision for the future: we will deliver the most sustainable packaging for resilient food supply systems which is renewable, climate positive and circular.

Through its robust and ambitious roadmap, the industry commits to take action on all parts of the industry value chain, from sustainable sourcing to climate impact and recycling. Increasing the collection and recycling of beverage cartons to reach a 90% collection rate and at least a 70% recycling rate by 2030, and the decarbonisation of the industry’s value chain in line with the 1.5oC aligned science-based targets are included in the ten commitments.

In line with the vision of ACE members, beverage cartons will be:

  • Made only from renewable and / or recycled material.
  • Fully recyclable and recycled.
  • Made entirely from sustainably sourced raw materials.
  • The packaging solution with the lowest carbon footprint 

“The industry has set high and ambitious standards for the next ten years,” said Annick Carpentier, Director General of ACE. “We look forward to fostering a dialogue with EU decision makers to ensure that the necessary regulatory conditions are in place to support the industry’s journey towards beverage cartons as the sustainable packaging choice for today and tomorrow.”

Beverage cartons are a recyclable low carbon packaging solution that protect food and beverages, allowing their safe use and transport while also preventing food waste. With the commitments and targets set in the 2030 Roadmap, the industry will strive for its packaging to continue to actively contribute towards the ambitions of the EU Green Deal, specifically climate neutrality, circularity, biodiversity, and resilient food systems, while never compromising the health and safety of consumers.

“The industry continues to invest in innovation and technology to increase beverage carton recycling,” said Marcelle Peuckert, President of ACE. “The industry needs an enabling policy framework that will continue to support our investments and innovation over the next decade.”

ACE members have outlined clear deliverables, will report on the Roadmap’s overall progress on a regular basis, and will develop, add, and adapt metrics should they not currently exist, also in partnership with others.

ACE Ireland members build on commitment to verified traceability of wood fibre

Members of the Alliance for Beverage Cartons and the Environment Ireland (ACE Ireland) – Tetra Pak, Elopak and SIG Combibloc – are continuing to build on their commitment to wood fibre traceability achieved in 2015, according to the 10th Proforest report on the industry’s Chain of Custody (CoC) progress.

In 2015, ACE Ireland members met the targets committed to in 2007, that 100 per cent of wood fibre purchased globally by the member companies was either FSC certified or FSC controlled wood. Proforest, an independent organisation working in the field of natural resource management, recently carried out a tenth progress update to cover the period of 1st January to 31st December 2019. The report shows that the companies have continued to make progress on their commitments and extend this across their supply chain.

The report shows:

  • All 46 of the manufacturing plants operated by the three ACE Ireland members are Chain of Custody-certified.
  • All of the mills and traders which supply liquid packaging board (LPB) to the ACE members were Chain of Custody-certified.

Commenting, Chief Executive of ACE Ireland, Richard Hands said: “The latest report from Proforest illustrates the beverage carton industry’s continuing commitment to ensuring sustainable sourcing of its raw materials and incorporating this commitment into their business strategies.”

Responsibly sourced, renewable materials have a key role to play in supporting a low carbon circular economy. In Sweden and Finland, where most of the wood fibre for European food and drink cartons originates, forests are expanding with growth in forest volume increasing year-on-year as annual growth exceeds cuttings.

“ACE Ireland members have a clear interest in ensuring that forests are responsibly managed as, on average, 75 per cent of a food or beverage carton is made from this natural renewable material.

“Traceability is one of our industry’s key strategies in ensuring the responsible sourcing of primary raw materials, which is, in turn, critical to achieving sustainable economic growth”, concluded Mr Hands.

ACE Ireland’s response to the public consultation on a deposit and return scheme for Ireland

The Irish Government in its Waste Action Plan for a Circular Economy committed to introducing a Deposit and Return Scheme (DRS) for Ireland. In November 2020, ACE Ireland responded to an Irish Government ‘consultation on potential models’ to share our views on how a DRS should operate in Ireland.

ACE Ireland strongly advocates for consideration to be given for the inclusion of Beverage Cartons in any DRS for Ireland. See below our response to the questions asked as part of the consultation.

The Report recommends a centralised, operational model for Ireland. Do you agree with this recommendation?

ACE Ireland agrees with the recommendations of the Eunomia report for a centralised operational model for Ireland that is producer owned and led. The establishment of a Central System Operator would help ensure greater transparency and accountability for the implementation of a DRS system which via underpinning legislation can be mandated by Government to achieve performance targets, particularly in the context of ambitions targets set out in the Waste Action Plan for a Circular Economy.

As referenced in the consultation document, a centralised approach has worked well in terms of other extended producer responsibility models such as Repak and WEEE Ireland. As this DRS will be a relatively new approach to recycling in Ireland, ACE Ireland believes that centralised model is will be the most effective means to drive public awareness and educate Irish citizens with regards to how the DRS works and why they should engage with it.

Are there other models you believe could work in an Irish context?

While ACE Ireland welcomes the proposed introduction of a DRS scheme and supports a centralised model for the introduction of the scheme, we do believe there is room to significantly broaden the scheme to include a wider selection of materials. In a Red C poll of over 1,006 Irish adults aged 18 or over, environment charity Voice Ireland revealed that 88 per cent of people surveyed ‘support an expansive DRS system taking in as many drink containers as possible’. The poll conducted from 1st – 5th October 2020, showed that most Irish people support the inclusion of metal cans, plastic water bottles, plastic milk bottles, glass bottles, coffee cups and drink cartons and pouches.

As noted in Section 6 of the Consultation Document on Potential Models for Ireland, the scheme will ‘not apply to glass bottles or composite beverage containers such as Tetrapak/Elopak’. However, there is a strong rationale for considering the inclusion of beverage cartons within the DRS, particularly in the context of the Government’s commitment to set specific recycling targets for packaging formats such as beverage and food cartons, as set out in the Waste Action Plan for a Circular Economy.

It is worth noting that life cycle analysis undertaken by the Heidelberg Institute for Energy and Environmental Research shows that beverage cartons are among the best environmental performers of all drinks packaging formats. They are also fully recyclable and primarily made from renewable, low-carbon paperboard. It is crucial, therefore, that systems which seek to drive greater circularity in the economy also support such low-impact packaging, thereby helping to achieve the Irish Government’s objectives outlined in the Waste Action Plan.

The results in the VOICE Ireland, Red C poll highlights the public appetite to see an expanded range of materials for inclusion in the DRS. We therefore recommend that there should be a deposit return trial of all materials to provide the evidence needed for a well-informed decision on materials which could be included in the DRS further down the line. Such a trial should include beverage cartons which can be recycled into a range of high-quality products.

Furthermore, if beverage cartons continue to remain excluded from the initial list of materials in-scope, we would strongly advocate the inclusion of a formal mechanism in the legislation underpinning the scheme to require the regular review of materials included. This mechanism would place the responsibility upon the DRS operator, in consultation with relevant stakeholders, to provide recommendations to the DCCAE for additional materials to be incorporated into the Scheme.

Incorporating such a mechanism will provide a way for new materials to be considered, helping to futureproof the Scheme, embedding flexibility and responsiveness, and enabling it to adapt to new materials and innovations in the packaging market.

What role should waste collectors play in the operation of a DRS?

We do not have a view on the role the waste collectors should play in the operation of the DRS, but it is critically important that existing kerbside collections must not be undermined by high-value materials being diverted away by the DRS. Many packaging formats will remain out of scope of the DRS – both beverage and non-beverage – and they will continue to rely on existing systems for collection. It will be important to ensure that a well-designed EPR system maintains the viability of high-quality kerbside collections, otherwise recycling performance overall could decrease.

The DRS study proposes a deposit per container of €0.20. Do you think this is appropriate? If not, should it be higher or lower or should different deposit rates apply depending on container size?

It is too early to put a figure on the optimum deposit level but understanding the experience of other similar countries would be useful. There are many factors that will determine optimum deposit level, and these will vary by country. However, the deposit would need to be high enough to incentivise consumers to return the container, but not so high as to distort the market and encourage fraud.

We note that some 78 per cent of people who responded to a VOICE Ireland Red C poll in October 2020 said they backed the introduction of a variable deposit fee, where consumers pay a deposit that varies based on the size and material of the container.

While a flat fee would seem to be the simplest approach and would not discriminate, further information is required to determine whether a flat rate or variable rate is appropriate or a composite of both. It must be considered that the purpose of the DRS is to incentivise consumers to return their package for recycling, irrespective of size or type, rather than encourage the use of one package over another. However, the principle should be that all containers carry a deposit, including those sold in multi-packs.

Consumers need to know about a DRS long before it becomes operational – do you have any suggestions as to how best the introduction of a DRS can be communicated to the public?

Ensure comprehensive national consumer outreach using all available channels.

What enforcement measures should be considered in parallel with the introduction of a DRS?

Consider financial penalties for non-compliance.

How should cross-border issues be treated to ensure producers are not at a competitive disadvantage relative to producers in Northern Ireland?

A simple and clear visible marking should be mandatory for all in-scope materials so that consumers can easily identify whether they have paid a deposit reducing the risk of fraud. It would be useful to learn from the experience of other countries with regard to this issue.

ACE announces increased EU beverage carton recycling rates

EU beverage carton recycling hits 51 per cent

ACE Ireland has welcomed the latest figures released by ACE Brussels on EU beverage carton recycling rates, which exceeded 50 per cent for the first time. The recycling rate for beverage cartons in the EU28* rose to 51 per cent in 2019, a rise of 2 per cent on 2018 figures and a continued year-on-year increase.

“We are pleased that the steady annual increase of the recycling rate for beverage cartons in 2019 surpassed 50 per cent,” said Annick Carpentier, Director General of the Alliance for Beverage Cartons and the Environment (ACE) in Brussels. “This is proof of our industry’s efforts and enhances the message that beverage cartons are recyclable and are being recycled at scale in Europe.”

Beverage cartons, made largely from renewable materials, contribute positively to a low carbon circular economy. The industry is driving beverage carton recycling across Europe and is committed to efforts that support the increase of the recycling rates in all EU Member States. The industry calls on policymakers at the European and national levels to assure that beverage cartons are collected for recycling separately, and to support a collection target to ensure beverage cartons are collected for recycling.

“With an upcoming EU legislative agenda towards more sustainable packaging, the beverage carton is well positioned with a 51 per cent recycling rate. This is an opportunity to inform policymakers at all levels that beverage cartons are a safe, circular and sustainable packaging solution with a low carbon footprint, and how the beverage carton you use at your table can be easily collected and recycled,” continued Ms Carpentier.