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Through the industry’s 2030 Roadmap, ACE Europe (The Alliance for Beverage Cartons and the Environment) members adopted an ambitious vision for 2030 and beyond: to deliver the most sustainable packaging for resilient food supply systems, which is renewable, climate positive and circular.

As part of the Roadmap, our industry committed to develop and annually review the Design for Recycling (DfR) Guidelines that will provide producers of beverage cartons with technical guidance to identify the materials needed in the packaging composition that are compatible with existing recycling processes and how the recyclability of beverage cartons can be optimized.

The guidelines published by the industry are based on expert judgement and consultation with targeted stakeholders including recyclers, waste management operators, and technology providers. They are complementary to the published 4evergreen DfR Guidelines for standard recycling processes and will feed into the upcoming 4evergreen Guidelines for enhanced processes (specialized recycling plants).

“Beverage cartons are recycled throughout the EU,” said Annick Carpentier, Director General of ACE. “By providing guidelines on the material composition of beverage cartons and how they should be designed for recycling, the industry continues to show its commitment to increasing the recyclability of beverage cartons. The Design for Recycling Guidelines are a sound basis to define the recyclability of packaging.”

Sorting and recycling technologies are developing and bringing innovation to the market while in parallel legal requirements evolve. Our industry is committed to reflect these developments by annually reviewing the Guidelines.

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 1.5^oC 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.

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 1^st January to 31^st 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.

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 1^st – 5^th 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.