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ROUND TABLE Food Packaging and the Circular Economy: Making Health and the Environment a Priority Hosted by MEP Piernicola Pedicini & MEP Claude Turmes Organised in collaboration with SAFE – Safe Food Advocacy Europe 16 May 2018 - European Parliament, Brussels


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Introduction On May 16, 2018, SAFE organised a Round Table on Food Packaging and the Circular Economy. The event was held at the European Parliament and hosted by MEP Pedicini and MEP Turmes, with the journalist Sara Lewis from European Food Law as moderator. The audience included European Commission’s officials, EFSA staff, journalists, MEPs, NGOs and several representatives of the food industry. The Round Table was organised in the framework of the LIFE Programme 2018-2019 managed by the European Commission (DG Environment and DG Climate Action). In the context of this programme, SAFE’s activities cover lobbying, advocacy and the implementation of an awareness raising campaign for European consumers. The main objectives of SAFE’s project are: ameliorating the legislation on food packaging by advocating for a better regulatory framework to protect consumers’ health and the environment, reducing the use of plastic packaging and promoting the use of alternative food contact materials that have a better impact on human health and on the environment, such as glass and other materials. To better inform its policy objectives, SAFE has actively collected scientific opinions of experts on food packaging, following debates on the matter and participating in several conferences and events. In anticipation of the Round Table, SAFE contacted over 12 Members of the European Parliament and had meetings with several of them, including MEP Elisabeth Morin-Chartier – Quaestor of the European Parliament, and Denisa Kuchtikova – Advisor to Quaestor Vladimír Maňka. SAFE also contacted two officials of the European Commission, namely Mr Werner Bosmans, Policy Officer at Dir B1 Sustainable Production, Products and Consumption (in charge of the coordination of the Plastics Strategy) and Mr Bastiaan Schupp from the Commission’s Directorate-General for Health and Food Safety (DG SANTE) – Food Processing Technologies and Novel Foods. As regards awareness raising activities, SAFE is currently working on the implementation of its campaign “Curb Plastic Curb Waste”, which will include two events, one in Brussels and one in Amsterdam. During the two events, which will be held in June and July 2018, a total of 2,500 households will receive a set of sustainable packaging and a guidance document outlining the importance of reducing food packaging, with practical advice for consumers and information on the benefits of such reduction for both the environment and consumer’s health.

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Piernicola Pedicini, Member of the European Parliament MEP Pedicini opened the round table by recalling the work done in 2017 on Food Contact Materials (FCMs), to achieve a more detailed FCM legislation. He pointed out that FCMs are a significant source of human exposure to chemical substances, as they can harbour harmful compounds such as Bisphenol A (BPA), a known endocrine disruptor. For this reason, MEP Pedicini believes there should be more coordination between FCM Regulation and REACH (Registration, MEP Pedicini (second from the right) opening the round table discussion Evaluation, Authorisation and Restriction of Chemicals) Regulation. Indeed, an increased transparency on the chemicals that are present in our food will allow the ban of some harmful plastics. MEP Pedicini concluded his address by summarising his position as follows: 1. Plastic packaging and FCMs should be reduced and replaced by reusable packaging solutions. 2. Bio plastic could be part of the solution if the material is truly compostable. 3. True circularity can only be achieved by reducing the amount of virgin plastic available on the market.

Claude Turmes, Member of the European Parliament

MEP Turmes (second from the right) addressing the audience

MEP Turmes addressed the audience by remarking the plastic industry’s strong lobbying power. Indeed, the message diffused by the plastic lobby is that plastic Food Contact Materials are necessary to reduce food waste. However, the statistics show how, in the last few years, food waste has grown as our plastic usage has increased, resulting in an evident correlation between the two variables. Nonetheless, despite the lobbying efforts of the plastic industry, civil society is 3

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becoming increasingly aware of the harmful nature of the overproduction of plastic. MEP Turmes also suggested that laws should be put in place to help the work currently done by advocacy groups and NGOs, addressing, for instance, the elimination of chemicals used in plastic packaging. Such initiatives would also reduce the loss of quality associated with recycled materials, which are often not used as FCMs due to their contact with chemicals. MEP Turmes concluded his speech by noting that a closed loop system will only be achieved when all the chemicals used in plastics are safe for food contact applications, regardless of their use. Moreover, it is very important to share with the public best practices and good examples and to reach an increasing number of citizens through professional communication on the negative impact of plastic packaging.

Floriana Cimmarusti, Secretary General of SAFE Ms Cimmarusti started by presenting the NGO SAFE - Safe Food Advocacy Europe, its mission, Members and activities in the framework of the LIFE Project. She then introduced the environmental and health concerns associated with single-use plastic, focusing on the fact that EU consumers throw away an average of 30kg of plastic packaging per person every year and that chemical migration of dangerous substances from Food Contact Materials into food is a grave issue that needs to be tackled. She then summarized the most recent initiatives from European institutions (the

(From left to right) Alice Bernard, Sara Lewis, Floriana Cimmarusti

European Strategy for Plastics in a Circular Economy of January 2018, the Commission’s decision to phase-out single-use plastics in its buildings of February 2018) and NGOs, such as the letter of Rethink Plastic Alliance to the European Parliament of April 2018, calling to end usage of single-use plastics in the Parliament’s premises.

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Ms Cimmarusti also presented SAFE’s policy proposals on the subject of FCMs, namely the adoption of a specific EU legislation and rules for non-harmonised materials, the adoption of better framework rules to help Member States perform monitoring and controls more efficiently, the importance of including clear, general legal criteria defining endocrine disruptors in the future FCM legislation and the need for a better coordination and a more coherent approach between the REACH Regulation and the FCM Regulation. She added that European consumers have the right to more information and that more studies should be conducted on materials that are allowed for use in food contact applications, especially recycled plastic. She finally criticized the extensive use of plastic packaging in the EP and called for a total ban of single-use plastic in the Parliament buildings. She also addressed the issue of recycled plastic, explaining that the variety of recycling methods and the current lack of scientific research on the matter make it impossible to ensure consumer’s safety in the occurrence of migration of chemical substances from recycled plastics.

Elisabeth Morin-Chartier, Member and Quaestor of the European Parliament Since MEP Morin-Chartier could not attend the Round Table in person, she addressed the audience through a video that she recorded especially for the event, after meeting with SAFE’s Secretary General Floriana Cimmarusti. MEP Morin-Chartier echoed SAFE’s position regarding the need to reduce the amount of plastics used in the European Parliament and announced the Parliament’s goal of accomplishing a zero-plastic MEP Morin-Chartier (via video) announcing the European Parliament's goal of accomplishing environment by summer 2019. a zero-plastic environment by summer 2019. She also explained that, to achieve such a change, the decision must be taken by the College of Quaestors and then presented for approval in front of the Bureau, the body responsible for managing the catering contracts for all Parliament facilities and meeting rooms. She explained that the Quaestors are working to achieve the objective of reducing plastic bottles in the EP by introducing water fountains in all three working sites 5 SAFE – Safe Food Advocacy Europe A.S.B.L. Mundo B- Rue d’Edimbourg 26 1050 Brussels Belgium +32 (0) 28 93 08 96

of the Parliament; in fact, 127 have already been installed and the final goal is to have 300 water fountains spread across the three buildings. MEP Morin-Chartier also clarified that this move toward a zero-plastic work environment will not only benefit the environment and human health but will also result in substantial economic gains. She finally addressed the problem of the catering services of the EP, pointing out the lack of returning schemes of food packaging and the important lobbying work that needs to be done towards the suppliers of the Parliament to promote reusable packaging and alternative materials to single-use plastic.

Alice Bernard, Chemical Lawyer at Client Earth Ms Bernard started her presentation by informing the audience of the lack of regulation on the use of endocrine disruptors in FCM applications, due to the so-called “safe level” approach. She then defined endocrine disruptors as chemicals that can interfere or block the endocrine (or hormone) systems, disturbing the regular functioning of our bodies and causing serious health issues such as cancer, infertility, learning disabilities and other developmental disorders. Ms Bernard illustrated the different level of acceptance of ED’s presence in food, explaining that while endocrine disruptors are banned in many other Ms Bernard explaining the concept of "safe-level" applications (such as pesticides), the current legislation on FCMs foresees specific migration limits set per chemical, with the “safe level” determined case by case. Ms Bernard then presented the advantages and disadvantages of the “safe level” approach compared to the “no approval” approach and explained that, although the latter may generate a few false alarms, it always succeeds in preventing harm to human health due to mistaken scientific estimations. In Bernard’s opinion, attitude towards risk is a societal choice, which should be made taking into account not only the benefit of businesses, but also – and especially – the public interest. In conclusion, given that hormones play their messenger role in our bodies at low doses and that timing of exposure may matter more than the dose itself, Bernard underlined how the most recent review of scientific evidence by the European Chemicals Agency (2017) questions the possibility to set a “safe level” for endocrine disruptors.

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Meadhbh Bolger, Resource Justice Campaigner at Friends of the Earth Europe Ms Bolger presented the shortcomings of Life Cycle Assessments (LCA) in food packaging policy, which are extensively used to evaluate the environmental performance of packaging. Bolger explained that LCA are currently very subjective, as manufacturers can select which indicators they want to include in the assessments. The information provided by the current LCA have very few environmental indicators (they focus on green gas emissions) and this method does not allow for a proper assessment of the health impacts of FCMs. Ms Bolger also indicated that LCA virtually ignore the “end of life” of FCMs, therefore neglecting whether FCMs can be Ms Bolger (fifth from the left) addressing the audience recycled, reused, must be incinerated or end up in a land field. End of life and the health impact of possible chemical migration from packaging are currently not being addressed by LCA. She concluded her presentation by proposing a few solutions and recommendations, including zero and reusable packaging, shorter food supply chains, policy changes and a broad re evaluation of LCAs to assess whether they are the right tool or not.

Alberto Mantovani, Research Director at the Italian National Health Institute (ISS) Regretfully, Mr Mantovani could not attend the Round Table in person due to the cancellation of his flight. In the video presentation that he recorded especially for the event, which focused on the Emerging Toxicological Issues in Food Contact Materials, Mr Mantovani highlighted the following four categories of risks: Nanomaterial, Endocrine disruptors, Non-intentionally added Substances (NIAS) and Neurotoxicants. All four categories or risky materials are currently being used in FCM applications despite their documented health concerns. Mr Mantovani also remarked the need for a more robust and transparent risk assessment of both existing and emerging risks of FCMs. Mr Mantovani joined the discussion via video

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Anna Hagemann Rise, Communication Director for Fazer Lifestyle Foods at Fazer Ms Hagemann Rise opened her address by presenting the corporate social responsibility (CSR) efforts undertaken by her company and underlining that innovation and sustainability are at the core of Fazer Lifestyle Foods. The brand’s star product Froosh, the number one smoothie brand in the Nordic, is the perfect ambassador for the company, as it is not only sustainably sourced and produced but also sustainably packaged. Indeed, Fazer Lifestyle Foods uses glass as the primary FCM for their smoothies. In her view, using a glass packaging has multiple benefits as it allows the product to be 100% recyclable while also extending the Ms Hagemann presenting Fazer Lifestyle Foods CSR initiatives smoothie’s shelf life without having to resort to chemical additives and preservatives. Ms Rise also encouraged other food companies to invest in their CSR efforts and review their current packaging material to find more sustainable and green packaging solutions.

Bastiaan Schupp, European Commission’s Directorate-General for Health and Food Safety (DG SANTE) – Food Processing Technologies and Novel Foods Mr Schupp started his presentation by recognising that, as of now, FCMs are poorly regulated. Firstly, the current definition of FCM is too broad and generic, which makes regulating these materials significantly more difficult. Moreover, out of the 17 approved FCMs there only exists a detailed legislation for four of them. Mr Schupp then indicated that, in the upcoming months, the Commission will mainly focus on the following five points: the evaluation of FCMs, regulating recycled FCM plastics, regulating plastic sub-materials, 8 Mr Schupp addressing DG SANTE's position on current FCM Regulation

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regulating ceramic FCM and regulating printed FCM. He also clarified that the key role of DG SANTE in the European Commission’s strategy for a Circular Economy is to ensure a safe implementation of the Plastic Strategy. The Commission will also encourage a shift from the main plastics used in FCM applications (polyolefins) towards recyclable alternatives, as polyolefins are not recyclable. Finally, Mr Schupp noted that the Commission is not currently working on a new legislative proposal on FCMs, which is expected for the coming years but will not be presented before the next elections to the European Parliament, in 2019.

Margrete Auken, Member of the European Parliament MEP Auken was the last speaker of the day and echoed the need for better FCM Regulation, a need that is even more pressing in the light of the recent China ban of all waste coming from the EU. MEP Auken underlined that the safe recycling of plastic is very important, especially when the end use of these materials will be FCMs. In her view, the EU will need to work on better recycling and waste management, although recycling and reduction of plastic alone will not help attain the goals set out by the Plastic Strategy communication. MEP Auken also called for an investment of time and energy from governments, the industry and consumers towards finding truly sustainable alternatives to plastics MEP Auken (second from the left) addressing the audience in FCM application. She finally noted that some alternatives, such as biodegradable plastics and oxodegradable plastics, are not true solutions to the current problem.

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Conclusion The Round Table was held in an open discussion format. The topics of food packaging in the circular economy and of FCM’s health and environmental impact were discussed. All speakers and attendees were successfully able to discuss their views and share their expertise. The dangers, challenges and opportunities of our current packaging systems were explored, in a mindful discussion toward achieving the priorities put forward by the recently adopted Plastic Strategy of the European Commission.

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Minutes Round Table on Food Packaging at EP / SAFE  
Minutes Round Table on Food Packaging at EP / SAFE