Why sustainability is important to the adhesive tape industry
Afera’s 7th webinar in COVID-19 lockdown exit series explored the European legislative business case for embracing “sustainability” in its various forms
The second-to-last biweekly Webinar targeting issues around the European “lockdown exit”, Afera’s recent interactive session offered an outside-in regulatory view of the relationship between business recovery and sustainability in the European tape industry. (The last of the series provided an inside-out view of “The state of sustainability in adhesive tapes”.)
50 Afera Member Company delegates tuned in to learn about the standardised definition of sustainability and all related E.U. initiatives, including the United Nations Sustainable Development Goals, the European Green Deal, the Circular Economy Action Plan, the updated Packaging and Packaging Waste Directive, the Chemicals Strategy for Sustainability, the updated E.U. Climate Law, the Single-Use Plastics Directive and sustainable COVID-19 crisis recovery efforts.
“During the Webinar, we polled our audience about their personal and professional relationship with the topic of sustainability—specifically, if they had made the European Green Deal a part of their company’s business case,” said Afera Regulatory Affairs Manager Pablo Englebienne. “Interestingly, we found that about half are implementing it or think it should be implemented, while the other half said ‘no’ or they don’t know.” Mr. Englebienne also introduced the dedicated Afera Sustainability Working Group, which will explore the necessities and opportunities in embracing European sustainability principles—for instance, avoiding waste and promoting recycling—throughout the adhesive tape value chain.
Definition of sustainability
The United Nations’ definition of sustainability states, “For development to be sustainable, it should meet the needs of the present without compromising the ability of future generations to meet their own needs.” There are 3 core elements of sustainability that need focus: economic growth, social inclusion and environmental protection.
We asked participants about their view on sustainability from a personal or company perspective. 2/3 of registrants see sustainability as a business opportunity, ¼ feel unclear about its significance to them and a small number see it as an additional business expense.
Sustainable Development Goals (SDGs)
In 2015, the U.N. Member States adopted the 2030 Agenda for Sustainable Development that provided a shared plan for sustainable development based on 5 pillars: people, prosperity, planet, peace and partnership. The Agenda was expressed in the form of 17 overarching SDGs, which specify principles and corresponding concrete steps to be considered and taken by governments, individual companies and associations in order to achieve sustainable development.
The European Green Deal (EGD)
Announced in December 2019, the EGD is the embodiment of how the E.U. aims to achieve the U.N. SDGs. One of the EGD’s primary goals is that Europe becomes climate-neutral by 2050. This will have to be achieved by protecting human, animal and plant life, and by cutting down on pollution. At the same time, E.U. companies will be enabled in becoming world leaders in developing clean products and technologies. Importantly, according to the European Commission, all of this should be done without creating inequalities and by ensuring that everyone is included in the process.
Do you already have a clear view of the impact of the Green Deal on your business? 9 out of 10 participants said that they are still figuring it out.
Afera Sustainability Working Group’s (Sus-WG) mission
We have set up a Sustainability Working Group (Sus-WG) under the leadership of Martijn Verhagen, Afera Technical Committee Member and team leader for liquid coated adhesives at Lohmann GmbH & Co. KG. Including several members of the entire adhesive tape value chain, the WG has one purpose in mind: promoting adhesive tapes as sustainable solutions.
In the SUS-WG’s mission statement, 4 of the U.N. SDGs are recognisable: planet, people, prosperity and partnerships. So, the Industry is working on sustainable solutions that will improve recyclability of the products into which tapes are incorporated. This is not only good for the planet, but it is what people want because it improves and protects their environment. Prosperity comes out of using an efficient, rational approach to sustainable development, with companies designing better products and forging beneficial partnerships to help themselves, the Industry and society reach our goals.
Why is the European Green Deal important to the adhesive tape industry?
The EGD is the main priority of the strategy for 2019 to 2024 of the von der Leyen Commission. A key aspect of the EGD is that it sets out a roadmap for several new legislative acts, with either new or updated legislation, as well as setting strategies for many topics that touch sustainability: European Climate Law, European Industrial Strategy, Strategy on Adaptation to Climate Change, the Circular Economy Action Plan, Farm to Fork Strategy, Biodiversity Strategy and Chemicals Strategy for Sustainability.
Circular Economy Action Plan (CEAP)
Particularly important to the EGD is the CEAP, which specifically focuses on many markets in which tapes are used, e.g. the packaging, electronics, plastics and construction arenas. Here we will see new or updated existing legislation coming into effect over the next few years.
Waste Framework Directive (WFD) and Packaging and Packaging Waster Directive (PPWD)
E.U. waste legislation, which was already in scope before the EGD, has already been integrated into the EGD with the CEAP. Both the WFD, ‘the mother of all European waste legislation’, and the PPWD are currently being updated.
Next Generation E.U.
The E.C. has already stated that funding for economic recovery from the COVID-19 crisis in the form of the Next Generation E.U. initiative will be necessarily tied to EGD objectives.
Circular Economy Action Plan (CEAP)
Announced on 11 March 2020 just as COVID-19 disruption was leading to lockdowns in most European countries, the CEAP is aimed at improving the circularity of the E.U. economy by increasing product durability, reusability, upgradability and repairability—basically preventing products from becoming waste earlier than necessary—and at the same time restricting single-use and disposable products.
The CEAP will promote recycling by requiring the incorporation of secondary raw materials into various products while increasing the quality of the recyclates that come out of treating the waste. The purpose is to reward sustainable products and/or penalise non-sustainable ones using, for example, the “polluter pays” principle.
Areas of focus relevant to tapes:
- Electronics: Longer product lifetimes including easier repairability, and improved collection and treatment, so that ultimately the development of tape products for electronics will keep the tapes relevant.
- Batteries and vehicles: New regulatory framework for batteries, boost in circular potential, so that batteries will have to be improved.
- Packaging: New mandatory requirements on what is allowed on the E.U. market, including the reduction of (over)packaging; extended producer responsibility (EPR) fees harmonisation across Europe.
- Plastics: New mandatory requirements for recycled content improvement and special attention for microplastics generation, as well as requirements for biobased and biodegradable plastics inclusion in the future.
- Construction and buildings: Strategy for Sustainable Built Environment promoting circularity of materials used for construction purposes.
Update of waste legislation: Packaging and Packaging Waste Directive (PPWD)
Originally approved in 1994, the PPWD sets the essential requirements (ERs) for the packaging materials with which all packaged products must comply. These involve reducing packaging waste and establishing design requirements for packaging materials.
Some of the ERs set in 1994 did not take Circular Economy requirements into consideration, so this is being newly addressed in the PPWD. The increased use of recycled material in packaging materials is an ER which is being re-evaluated for setting additional goals, as well as increasing the effectiveness and efficiency of EPR schemes.
PPWD essential requirements (ERs) updated in country-specific legislation
In April 2020, consultant Eunomia issued a guidance document on how the PPWD should be translated into national legislation and implemented by each of the E.U. Member States (MSs). Some of the main issues covered by the guidance could affect the adhesive tape industry.
With respect to use for packaging materials, adhesives are mentioned as possibly forming small particles during paper processing, resulting in “stickies” which hinder recycling by compromising both the equipment and the final product. This could lead to regulating the adhesives that can be used in packaging tape.
Furthermore, the siliconised paper liner for tape (e.g. for double-sided tape) is especially relevant to the pressure-sensitive labelling industry. Siliconised liner is stated as being non-recyclable, a delineation which may prevent the use of these types of release liners. There are technical solutions for recycling liners, and the requirements for these need to be regularised and specified, just as many criteria need to be set for recyclability of items throughout the supply chain.
A public consultation in which the E.C. invites stakeholders to provide comments on the updated ERs for its roadmap is open until 6 August 2020.
Extended producer responsibility (EPR)
The EPR schemes offer a way to implement the “polluter pays” principle, in which the cost of waste management is allocated to the original producer or an intermediary in the supply chain. This is mandatory for several waste schemes, including packaging (PPWD) and electronics (WEEE), but it requires country-specific implementation. Thus consultant Eunomia also prepared a guidance document on ERs, released in May 2020, with the aim of harmonising how the EPR schemes are implemented across all E. U. MSs as much as possible. The actual E.C. guidance is set for subsequent release and will be monitored by Afera.
An issue that must be addressed, as mentioned above, is the compromising of the paper recycling process by adhesives. This could potentially affect the recyclability of materials and therefore the way that the EPR schemes are introduced.
Chemicals Strategy for Sustainability
The E.U. is reassessing the fitness of the whole package of chemicals management legislation, including REACH, with sustainability in mind.
A key aspect of the roadmap includes simplifying substance assessment. Currently there are 3 potential European organisations that can assess substances for different purposes: ECHA (the European Chemicals Agency, EFSA (the European Food Safety Agency) and EMA (the European Medicines Agency). Sometimes they have to address substances within different legislative frameworks, and they can also issue different outcomes. This is something the Strategy aims to streamline.
Specifying the risks associated with endocrine disruptors (e.g. BPA), an emerging topic of the last few years, is also something that this initiative aims to do.
The Chemicals Strategy for Sustainability is also focussed on levelling the playing field for European manufacturers and importers, who sometimes free-ride on schemes that European manufacturers cannot avoid. This ultimately results in lower protection of human health and environment.
Combined assessment of simultaneous exposure to multiple substances is seen as important to the E.C. Currently evaluation of mixtures is not clearly regulated. They also want to target very persistent chemicals, such as polyfluorinated substances (PFAs).
The framework of this initiative will include a definition of sustainable chemicals having to do with how well a chemical can be put into the Circular Economy in terms of its recyclability. And, furthermore, whether it is an impurity that would affect the recyclability of some waste streams that then would prevent the reuse of these recyclates in high-valued materials.
E.U. Climate Law: climate neutrality by 2050: GHG emissions = GHG removal
The E.C. has proposed an updated Climate Law, another important initiative of the EGD to achieve climate neutrality by 2050. This means that the amount of emissions must be equal to the amount of removal of greenhouse gasses. The majority of greenhouse gasses (GHGs) is CO₂, but there are other gasses, such as methane, nitric oxide, Sulphur hexafluoride and nitrogen trifluoride (CH₄, N₂O, SF₆ and NF₃) which also must be taken into account. Currently under discussion are legislative targets for 2030 for GHGs is a 50-55% reduction of the levels of 1990.
A key issue of the current Climate Law is that recycling is not taken into account at all as a removal within its framework. Increasing recycling reduces GHG emissions directly by cutting emissions from landfills and indirectly by recycling materials which would otherwise be extracted and processed. The legislation takes recycling into account indirectly but never specifically mentions an aim to increase it. What the Climate Law does do is encourage sustainable renewable sourcing of bio-based materials, such as paper and plastics.
Single-Use Plastics Directive (SUPD)
Passed on 5 June 2019, the SUPD (E.U. Directive 2019/904) legal text clearly stated its aims but not the exact terms of implementation. Therefore, a guidance document for transposition into national law in each of the E.U. MSs was developed by a consultant and released in April 2020. This defines in more detail many of the terms which were left ambiguous in the original text agreed upon by the European Parliament. For example, the legislation describes the “main structural component”, which you would think signifies the largest amount in a material. In the guidance document, however, the “main structural component” is replaced by a “functional component” idea. Essentially, if in absence of this component the product cannot fulfil its function, then it is designated as a main structural component. Because of this crucial change in interpreting the legal text, some have debated the significance of the legislation to their own industries. Afera is monitoring the national applications of the legal text, that must be put into place within 2 years of the passing of the original E.U. directive, so by June 2021.
The division of plastic is another topic which was not defined in the original legislation. It was communicated that the definition under REACH, along with other parameters, would be used. The guidance document went beyond this, while not offering absolute clarity, so that even cellulose could be understood to be plastic. This has generated much discussion within the paper industry, and Afera will continue to monitor the situation as the legislation is adopted by each of the MSs.
Sustainable COVID-19 recovery
Set up by the E.C., Next Generation E.U. stipulates that funding for financial recovery will be tied to sustainable initiatives that follow the principles of the Green Deal. In addition to this, there are many initiatives coming out of NGOs, industry and trade associations that state there is interest from the private sector in a sustainable restart of the economy.
An example is the Ellen MacArthur Foundation which recently released a pledge supported by more than 50 large companies “to step up, not step back” in building a more sustainable future.
In the Netherlands, 250 leading companies, both large and small ranging from banking and services to manufacturing, have signed a pledged to include sustainability in recovery and how they plan to do this.
Lastly, ACEA (the European Automobile Manufacturers Association) have prepared a statement with 25 actions for a successful restart of the E.U. automotive sector, including several sustainability initiatives, like increasing the number of electric cars or alternatively fuelled cars.
The “Sustainability and business recovery in the new normal” Webinar slide deck including active links is also available upon request to the Secretariat. Any questions, comments or suggestions, as well as volunteers for participating in a future Webinar panel, can be submitted to Mr. Englebienne here.
Next webinar scheduled for 3 September – register now!
Afera’s next and last exclusive Webinar in our lockdown exit series “Navigating the COVID-19 crisis within the adhesive tape value chain” will take place after the summer holidays and will cover “State of sustainability in adhesive tapes”. This interactive session will offer an inside-out view of this topic, including input from a number of companies from the Industry on their approaches and experiences with implementing sustainability initiatives in their organisations, the effect of the COVID-19 crisis on sustainability, how Afera Members see the Green Deal and what the tape industry can do to improve sustainability.
The Webinar will be held on Thursday, 3 September, 14.00-15.00 CEST. Please register here.