“Legislation needs to be tailored versus specific products”

In the latest episode of the podcast Forum for Bioeconomy, host Anders Bolling is visited by Anna Holmberg, Director and Head of the Brussels office at Swedish Forest Industries Federation.

Anna Holmberg has a background of working in the pulp and paper and chemical industries before entering the area of public affairs.

– I've managed to tie together my business experience with a huge interest in the way that politics are developed today, she explains in the podcast.

The need for a Brussels office became apparent to the Swedish Forest Industries Federation a few years ago.

– We saw that EU policy was affecting our members more and more, both positively and potentially negatively. We came to realise that we needed to be in Brussels permanently, to network, to monitor, to meet and talk to people both generally but also related to ongoing processes.

Within shortly, the European Commission is to adopt the Sustainable Products Initiative and a legislative proposal on substantiating green claims. In the summer, a revision of the Packaging and Packaging Waste Directive is expected.

– The Commission has identified a need to make it easier for consumers to make informed and sustainable choices. The Commission has further stated that this will require EU common legislation. Our Federation usually has a very strong belief in the market economy being a self-regulatory force, but we acknowledge the importance of empowering consumers in the green transition, Anna Holmberg says.

Packaging fit for purpose

Instead of arguing that we need to reduce our use of packaging across the scale, Anna Holmberg believes that it is better to ensure the packaging that is used is being “fit for purpose”.

– I'm the first one to admit that within fibre based as well as other types of packaging there is some over packaging going on. But packaging is not produced and used for its own sake, it is used because we need to protect food for instance, or we need to be able to transport goods in a safe way.

Some of the packaging that we use today is single use, meaning that you only use it once. Anna Holmberg does not see an issue with that. At least not if there are collection systems enabling the informed European citizen to leave this packaging in a collection system from where it can be recycled. She emphasizes the importance of single use packages in certain sectors.

– In the medical sector single use is important as well as in the food and food service sector. So the discussion between single use and reuse it's not black or white, not one or zero, we need to have a much, much more nuanced discussion, she says.

So what is important, according to the Swedish Forest Industries, for the legislator to avoid?

– First of all there will never be a one size fits all solution. Legislation needs to be more tailored versus specific products or specific product groups, Anna Holmberg says.

She also requests a balanced and knowledge-based discussion.

– We need conclusions to be based on sound scientific evidence, she says.

– And thirdly I would say that the application of what's called mandatory recycled content needs to be done with a bit of Fingerspitzengefühl, as the Germans say.

Recycling rate is not everything

She develops her reasoning by explaining how, in the political discussion in Brussels, it is often raised that if we put a mandatory recycled content on products, they will automatically be more sustainable.

– If it is a product from a value chain that has low collection and recycling rate today, then yes, perhaps that could be a good policy tool to push that value chain to improve, Anna Holmberg says.

– But if you instead imply it on fibre-based packaging, which has a recycling rate above 82% already today, you could actually risk destroying a very well working system.

Sweden has plenty of forests and a well-developed sustainable forest-based industry. Therefore, packaging produced in Sweden is made mainly from fresh fibres In continental Europe it is more common that fibre-based packaging is based on recycled fibres.

– If a demand for mandatory recycled content would be put on all types of fibre-based packaging it would result in fibres having to be transported around Europe. This would in turn increase emissions and costs and reduce sustainability.

Legislative proposals that doesn´t consider all these parameters’ risk destroying an already well working system.

– Here the Commission must find that balance between making sure those that are behind could actually get up to speed and at the same time making sure that the front runners can continue to develop.

Five circular characteristics

The European Commission highlights five characteristics as of special importance for circular products: recyclability, reusability, durability, repairability and upgradability. Renewability, however, is not included. Problematic, Anna Holmberg states.

– If we are serious about Europe being the first climate neutral continent by 2050, we need to move from todays linear and fossil-based economy to a more circular one. But also, to an economy which to a higher extent is based on renewable resources. In other words, we have to make sure that we keep the fossils in the ground, Anna Holmberg says.

Therefore, she argues that renewability is just as an important principle for sustainability as recyclability or durability.

– We think that it really makes sense to include renewability already in the Sustainable Products Initiative. We need to move to a more circular economy and an economy which is to a higher extent based on renewable resources.

– I am the first one to admit that our products are not the only solution to achieve climate neutrality, we are not the silver bullet. But we are important contributors. Society needs our products to transform, but to be able to contribute even more we must make sure that the upcoming EU policies will acknowledge the contribution of fibre-based packaging.