By Peter Harding, President of UNESDA Soft Drinks Europe and CEO of Suntory Beverage & Food Europe

The EU is set to move towards a circular economy for beverage packaging. In just a couple of weeks, Members of the Environment Committee in the European Parliament will vote on their amendments to the EU Packaging and Packaging Waste Regulation (PPWR). In parallel, EU Member States are working towards adopting their position on this file by the end of the year. Among the key areas of attention in the PPWR is reuse and refill. It is absolutely critical that MEPs and Member States support sound measures that ensure that recycling, reuse and refill are complementary solutions, and reject proposals to increase the reuse and refill targets without further assessment of their environmental, economic and social impacts.

The EU is taking a leadership role in driving circularity and the PPWR is among the most ambitious EU policies in this regard. The European soft drinks sector, represented by UNESDA Soft Drinks Europe, supports the goals to better reduce, collect, recycle and reuse beverage packaging. We have already shown that we take bold voluntary actions to contribute to accelerating the green transition in Europe through our commitment to making our soft drinks packaging fully circular by 2030.

Our sector also supports reuse and refill systems as part of the solution to reduce packaging and packaging waste. We are already investing in these systems as a complementary action to our ongoing efforts to reduce and recycle our packaging.

It is fundamental that recycling and reusable systems are complementary solutions and MEPs and Member States should enshrine this in the PPWR. How?

Key ask 1 – Do not increase the reuse and refill targets (Art. 26) without further impact assessment

The European Commission’s impact assessment has been heavily criticised by many stakeholders, including our sector, over the last 9 months. The lack of a proper environmental and economic assessment of the implications of the reuse and refill targets proposed by the European Commission in the PPWR is worrying as legislation should always be developed on the basis of clear and granular data on the costs and benefits of the measures being proposed. So, first things first: the only way to assess the real impact of scaling up reusable systems across the EU is to thoroughly analyse the costs and benefits of setting up these systems in different Member States, different sectors and different distribution channels. As an example, the shift to 10% refillable PET as of 2030 in the EU is estimated to cost more than €16 billion, according to a PwC study.

It is very concerning to see proposals for increased reuse and refill targets for 2030 and 2040 that are not based on any further impact assessment that justifies them. Why forcing beverage manufacturers, of which a majority are SMEs, to make huge investments in reuse and refill systems in geographies or channels where existing well-functioning single-use systems make more sense from an environmental and economic perspective?

In our view, the proposed targets are already extremely challenging and therefore the focus now has to be on providing manufacturers with the necessary enablers and the flexibility to invest in the best packaging mix.

Key ask 2 – Maintain systems enabling refill in the reuse and refill targets (Art. 26)

We are all familiar with the traditional returnable refillable bottle, whereby the consumer buys a beverage bottle in a store and brings it back to the retailer for it to be refilled. This is not, however, the only system to reuse and refill – and it is not always the best solution from an environmental perspective. Asking beverage manufacturers to focus all their investment and innovation only in reuse on traditional returnable refillable bottles takes no account of consumer patterns of shopping and consuming beverages, and stifles the innovative solutions that open up possibilities to match consumers to more sustainable purchasing habits.

Today, there are several innovative reusable solutions that are convenient for consumers, are responding to new consumption habits and are helping reduce packaging as they use little to no packaging, such as home soda dispensers and refill stations in stores and horeca. Why, then, aren’t these at-home and on-the-go solutions, which are recognised by the Ellen MacArthur Foundation as reuse models, counting towards the achievement of the reuse and refill targets? It makes all sense to consider them for the attainment of the reuse and refill targets. The PPWR should secure a future for these innovative refill solutions and the EU co-legislators should therefore support a broad definition of reuse and refill that includes the whole spectrum of available reusable and refill models.

Key ask 3 – Create well-designed exemptions to ensure reusable packaging is only used where and when it makes the most sense

It is essential to make sure that reusable packaging is only introduced where it makes sense from an environmental, economic and consumer perspective. To enable it, the PPWR should provide a form of exemption if certain environmental criteria are met in order to avoid unintended adverse effects of the reuse and refill targets.

Some amendments tabled in the different European Parliament’s committees involved on this file can serve as a positive source of inspiration as they recognise the role of existing well-functioning circular systems. For example, many countries are investing in achieving 90% collection of PET bottles and aluminium cans through the introduction of Deposit and Return Systems (DRS). Let’s encourage these investments!

Now is the moment for the European Parliament and EU Member States to make the PPWR more supportive and more realistic. Our sector will remain constructive and engaged with all stakeholders to help create a stable and enabling policy environment.

The World Health Organization (WHO) and the UN Food and Agriculture Organization (FAO) have re-affirmed that aspartame is safe. UNESDA Soft Drinks Europe applauds the conclusions of the new, comprehensive safety review of aspartame by the WHO/ FAO Joint Expert Committee on Food Additives (JECFA), the world’s leading food safety body for additives.

Commenting on the release of the WHO/FAO JECFA review of aspartame, Nicholas Hodac, director general of UNESDA, stated:

“Once again, aspartame is assessed as safe by the world’s leading authority on food safety, based on a rigorous review of high-quality evidence. The WHO/FAO JECFA definitive conclusion is of great importance. It strengthens public confidence in the safety of aspartame and will help consumers make well-informed food and beverage choices.’’

Mr. Hodac added: ‘’This WHO/FAO conclusion is also key in further supporting our sector’s sugar reduction efforts. For decades, we have been reducing the average sugar content in our soft drinks, largely through the use of low- and no-calorie sweeteners, such as aspartame. To make further progress in encouraging consumers towards more balanced diets, the continued support of public health authorities on the use of aspartame and other sweeteners is essential.’’

Commenting on the opinion issued by the International Agency for Research on Cancer (IARC), Mr. Hodac said: “IARC is not a food safety body. It has classified aspartame, pickled vegetables and working at night as possibly carcinogenic. The fundamental aspect to consider is the potential risk on human health, which is what WHO/FAO JECFA has assessed with the conclusion that aspartame is safe.”

The WHO/FAO JECFA review of aspartame reiterates similar findings determining the safety of aspartame by over 90 food safety agencies around the world, including the European Food Safety Authority (EFSA) and the US Food and Drug Administration (FDA).

The European soft drinks sector achieved an impressive average 7.6 % sugar reduction between 2019 and 2022

The European soft drinks sector, represented by Unesda, announced further progress¹ on its commitments to the EU Code of Conduct on Responsible Food Business and Marketing Practices,² with strong results achieved in 2022 in its actions to create a healthier beverage system in Europe.

Ian Ellington, President of Unesda and Senior Vice-President and Chief Marketing Officer for PepsiCo in Europe, comments: ‘’As a sector, we remain committed to making significant progress on our many EU Code of Conduct commitments. We have achieved impressive results in our health and nutrition actions and, in particular, in our sugar reduction, marketing and advertising practices and school policies.’’

Ellington added: ‘’The journey has not been easy. Rising inflation in 2022 significantly impacted our ability to use more recycled content in our packaging due to the challenges we faced in accessing food-grade feedstock for recycling. We need policy support to deliver fully circular beverage packaging and to continue advancing on our sugar reduction programme.’’

Among Unesda’s achievements are its actions to encourage European consumers towards healthier dietary habits:

The sector delivered a 6% reduction in average added sugars in its soft drinks between 2019 and 2022 across Europe, as indicated by data analytics and consulting company GlobalData. This represents an additional reduction of 4 percentage points within 1 year (between 2021 and 2022). It shows that Unesda is on track towards meeting its commitment to reduce average added sugars in its beverages3 by another 10 % in the EU-27 and in the UK between 2019 and 2025.⁴ The success of the sector’s reformulation efforts to reduce sugar largely relies on the use of low- and no-calorie sweeteners to increase the offer of low- and no-calorie beverages. These ingredients should continue to be supported by public authorities and regulators to enable the sector to make further progress on sugar reduction.

Unesda corporate members achieved solid results regarding its marketing and advertising commitment, as demonstrated in the audits carried out by independent marketing and media consultancy Ebiquity (television) and the European Advertising Standards Alliance (websites, social media and influencers).⁵ The sector reached high compliance rates (98.7 % on TV, 92.9 % on company-owned websites, 94.1 % on company-owned social media profiles, and 100 % on influencer profiles), and is committed to continuing to work towards full compliance of its marketing and advertising commitment.

Unesda corporate members also reported to be highly compliant with the sector’s school policies⁶ in the four selected EU countries for its 2022 monitoring, conducted by third-party auditors BVA-BDRC:⁷

• 100 % (primary schools) and 92.3% (secondary schools) in Austria
• 100 % (primary schools) and 93.4% (secondary schools) in Italy
• 100 % (primary schools) and 100% (secondary schools) in Slovenia
• 100 % (primary schools) and 96.2% (secondary schools) in Sweden

Industry faces major challenges to accelerate packaging circularity

Unesda and its corporate members continued their actions to increase the amount of recycled plastic content in their beverage PET bottles to achieve the sector’s objective of using 50% recycled PET by 2025. The cost and availability of this material have been major challenges impacting these efforts. The most effective way to address this issue is to prioritise high-quality recycling in EU and national legislation by granting the sector a priority access right to the feedstock for recycling issued from its PET bottles. This will ensure that PET bottles are recycled into new beverage packaging in a closed-loop system, and are not being downcycled in non-food applications.

The way forward: Policy support is key

The European soft drinks sector remains determined to deliver on all its commitments but needs supportive policies in place to be successful.

In particular, the sector’s further actions to promote healthier lifestyles fully depend on support from EU public authorities and regulators for the use of ingredients assessed as safe by health authorities and on evidence-based dietary recommendations that do not denigrate or discriminate against any ingredient approved for use.

In order to accelerate the transition to full circularity of its packaging, Unesda calls for legislation supporting well-designed, industry-led Deposit Return Systems, the increased collection of beverage packaging across the EU and high-quality recycling through a priority access right to recycling feedstock to ensure a closed-loop system.

In addition, Unesda calls for a realistic regulatory framework on reuse that provides beverage producers flexibility to invest in the packaging mix that makes the most sense from environmental, economic, and consumer perspectives. This also includes considering all available reusable and refill options (at home and on the go) for the achievement of the reuse and refill targets proposed in the proposal for a Packaging and Packaging Waste Regulation.

Unesda will continue to engage with EU decision-makers in a constructive manner to help ensure policy predictability and coherence.

¹Read Unesda’s 2022 progress report on its commitments to the EU Code of Conduct here.
²The EU Code of Conduct on Responsible Food Business and Marketing Practices was launched by the European Commission in July 2021 and it is an integral part of the EU Farm to Fork Strategy to create a more sustainable food system in Europe. The EU Code of Conduct aims to encourage the entire food and drink sector to provide more sustainable and healthier food and beverage choices.
³Unesda’s sugar reduction commitment is applicable to all product categories under Unesda’s remit, including still drinks, carbonate drinks, energy drinks, sports drinks, dilutables and iced teas, but excludes bottled water, 100 % juices, milk based and hot beverages.
⁴This will represent a 33 % overall reduction in average added sugars in soft drinks since 2000, building on past sugar reduction milestones that the sector achieved from 2015 to 2019 (14.6 % reduction on average) and from 2000 to 2015 (13.3 % reduction on average).
⁵Unesda corporate members started implementing an effective Responsible Marketing Code of Conduct in 2006 with its commitment to no marketing communication in printed media, websites or during broadcast programmes specifically aimed at children under 12. Since then, they have reinforced this commitment by extending the scope of media channels in which they do not market and advertise their soft drinks to the under-12s: cinemas in 2008 and the digital world, including company-owned websites, in 2018 when they also tightened the audience criteria and committed not to market and advertise their beverages when 35 % of the audience or more was under 12 years of age. As of 1 January 2022, Unesda corporate members extended the age range by committing not to advertise and market any of their soft drinks to children under 13 years across all media. This includes TV, radio, in print, in cinemas and online, including social media and other online platforms and sites (company-owned websites and video-sharing platforms such as YouTube). It also includes direct marketing, product placement, interactive games, outdoor marketing, mobile marketing and contracted influencers. Unesda corporate members also committed to lowering the audience threshold from 35 % to 30 % so that fewer young children are directly exposed to advertising for any of its soft drinks.
⁶Unesda and its members are committed not to sell any soft drinks in EU primary schools since 2006 (through direct distribution), and to only sell low- and no-calorie soft drinks in EU secondary schools since 2017 (through direct distribution), and only in non-branded vending machines.
⁷The monitoring of Unesda’s school commitment is performed every two years in a group of different countries where there is a voluntary school commitment in place to provide a diversified sample of larger and smaller countries from different parts of the EU.

The non-alcoholic beverage industry, represented by the European Fruit Juice Association (AIJN), Natural Mineral Waters Europe (NMWE) and UNESDA Soft Drinks Europe, calls on the European Commission for “priority access” to its recycled plastic (PET) material, or a similar mechanism that guarantees “right of first refusal”, to be incorporated in the upcoming revision of the Packaging and Packaging Waste Directive.

As the beverage industry continues to invest in circularity and to put highly recyclable PET on the market, it needs to have priority access to its own recycled packaging material. This will help the beverage industry produce new packaging with food-grade recycled PET compliant with EU food safety standards, achieve its recycling targets and prevent its recycled PET being downcycled. Closing the bottle loop is required to ensure that the beverage industry meets the Single Use Plastics Directive (SUPD) targets and contributes to building a more circular economy for beverage packaging.

Wouter Lox, Secretary General of the European Fruit Juice Association (AIJN), commented: ‘’Food packaging serves specific needs, but most importantly is to safeguard the food products quality, conserves the food and assures food product safety. Also every food product has its specific packaging material properties and requirements in order to assure the packaging purpose. The access to the packaging material is essential to continue providing high quality and safe foods. This requirement needs to be merged with the sector commitments to respond to the EU Green Deal and the Circular Economy Action Plan. Therefore the access to the recycled material responding to the highest food quality standards needs to be reassured at every stage of the circularity circle.’’

Patricia Fosselard, Secretary General of Natural Mineral Waters Europe, stated: “Thanks to significant investments in collection schemes and in eco-design, PET bottles have become the most collected and recycled items around Europe. Through well-designed Deposit Return Schemes, several countries already achieve collection rates above 90%. Our members are determined to give every bottle a second life, but they can only do this if they get back the material that they place on the market so we can successfully close the loop.”

Nicholas Hodac, Director General of UNESDA, added: ‘’The entire beverage industry in Europe is fully supportive of the EU Green Deal and Circular Economy Action Plan and is committed to delivering full circularity for PET bottles. To get there, we need the European Commission to allow us to have priority access to our own recycled plastic material to meet our EU recycling obligations and avoid downcycling, which will break the bottle loop. It is just fair that we regain the equivalent quantity of collected and recycled material that we place on the market to move circularity forward.’’

The beverage industry is subject to several mandatory requirements under SUPD, one of which is that PET in bottles has to be food-grade to comply with EU food safety standards. In addition to introducing mandatory collection targets for PET bottles, SUPD also mandates the beverage industry to use a minimum of 25 % (by 2025) and 30 % (by 2030) of recycled content. The beverage industry’s commitment is not only to achieve these EU targets, but also to go much further by creating a closed loop for its PET bottles. Granting the beverage industry fair access to the amount of PET plastic material that it puts on the market and of which it finances the collection is key to promote effective bottle-to-bottle recycling.

Reaching 14.6 % reduction of added sugars in soft drinks between 2015-2019

Europe’s soft drinks industry has reduced added sugars in its drinks across Europe by an average of 14.6 % between 2015 and 2019.^[1]

UNESDA Soft Drinks Europe, representing soft drinks producers across the EU, is committed to creating healthier and more sustainable food environments. It is determined to support consumers in managing their intake of added sugars from soft drinks by ensuring that the healthier choice becomes the easy choice. The industry responded to the European Commission’s call for a 10 % reduction in added sugars by 2020 and recent research, by independent analysts GlobalData, confirms that it has met, and surpassed, the target ahead of time.

“This reduction is proof that the soft drinks industry’s voluntary efforts to reduce sugar across the EU are delivering tangible results,” said UNESDA president and president Western Europe at The Coca-Cola Company, Tim Brett. It demonstrates our sector’s accelerated action in response to changing consumer preferences and the expectations of public health stakeholders.”

The 14.6 % reduction in added sugars has been achieved through a comprehensive range of actions including changing recipes to reduce sugars while maintaining a taste with which consumers are happy; innovating to develop new products with different sweetness levels; increasing availability of small packs to support portion control and moderation; and nudging people toward more no- and low-sugar/calorie options through marketing investments. This latest sugar reduction comes on top of previous achievements and means that Europe’s soft drinks industry has now reduced added sugars by an average of 26 % since 2000.

UNESDA is a founding member of the EU Platform for Action on Diet, Physical Activity and Health and has undertaken a series of voluntary commitments over the past 15 years to help address unhealthy diets as a risk factor for non-communicable diseases. These have been complemented by numerous national pledges to support EU member states in their action plans to create healthier food environments. These pledges are the result of stakeholder engagement at a national level and set targets based on local baselines and expectations. They reflect the conclusions of the 2016 Dutch EU Presidency which highlighted that sugar reduction is a gradual process and needs to take account of different dietary habits and preferences across the EU.

“Our sector’s progress in reducing sugar and calorie reduction has been enabled by the openness of stakeholders to engage through the EU Platform,” concluded Tim Brett. “We believe that the EU Code of Conduct for responsible business and marketing practices announced in the EU Farm to Fork strategy offers an opportunity to continue this dialogue with all actors, including Member States. As an industry we are committed to maintaining our efforts through a range of voluntary actions to ensure that the healthier choice becomes the easy choice.”

The path towards sugar reduction through reformulation comes with multiple challenges from a technological and consumer acceptance perspective and these become greater the more the reductions continue.

While the soft drinks sector has reduced the average sugar content in its products, and the WHO’s research^[2] shows that frequency of consumption among school-aged children has declined across all age groups over the past 16 years, recent data shows that rates of overweight and obesity have not reduced. This demonstrates the complexity of the issue and the need for a holistic approach with all food and drink sectors committing to actions that support healthier food environments.

In addition to ongoing sugar and calorie reduction, Europe’s soft drinks sector has also made far-reaching commitments to behave responsibly in the marketplace including no advertising to children under 12; no sales of any soft drinks in EU primary schools and only no- and low- calorie drinks offered for sale in EU secondary schools.

About UNESDA
Established in 1958 UNESDA Soft Drinks Europe is a Brussels-based association representing the European soft drinks industry. Its membership includes both companies and national associations from across Europe producing drinks including still drinks, squashes, carbonates, powders, iced teas, iced coffees, syrups, energy drinks and sports drinks. It is signatory to the EU Transparency Register (No: 25498952296-56).

^[1] GlobalData research across 7 markets – Belgium, France, Germany, Spain, Sweden, Romania, UK
– representing 62 % of the EU market and extrapolated to create an aggregate figure.
^[2] https://www.euro.who.int/en/health-topics/Life-stages/child-and-adolescent-health/health-behaviour-in-school-aged-children-hbsc

A study released this week illustrates how the European soft drinks industry is rooted in the European economy and boosts progress throughout its value chain. The sector generates € 185 billion revenue – equivalent to 1.24 % of EU GDP, indirectly supports 1.7 million jobs and delivers almost € 30 billion in tax contributions to EU member states.

The industry supports a local value-chain of suppliers, distributors and retailers with a revenue that is 2.5 times greater than that which it receives itself. It contributes revenue, jobs and investment from the agricultural sector where it sources ingredients including fruit, berries and sugar beet; to the packaging and raw materials industries; through to the transport and distribution sectors and finally to the supermarkets, shops, bars and restaurants across the continent where its products are sold.

The study was undertaken by leading drinks industry analysts Global Data to mark UNESDA’s 60th anniversary and is based on 2016 data.

You can access the full report here: www.unesda.eu