INSIGHT by the Dutch Association of Investors for Sustainable Development (VBDO)

The whole plastics lifecycle poses a serious and growing threat to the environment, climate, biodiversity, human rights and public health. Accumulating research continues to emphasise the gravity of these impacts but the picture is already clear: intensive production and use of plastics is causing untold damage to the health of people and planet, with scientists affirming that “clean-up is futile” if production continues at current rates.1

We, investors and their representatives, believe that companies must set their sights higher and act more swiftly to address the plastics crisis through reducing their dependence on single-use plastic packaging, working to bring production and consumption of plastics within the limits of the planetary boundaries and alignment with the Paris Agreement and the Kunming-Montreal Global Biodiversity Framework. This statement is directed at companies in the fast-moving consumer goods and grocery retail sectors, including (non-exhaustively) those listed in the Appendix to this statement.

 

| Financial risks to companies and investors

Plastics imposes an estimated externality cost on society of $US 350 billion per year arising from greenhouse gas emissions, ocean pollution and collection costs – at least US$ 1000 per tonne of plastic produced.2 As action from policymakers steps up to address the plastics crisis and society demands accountability from corporate actors perpetuating the problem, companies on the value chain are exposed to significant and mounting plastic-related risks.

These risks include regulatory risks arising from bans, taxation and extended producer responsibility costs, reputational risks, increased momentum in plastic-related litigation3 and increased raw material costs4. As responsible investors, we are concerned that companies that do not proactively address these risks with actions aimed at reducing their dependence on single-use plastics may face higher costs or lose business opportunity, therefore putting long-term value creation and investment returns at risk.

 

| Our expectations for accelerated corporate action on plastics

Actions taken by companies to date have failed to have impact on the scale and at the rate required. As noted in the Ellen MacArthur Foundation’s 2022 Progress Report, signatories to the Global Commitment are not on track to meet their 2025 target that all packaging be reusable, recyclable and compostable.5 Efforts on reduction, implementing reuse6 and addressing toxicity remain very limited7.

We expect companies to make a real and scalable change by setting more ambitious targets and taking stronger actions. Companies must set a clear vision to drastically reduce consumption of single-use plastic packaging in absolute terms, phase out hazardous chemicals and, crucially, advocate for – not against – the policy framework needed to support these actions. To this end, we expect companies that intensively use plastic packaging (notably the FMCG and grocery retail sector) to:

 

1. Support ambitious plastics policy for effective outcomes

>> Global Plastics Treaty

The plastics crisis is a problem without borders not least because many companies are producing and placing on the market plastic products and packaging in many different markets. Efforts to negotiate a new Global Plastics Treaty will be decisive for turning the dial on the plastics crisis while also reducing operational complexity and compliance risk across markets.

We expect companies to support international efforts for an ambitious plastics treaty by joining the Business Coalition for a Plastics Treaty and advocate for legally binding measures designed to reduce production and consumption and boost reuse.

 

>> EU Packaging and Packaging Waste Regulation proposal

The European Commission’s proposal for the revision of the Packaging and Packaging Waste Regulation (PPWR) contains much-needed focus on prevention and reuse, and could go a long way in reducing packaging consumption, notably by addressing overpackaging and scaling up reuse systems.8 It is therefore concerning that a recent analysis of European consumer product sector engagement on the PPWR revision identified that the sector’s “industry associations are engaged overwhelmingly negatively with the PPWR”, noting that lobbying efforts had already succeeded in lowering the targets and weakening the measures considered by the European Commission.9

We expect companies to publicly support the ambition of the PPWR reform, to refrain from lobbying to reduce this ambition and to ensure that industry associations to which they are a member act in accordance with this position.

 

2. Commit to – and start delivering – absolute reduction of single-use plastic packaging, including through implementing reuse systems

It is clear that drastically reducing production and consumption of plastics is the priority action needed to address the plastics crisis. This includes upscaling of reuse systems. Well-designed reuse systems provide significant environmental benefits – a reduction in resource use, energy, toxic substances, water use, contributing to reducing carbon emissions and preventing pollution.10

We expect companies to establish a clear plan of action to reduce material consumption in absolute terms, prioritising eliminating the need for single-use packaging altogether, including through upscaling reusable packaging systems, to be achieved by clearly defined timescales and subjected to external verification.

 

3. Address toxicity in value chains

Over 3,000 potentially harmful chemicals have been identified in food packaging, both intentionally and unintentionally added chemicals.11 Failure to address use of these chemicals is contributing to a chemical pollution crisis, with hazardous chemicals ubiquitous in humans, the environment and accumulating in materials and products,12 posing a significant threat to human health13. Increased use of recycled plastics raises serious concerns about the lack of knowledge, traceability and transparency of chemicals in packaging, with research flagging toxicity risk of recycled plastic.14

We expect companies to commit to identifying and eliminating the use of hazardous substances15 in products and packaging and to publicly report their progress in doing so.

 

We invite other institutional investors to contact us to support this statement and collaborate on efforts to engage with companies including those listed in the Appendix to this statement, as well as to work with stakeholders to encourage the adoption of ambitious targets needed to accelerate progress.

 

 

Please find the full statement, signatory list, and appendix here.

 

  1. Eriksen et al, “A growing plastic smog, now estimated to be over 170 trillion plastic particles afloat in the world’s oceans – Urgent solutions required”, PLOS ONE 18(3): e0281596 (2023). , “More than 170tn plastic particles afloat in the oceans, say scientists”, 8 March 2022.
  2. Carbon Tracker, “The future’s not in plastics: Why plastics demand won’t rescue the oil sector”, 2020.
  3. ClientEarth, “Plastics on trial: a briefing series on evolving liability risks related to plastics, vol. II Hazardous chemicals”, 2022.
  4. Planet Tracker, “Packaging labels: Don’t lose your bottle over the label”, 2023.
  5. Ellen MacArthur Foundation, “The Global Commitment 2022: Progress Report”, 2022.
  6. Ibid.
  7. VBDO, “Plastic Perspectives: An overview of the plastic footprints, ambitions and plastic lobbying activities of listed European and UK grocery retailers and FMCGs”, 2022.
  8. Proposal for a revision of EU legislation on Packaging and Packaging Waste, 30 November 2022. Available online: https://environment.ec.europa.eu/publications/proposal-packaging-and-packaging-waste_en.
  9. InfluenceMap, “The consumer products sector and the EU’s circular economy policy for packaging and packaging waste”, 2023.
  10. Rethink Plastic and Break Free From Plastic, “Realising reuse: the potential for scaling up reusable packaging, and policy recommendations”, 2021.
  11. B Geuke et al, “Systematic evidence on migrating and extractable food contact chemicals: Most chemicals detected in food contact materials are not listed for use”, Critical Reviews in Food Science and Nutrition, 2022, DOI: 10.1080/10408398.2022.2067828
  12. UNEP, “Global Chemicals Outlook II: From legacies to innovative solutions”, 2019.
  13. UNEP, “Drowning in plastics: Marine litter and plastic waste, vital graphics”, 2021.
  14. Gerassimidou et al, “Unpacking the complexity of the PET drink bottles value chain: A chemicals perspective”, Journal of Hazardous Materials, Vol. 430 (2022) 128410.
  15. These should include substances listed in the Understanding Packaging Scorecard list of Food Chemicals of Concern, developed on the basis of research and information from leading NGOs and industry associations, periodically updated to reflect the best science available. The chemicals of concern in the UP Scorecard list are divided into three tiers, with Tier 1 representing a shortlist of priority chemicals of concern to avoid, based on broad stakeholder agreement, and Tiers 2 and 3 presenting more extensive sets of chemicals that should not be used in the manufacture of food contact materials.

| All opinions expressed are those of the author and/or quoted sources. investESG.eu is an independent and neutral platform dedicated to generating debate around ESG investing topics.

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