Compliance Copilot Newsletter #2: Green Claims vs Single-Use Plastic

?? Recent green claims news

• 27 June:?Following widespread criticism of their carbon offsetting projects (see our?previous newsletter), Verra announces?changes to their Verified Carbon Standard (VCS) program, also inviting public consultation.
• ?? The why: Verra is addressing past project shortcomings by expanding project types and streamlining registration and validation processes.
• 28 June:?The Voluntary Carbon Market Integrity Initiative (VCMI) releases?Claims Code of Practice, giving “companies a rulebook to follow for making credible climate claims.”
• ?? The why: The rulebook shifts from carbon-offsetting to the 'contribution claims' model for private sector climate financing.
• 09 July:?Eight Swiss companies, including Swisscom and Coca-Cola Switzerland, are?facing complaints?lodged by the Swiss Consumer Protection Foundation (SKS) for their alleged involvement in illegal greenwashing activities.

?? Deep dive

McDonald’s “Better M” campaign: Should we appreciate their call for resource appreciation?

The gist:?McDonald’s Germany has launched a provocative campaign, “Better M,” turning its packaging into the stars of the show and calling for a greater appreciation of resources and the closing of material cycles.

The specifics:

• The campaign focuses not on the products, but on their empty packaging, turning drink cups, fries, boxes, etc., into sustainability ambassadors.
• The packaging explains why they are “beautiful” and more than “just trash” – they are valuable raw materials.
• McDonald’s has already issued 4.7 million Happy Meal? books made from recycled cup material.
• The campaign is supported by striking motifs in the OOH and digital sectors and in the restaurants themselves.

The critical reflection:?Among the responses to “Better M” are criticisms that this campaign is another McDonald’s initiative that promotes recycling (of single-use materials) over more sustainable solutions like reusable packaging (for inspiration, have a look at the?European Reuse Alliance) and will not deliver the desired positive impact for the environment.

The soundbite: “[McDonald’s] would have us believe that resources ending up in the trash are not wasted because they can be efficiently recycled. But true resource appreciation is different [...] Instead, one could join a real reusable system and scale it up with McDonald’s market position [...] In the end, perhaps a sensible and widespread reusable ecosystem would emerge, one that people can use and truly values and conserves resources.” -? Maximilian Mauracher , Co-Founder / Systemic Designer, New Standard Studio

?? Regulation explained

Shampoo vs chemical weapons: “Dual Use” EU Regulation 2021/821

"Dual-use" signifies items, including products, software, and technology, that have both peaceful and military applications. The "Dual-Use" regulation is an EU initiative to regulate the export and transit of these items, preventing the spread of weapons, notably those of mass destruction.

The practice is rooted in the EU Regulation 2021/821, which provides a list of dual-use items, organised by potential use in its annexes, and these are subject to EU control.

To make this more tangible, let's consider you're a manufacturer of personal care products. Here's how the key points of the regulation would apply to you:

1. License requirement:?Suppose your skincare product contains a chemical that can also be used in chemical weapons. Before you export it outside the EU, you'll need to secure a license.
2. Catch-all provision:?If this chemical is not directly listed in the Regulation but can be used in creating weapons of mass destruction, the catch-all provision applies, and the item is controlled.
3. Intangible technology transfers:?If your product manufacturing process includes a unique technology or software that you intend to share through electronic means with a company outside the EU, that too falls under the regulation.
4. Technical aid:?Suppose you plan to offer technical assistance to another company related to your dual-use item (the skincare product), particularly if the product can be used in relation to weapons of mass destruction, you might need to get authorisation first.
5. Enforcement and penalties:?As a member state, your country enforces these regulations and sets penalties for violations, which are designed to be effective and proportionate. In Germany, for example, this is primarily the responsibility of the Federal Office for Economic Affairs and Export Control (BAFA).

Also, the EU Dual-Use regulation aims not to prohibit but to regulate the export of dual-use items to prevent misuse.

That is all we have for now. Thank you for reading????Share this issue with others and subscribe for more insights about product compliance and sustainability.

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