Graphic Packaging Holding Co

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Graphic Packaging Holding Co provides extensive, specific disclosure on every aspect of its climate-related lobbying. It names multiple identifiable policy files it has engaged on, including Extended Producer Responsibility (EPR) frameworks in Europe and North America, the EU Packaging and Packaging Waste Regulation flowing from the European Green Deal and Circular Economy Action Plan, and the UK’s new EPR scheme scheduled for 2024. The company explains exactly how it interacts with policymakers––for example, submitting position papers, holding “discussions with MEPs” on the EU regulation, meeting UK officials on the EPR scheme, working “via its associations regarding different policy files,” and supporting candidates through the GPI-PAC––clearly identifying both the mechanisms and the targets of these efforts. It is equally explicit about what it wants to achieve: it “opposes EPR for paper and paperboard packaging that does not factor in the recovery rates of the materials,” calls for “fee structures scaled based on actual material recovery,” seeks “harmonization in terms of collection, sorting and recycling of packaging across Europe,” and questions stringent reuse obligations, favouring “proportionate requirements for fiber-based packaging.” By detailing the policies, the channels used to influence them, the policymakers addressed, and the concrete outcomes it is advocating, the company demonstrates a comprehensive level of transparency on its climate-policy lobbying. 4
Lobbying Governance
Overall Assessment Comment Score
Strong Graphic Packaging Holding Co. establishes a clear governance framework for climate-related engagement by assigning oversight to its Vice President of Government Affairs and embedding climate policy into its strategic planning processes. As the company explains, "Graphic Packaging’s VP of Government Affairs provides strategic direction and ensures that the direct and indirect activities regarding climate change policies are consistent with the strategy," and this strategy "is reviewed formally each year and on an ad hoc basis." Senior leadership engagement is evident in that "Graphic Packaging’s President and CEO and other members of the Executive Team participate in policy discussions at Federal and State levels," while environmental and climate change considerations are incorporated into the long-range plan, which "is presented to the Board of Directors for its consideration and approval." However, the company does not disclose a public commitment to align its engagement with the goals of the Paris Agreement, noting only that it plans to have one in the next two years, and it provides no details on monitoring or managing the climate positions of trade associations or external partners, highlighting areas where its governance could be strengthened. 3