AMETIC · Trade and business associations · ES
AMETIC’S COMMENTS ON PPWR FINAL VERSION APRIL 2023 1/13 AMETIC’S COMMENTS ON THE PROPOSAL FOR A REGULATION ON PACKAGING AND PACKAGING WASTE AMETIC is the association of the digital technology industry sector in Spain, which constitutes a real lever for sustainable economic development, helping to increase the competitiveness of other sectors. Our associates are companies of all sizes, including large global companies in Information Technology, Telecommunications, Electronics, Services and Digital Content, leading companies in digital transformation, as well as industry associations. AMETIC welcomes the harmonization efforts in the Proposal Regulation for packaging and packaging waste and a more circular economy. However, some measures in the PPWR proposal raise concerns regarding their technical feasibility and practicality, and lacks impact assessment to justify the proportionality of…
…taken into account by policymakers. Commission’s proposal Suggested amendment Article 6 - Recyclable packaging 1. All packaging shall be recyclable. 2. Packaging shall be considered recyclable where it complies with the following: (a) it is designed for recycling; (b) it is effectively and efficiently separately collected in accordance with Article 43(1) and (2); (c) it is sorted into defined waste streams without affecting the recyclability of other waste streams; (d) it can be recycled so that the resulting secondary raw materials are of sufficient quality to substitute the primary raw materials; (e) it can be recycled at scale. Point (a) shall apply from 1 January 2030 and point (e) shall apply from 1 January 2035. Article 6 - Recyclable packaging
(a) shall apply from 1 January 2030 and point (e) shall apply from 1 January 2035. Article 6 - Recyclable packaging 1. All packaging shall be recyclable. 2. Packaging shall be considered recyclable where it complies with the following: (a) it is designed for recycling; (b) it is effectively and efficiently separately collected in accordance with Article 43(1) and (2); (c) it is sorted into defined waste streams without affecting the recyclability of other waste streams; (d) it can be recycled so that the resulting secondary raw materials are of sufficient quality to substitute the primary raw materials; (e) it can be recycled at scale. Point (a) shall apply from 1 January 2030 and point (e) shall apply from 1 January 2035. Justification: It is necessary to clarify that the recyclability requirements will need to be met in a two-stepped approach, i.e. (a) from 1 January 2030 and (b) from…
…20 of the Regulation Ref. Ares(2023)2891237 - 24/04/2023 AMETIC’S COMMENTS ON PPWR FINAL VERSION APRIL 2023 2/13 3. Recyclable packaging shall, from 1 January 2030, comply with the design for recycling criteria as laid down in the delegated acts adopted pursuant to paragraph 4 and, from 1 January 2035, also with the recyclability at scale requirements laid down in the delegated acts adopted pursuant to paragraph 6. Where such packaging complies with those delegated acts, it shall be considered to comply with paragraph 2, points (a) and (e). 3.
…packaging complies with those delegated acts, it shall be considered to comply with paragraph 2, points (a) and (e). 3. Recyclable packaging shall, placed on the EU market from 1 January 2030 or 36 months after the publication of the delegated acts pursuant to paragraph 4, whichever is the latest, shall comply with the design for recycling criteria as laid down in the delegated acts adopted pursuant to paragraph 4 and, recyclable packaging placed on the EU market from 1 January 2035 or 36 months after the publication of the delegated acts pursuant to paragraph 6, whichever is the latest, shall also comply with the recyclability at scale requirements laid down in the delegated acts adopted pursuant to paragraph 6. Where such packaging complies with those delegated acts, it shall be considered to comply with paragraph 2, points (a) and (e).
…packaging complies with those delegated acts, it shall be considered to comply with paragraph 2, points (a) and (e). Justification: It is The Regulation must explicitly clarify that the aforementioned effective dates refer to date of placing on the EU market, i.e. any packaging placed on the EU market from these dates onwards must meet the respective recyclability requirements and any packaging placed on the EU market before these dates can be commercialized and used until depletion of stocks. Furthermore, a sufficient transition period of at least 36 months following the publication of the aforementioned Delegated Acts is needed to allow for stocks of packaging not complying with the new requirements to be placed on the market, which otherwise will have to be disposed of as waste. Article 6 – recyclable packaging
…to be placed on the market, which otherwise will have to be disposed of as waste. Article 6 – recyclable packaging 3. Recyclable packaging shall, from 1 January 2030, comply with the design for recycling criteria as laid down in the delegated acts adopted pursuant to paragraph 4 and, from 1 January 2035, also with the recyclability at scale requirements laid down in the delegated acts adopted pursuant to paragraph 6. Where such packaging complies with those delegated acts, it shall be considered to comply with paragraph 2, points (a) and (e). 4.The Commission is empowered to adopt delegated acts in accordance with Article 58 to supplement this Regulation in order to establish design for recycling criteria and recycling performance grades based on the criteria and parameters listed in Table 2 of Annex II for packaging categories listed in Table 1 of that Annex, as well as rules…
…to be paid by producers to comply with their extended producer responsibility Article 6 – recyclable packaging 3. Recyclable packaging shall, from 5 years after entry into force of the standards referred to in paragraph 4 1 January 2030, comply with the design for recycling criteria as laid down in the delegated acts adopted pursuant to paragraph 4 and, from 1 January 2035, also with the recyclability at scale requirements laid down in the delegated acts adopted pursuant to paragraph 6. Where such packaging complies with those delegated acts, it shall be considered to comply with paragraph 2, points (a) and (b).
…complies with those delegated acts, it shall be considered to comply with paragraph 2, points (a) and (b). 4.By 1 January 2025, the Commission shall request the European standardisation organisations to develop, at the latest by 31 December 2026, harmonised standards The Commission is empowered to adopt delegated acts in accordance with Article 58 to supplement this Regulation in order to establish design for recycling criteria and recycling performance grades based on the criteria and parameters listed in Table 2 of Annex II for packaging categories listed in Table AMETIC’S COMMENTS ON PPWR FINAL VERSION APRIL 2023 3/13 obligations set out in Article 40(1), based on the packaging recycling performance grade, and for plastic packaging, the percentage of recycled content.
…based on the packaging recycling performance grade, and for plastic packaging, the percentage of recycled content. Design- for-recycling criteria shall consider state of the art collection, sorting and recycling processes and shall cover all packaging components. The Commission is empowered to adopt delegated acts in accordance with Article 58 to amend Table 1 of Annex in order to adapt it to scientific and technical development in material and product design, collection, sorting and recycling infrastructure. 1 of that Annex. From the date of publication of the references to harmonised standards in the Official Journal of the European Union, packaging which is in conformity with those standards shall be presumed to be in conformity with the requirement laid down in paragraph 1.
…in conformity with those standards shall be presumed to be in conformity with the requirement laid down in paragraph 1. The Commission is empowered to adopt delegated acts in accordance with Article 58 to supplement this Regulation in order to establish , as well as rules concerning the modulation of financial contributions to be paid by producers to comply with their extended producer responsibility obligations set out in Article 40(1), based on the packaging recycling performance grade, and for plastic packaging, the percentage of recycled content. Design-for- recycling criteria shall consider state of the art collection, sorting and recycling processes and shall cover all packaging components.
…shall consider state of the art collection, sorting and recycling processes and shall cover all packaging components. The Commission is empowered to adopt delegated acts in accordance with Article 58 to amend Table 1 of Annex in order to adapt it to scientific and technical development in material and product design, collection, sorting and recycling infrastructure. Should the adoption of the standards referred to in in this paragraph be delayed, a presumption of compliance with the requirements set out in paragraph 2 of this Article shall apply to all packaging placed on the market in the Union until such standards are adopted. Justification: The proposal contemplates the adoption of numerous delegated acts for the assessment of packaging recyclability without providing a clear timeframe for their adoption.
63 → 12