Federation of The European Cookware, Cutlery and Housewares Industries

FEC c/o Unitam  39/41, rue Louis Blanc – FR-92400 Courbevoie   CS 30080 – F-92038 Paris La Défense cedex E. [email protected]  https://fecassociation.eu/  FEC LinkedIn 24/04/2023 FEC input on the PPWR proposal To ensure the protection of cookware, cutlery, and other products used for preparing and serving of food, packaging is necessary. From storage in the warehouses to shipment and delivery at consumers’ houses, it guarantees the good conditions of the articles and preserves the required level of safety in their use. Packaging is also a vector of information to the consumer on the product (characteristics, place of fabrication, references, recycling conditions, etc.).

…to the consumer on the product (characteristics, place of fabrication, references, recycling conditions, etc.). The Federation of European Manufacturers of Cookware and Cutlery (FEC) and its members fully support the objective of the Packaging and Packaging Waste Regulation (PPWR) proposal to contribute to the efficient functioning of the internal market for packaged goods, while preventing or reducing the adverse impacts of packaging waste on the environment and human health. Key Comments A) Implementation of a harmonized labeling FEC welcomes the proposal for a transition from a Directive to a Regulation for Packaging and Packaging Waste, which will ensure the implementation of harmonized obligations across the EU Member States and secure the functioning of the Single Market.

…of harmonized obligations across the EU Member States and secure the functioning of the Single Market. However, FEC is concerned about the provisions in the text that permit Member States to set particular requirements at the national level. The current situation for manufacturers of consumer goods present across different European markets, encounters a wide variety of divergent requirements for the packaging of their goods. The European Commission proposal, still presents some flexibility for Member States to keep their national packaging rules, specifically those about packaging marking and labeling obligations. FEC calls for the preservation of a full internal market legal basis which could stop the plethora of divergent requirements which would breach the Single Market not ensuring the free movement of goods and their packaging.

…requirements which would breach the Single Market not ensuring the free movement of goods and their packaging. We believe that uniform Regulation, with harmonized requirements, is the key to developing a true EU circular economy. In addition, the co-existence of divergent packaging marking and labeling obligations implies that manufacturers of FEC either have to manage specific packaging for national markets (meaning more inventories and supply chain complexities), either have to integrate all the obligations on a single packaging (which may lead to bigger packaging). In both cases, such a situation may serve badly the objective of lowering CO2 emissions induced by packaging, Ref. Ares(2023)2887914 - 24/04/2023 FEC c/o Unitam  39/41, rue Louis Blanc – FR-92400 Courbevoie   CS 30080 – F-92038 Paris La Défense cedex E.

…c/o Unitam  39/41, rue Louis Blanc – FR-92400 Courbevoie   CS 30080 – F-92038 Paris La Défense cedex E. [email protected]  https://fecassociation.eu/  FEC LinkedIn because of higher amount of packaging produced to meet regulatory requirements, and poses bigger challenges for SMEs players, which have more limited resources. The proposal for a regulation considers the introduction of a QR code system or digital data carrier to provide information on packaging reusability. From FEC, we consider this system a good opportunity to create a digital platform able to maintain and update labeling requirements altogether with recycling information without the need for new packaging or labels.

…and update labeling requirements altogether with recycling information without the need for new packaging or labels. The implementation of such system will help improve the readability of labels and facilitate their management by economic operators while ensuring the functioning of the internal market B) Availability and competitiveness in Europe. The targets set by the PPWR while ambitious should take into account market availability and competitiveness within the European market, pushing for the development of whole recycling schemes (sorting, recycling, converting), with the beneficial impact this would have in the growth of technology and second raw material market in Europe. To preserve the competitiveness of European manufacturers of products in export markets, it is instrumental that the European packaging industry remains competitive compared to international benchmarks.

…it is instrumental that the European packaging industry remains competitive compared to international benchmarks. To fully reach the ambitious targets of the proposal for Regulation, it should be taken into consideration not only post-consumer waste, but also post- industrial waste, which poses an important source of material. The so-called post-industrial waste cannot be just re-fed into the converting lines, and its decontaminated properties make it especially relevant for contact- sensitive applications. Ignoring this material could lead to big amounts of material suitable for recycled products being discarded from the circular economy. C) Design for Recycling Criteria Compliance To reduce waste and achieve recyclability the proposal introduces the design for recycling criteria, which will allow the achievement of recycling targets by 2030.

…proposal introduces the design for recycling criteria, which will allow the achievement of recycling targets by 2030. These new criteria will ensure all packaging is recyclable. Increasing recyclability will contribute to a high-quality secondary raw material market for products. Manufacturers of products are required to ensure conformity with the legislative requirements. The proposal for a Regulation proposes compliance that shall be demonstrated by technical information and declaration of conformity. While this alternative is well received by FEC, we are concerned about ensuring compliance for packaging from another economic operator with the PPWR requirements, and the administrative and economic cost it would have on manufacturers of packaged goods, in particular SMEs. We call for clarity on the responsibility for compliance with the packaging materials.

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