Interesų grupė
IPV position on the proposal by the European Commission for a EU Packaging and Packaging Waste Regulation The Industry Association for Paper and Film Packaging (IPV) welcomes the overarch- ing goals of the proposed regulation to contribute to a climate-neutral recycling econ- omy with a regulation on packaging and packaging waste (PPWR). Requirements for the recyclability of packaging and an increase in the use of recycled materials in packaging can make a positive contribution to the further development of the circular economy. However, the proposal also contains problematic aspects: Central decisions are shifted to the level of delegated acts and implementing acts and thus assigned to the EU Com- mission. This does not do justice to the necessary involvement of the European Parlia- ment and all affected stakeholders.
This does not do justice to the necessary involvement of the European Parlia- ment and all affected stakeholders. In addition, there is no scientific proof of the resulting ecological advantages for some measures with a high intensity of intervention in the decision-making freedom of com- panies - such as reusable quotas and packaging bans. The proposed regulation also establishes a series of new and complex documentation and certification obligations for manufacturers and distributors of packaging, which would result in significant and burdensome bureaucratic costs for companies. For this reason, the IPV draws attention to those points that make a revision of the draft regulation imperative in order not to undermine the objectives of the PPWR. Establishment of a standard Europe wide approach to dealing with packaging waste (Art.
…the objectives of the PPWR. Establishment of a standard Europe wide approach to dealing with packaging waste (Art. 4) The harmonisation to be achieved by moving from a directive to a regulation must not be thwarted by allowing Member States to go beyond the requirements of the PPWR. The aim must be to maintain a harmonised, well-functioning internal market in all Mem- ber States that ensures a level playing field for packaging manufacturers. Packaging producers are currently already confronted with different national measures (e.g., labelling), which run counter to a harmonised internal market and ultimately in- crease packaging waste. Art 4(4) of the PPWR, which allows Member States to go be- yond the requirements of the Regulation, is diametrically opposed to the idea of harmo- nisation and should therefore be deleted.
…of the Regulation, is diametrically opposed to the idea of harmo- nisation and should therefore be deleted. To strengthen the circular economy the separate collection of all packaging waste from end users should be described more specifically with a defined timeframe in Article 43. Use of recyclate (Art. 7) Paper and cardboard packaging that partially contains plastic would currently be sub- ject to the requirements of Art. 7 on the mandatory use of recyclate. For technical rea- sons or to meet hygiene requirements, fibre-based packaging may contain components made of plastics. To our knowledge, the use of recycled plastic in barriers has neither been researched nor tested.
…of plastics. To our knowledge, the use of recycled plastic in barriers has neither been researched nor tested. As the use of recyclate in food contact is already becom- ing extremely challenging for plastic packaging in the timeframe envisaged, a solution for the even more technically complex challenges of barriers for paper and cardboard Ref. Ares(2023)2871998 - 24/04/2023 2 packaging is not feasible. The IPV therefore calls for an exception from Art. 7 for pack- aging consisting of other materials than plastic as the predominant material and for contact sensitive packaging of all materials. Packaging minimisation (Art. 9 / Art. 21) The IPV welcomes the regulations to reduce packaging sizes to their necessary mini- mum (Art. 9) and to prevent over-packaging (Art. 21).
…regulations to reduce packaging sizes to their necessary mini- mum (Art. 9) and to prevent over-packaging (Art. 21). Flexible packaging can be manufactured to fit precisely and adapted to the products to be protected, so that it contributes to packaging minimisation. However, the proposed obligation for manufacturers to provide proof of compliance for each individual package is extremely problematic. The effort to prove and document more legally that packaging cannot be smaller or lighter than it actually is seems dis- proportionate, especially for small and medium-sized enterprises. Furthermore, in the area of food packaging, the requirements for packaging minimisa- tion must be coherent with other political regulations, especially within the framework of EU law on food contact materials. Market restrictions (Art.
…political regulations, especially within the framework of EU law on food contact materials. Market restrictions (Art. 22) All packaging has the function of protecting products from damage, spoilage and con- tamination during transport and storage. The loss or damage of the packaged product results in a higher environmental impact than the savings achieved by reducing the packaging in terms of resource consumption and emissions generated. In the case of food packaging, this leads to additional food loss and waste. Ensuring food protection and food safety are essential functions of food packaging. This is ensured through the use of recyclable packaging. Reusable packaging, for ex- ample for fruit and vegetables, on the other hand, can spread contamination and thus lead to increased food waste and consumer health risks.
…on the other hand, can spread contamination and thus lead to increased food waste and consumer health risks. In addition, the cleaning of re- usable packaging leads to increased environmental pollution. Market restrictions and traffic bans for reusable or recyclable packaging, as demanded in Article 22 of the draft regulation, are detrimental to consumer and climate policy and should be avoided at all costs. Therefore, the IPV calls for the deletion of Art. 22 for all reusable or recyclable packaging. Reusable quotas for transport, repackaging and shipping packaging (Art. 26) The IPV expressly welcomes the fact that B2B transport packaging (Art. 26 para. 12/13) and outer packaging (Art. 26 para. 10) made of paper, cardboard and paperboard are ex- cluded from the scope of application of the envisaged reusable quotas.
…made of paper, cardboard and paperboard are ex- cluded from the scope of application of the envisaged reusable quotas. Packaging should be defined independently of arbitrarily chosen product groups. For this reason, transport packaging of large household appliances (Article 26(1)) and online ship- ping packaging (Article 26(8)) should also be excluded from the scope of application of the reusable quotas. The subjection of this packaging to the scope of application of the reusa- ble quotas is purely arbitrary and without objective justification. Transport packaging for large household appliances and online shipping packaging are already being recycled - like other transport packaging - without any problems and on a large scale. The establishment of costly reusable return systems would require additional logistics and cleaning capacities.
…scale. The establishment of costly reusable return systems would require additional logistics and cleaning capacities. If a complete abolition of reusable quotas in this area is 3 not possible, fibre-based transport packaging and online shipping packaging should be exempted from this (Art. 26, Para.8). The general assumption in the draft of the PPWR that reusable packaging has an ad- vantage cannot be scientifically proven. Reusable packaging is associated with high addi- tional logistical costs. Return journeys cause additional CO2 emissions and already tie up scarce logistics capacities. The ecological effects of the time-consuming cleaning of reus- able packaging and the additional need for storage capacities must also be considered.
…time-consuming cleaning of reus- able packaging and the additional need for storage capacities must also be considered. Furthermore, it must be taken into account that the possibility of producing packaging pre- cisely contributes to packaging minimisation according to Art. 9. In contrast, standardised unit sizes in the reusable system inevitably lead to more empty volume and higher mate- rial input. The IPV therefore pleads for a non-discriminatory regulation oriented towards the ecologi- cal reality according to broadly accepted LCA methodologies of packaging, which recog- nises the advantages of recyclable packaging and does not lead to a one-sided prefer- ence for reusable systems. Reuse and recycling must be recognised as complementary packaging solutions! Additional remarks Technical documents need to be evidence-based, robust and reflect state of the art.
…solutions! Additional remarks Technical documents need to be evidence-based, robust and reflect state of the art. The proposed procedure in the draft to adopt delegated acts does not foresee stakeholders’ involvement which would be very regrettable as in-depth technical knowledge is needed to ensure the documents duly reflect today’s state of the art. Therefore, we propose that CEN, the EU recognised standardisation body, is given the mandate to develop the new standards, being the deputed body at EU level for all technical documents that are cur- rently planned as delegated acts. All materials may have advantages in different applications. The IPV therefore calls for the avoidance of false claims within the whole document (e.g. Recital 6 “…Plastic packaging is the most carbon-intensive material…”) and to recognise the resource efficiency of all materials when used in their best way.
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