European Cultural and Creative Industries Alliance (ECCIA)

April 2023 European Cultural and Creative Industries Alliance (ECCIA) Position paper on the Packaging and Packaging Waste Regulation The European Cultural and Creative Industries Alliance (ECCIA) is composed of seven European cultural and creative industries organisations - Altagamma (Italy), Circulo Fortuny (Spain), Comité Colbert (France), Gustaf III Kommitté (Sweden), Laurel (Portugal), Meisterkreis (Germany), and Walpole (UK) - who between them represent over 600 brands and cultural institutions. Based on art, culture and creativity, our work is underpinned by continuous innovation, a relentless focus on quality, highly skilled employment, and strong exports abroad. Our members strive for the highest quality in all they do, from products and services all the way to the experience offered to consumers. Ref.

…the highest quality in all they do, from products and services all the way to the experience offered to consumers. Ref. Ares(2023)2827986 - 21/04/2023 2 Introduction The European Cultural and Creative Industries Alliance (ECCIA) supports the European Commission’s Green Deal and its global ambition towards a more sustainable and circular economy. We recognize that minimizing the environmental impact of packaging and packaging waste is one of the key alleys for the achievement of the Green Deal, and therefore wish to contribute to the impactful, meaningful, and enforceable revision of the Packaging and Packaging Waste Regulation (PPWR). High-end and luxury industries are renowned for their products' excellence and exceptional creativity.

(PPWR). High-end and luxury industries are renowned for their products' excellence and exceptional creativity. Their design and product presentations are celebrated throughout the world, and they are a key asset to the EU’s cultural influence and competitiveness in the global economy. Our commitment to creating high-quality products that last over time and value the finest materials through unique designs is precisely what makes the luxury industry a key component of the European cultural and creative heritage. High-end and luxury goods are designed to be sustainable by nature – embracing both quality and durability. Produced in limited quantities, they can be repaired and restored, thus enhancing their ability to be reused, given a second life, or passed from one generation to another. This creative approach, which values timeless products, is at the very core of our business strategy.

…to another. This creative approach, which values timeless products, is at the very core of our business strategy. Packaging is an extension of high-end and luxury goods and a major component of our customers’ buying decisions. It is therefore essential for ECCIA members to retain the creative freedom to offer their customers packaging that reflects the high quality, innovation, and creative know-how that they embody. We firmly believe that our ability to combine our products’ aesthetics and sustainability should not be mutually exclusive and that the PPWR should strike the right balance between both. The following sections look at some of the PPWR’s key provisions, their potential impact on our sector and ECCIA’s recommendations. Our suggestions High-end cultural and creative industries are proud to have integrated sustainability commitments at the core of their products.

…cultural and creative industries are proud to have integrated sustainability commitments at the core of their products. As this Regulation will undoubtedly have a strong impact on global supply chains, ECCIA encourages the EU policymakers to, in particular: ● Ensure the highest level of harmonisation: The EU should set clear, binding objectives that can be applied and interpreted uniformly throughout the Single Market, therefore avoiding diverging environmental requirements at the EU level. ● Establish a level-playing field with third countries: Efficient controls are needed to prevent a distortion of competition that would be detrimental to EU businesses and “Made in Europe” products.

…needed to prevent a distortion of competition that would be detrimental to EU businesses and “Made in Europe” products. ● Preserve our industry’s competitiveness & creative freedom: The implementation of new policies should not weaken the leadership of European high-end and luxury industries and preserve their ability to provide meaningful solutions and innovate while remaining competitive in the global market. ● Involve industry in the elaboration of sector-specific targets: Defining criteria for packaging design in collaboration with the industry which must be involved in the definition of sector-specific targets. 3 ● Guarantee adequate time to adjust: When changes are deemed necessary, reasonable transition timelines should be provided, notably for existing products to find substitutions. I.

…necessary, reasonable transition timelines should be provided, notably for existing products to find substitutions. I. Finding the right balance between innovation, creativity and circularity of packaging (Packaging minimization - Article 9 and Annex IV) Research, development, and innovation have driven significant improvements in our product packaging circularity. The perfume industry is one of the best examples, constantly innovating to reduce the environmental footprint of its glass packaging1 (reducing the thickness of bottles, incorporating recycled glass, etc. while retaining purity, brilliance, and transparency).

…the thickness of bottles, incorporating recycled glass, etc. while retaining purity, brilliance, and transparency). While we support the overall objective of packaging minimization, we believe that overly restrictive provisions could lead to the gradual standardization of packaging, which would have a catastrophic impact on our industries on several levels:  Limiting European added value, by taking away the key ability for European high- quality products to demonstrate their uniqueness, quality and brand to European customers.  Increase in counterfeiting2, which is in constant geographical expansion. Its scope is now comparable to the strongest European industrial sectors. Standardization of packaging formats, in the perfumery and cosmetics or wine and spirits sectors, for example, would unnecessarily facilitate the action of counterfeiters who would simply have to copy a few formats.

…for example, would unnecessarily facilitate the action of counterfeiters who would simply have to copy a few formats. Fake packaging would also lure the consumers into believing they are buying genuine products and thus potentially put their health at risk through the consumption of counterfeit products.  Impact on our global competitiveness, as competitors from outside the EU would retain the ability to offer more attractive packaging outside of Europe. As a reminder, high-end and luxury industries export on average 60% of goods produced3.  Disappearance of traditional European know-how: the standardization of packaging would put at risk thousands of European artisans’ jobs (e.g., glassmakers, wood and leather artisans) rooted in several generations of traditional European savoir-faire.

…jobs (e.g., glassmakers, wood and leather artisans) rooted in several generations of traditional European savoir-faire. In order to strike a balance between the Commission’s objective of packaging minimization while preventing the potentially devastating impact that packaging standardization would have on our industries, we suggest the following adjustments: 1 In 2020, in the EU27 + the UK, on average 79% of glass packaging was collected for recycling (data published by Close the Glass Loop: link) 2 According to recent studies, the counterfeiting of alcoholic beverages remains a significant public health concern and has a substantial impact on both the legitimate sector and state revenue. Wine, spirits, distilled beverages, liqueurs, and beer are all targets for counterfeiters.

…sector and state revenue. Wine, spirits, distilled beverages, liqueurs, and beer are all targets for counterfeiters. In 2019, perfumes and cosmetics were the third most seized IPR-infringing goods at the EU’s external border (in terms of the number of seizure procedures). These counterfeit perfumes and cosmetics were valued at approximately EUR 40 million at the time of the seizure. Packaging materials for perfumes became one of the most-seized fake goods at the EU’s external border in 2020. In 2019, packaging materials were the third most frequently encountered counterfeit articles seized at the EU’s external border, continuing the trend from 2018. In 2020, it was the top category. In 2020, packaging materials were also among the five most frequently encountered categories of counterfeit articles seized in the internal market, together with the category of labels, tags and stickers.

…of counterfeit articles seized in the internal market, together with the category of labels, tags and stickers. (Data from EUIPO & Europol 2022, Intellectual Property Crime Threat Assessment 2022, Publications Office of the European Union, Luxembourg: link) 3 Contribution of high-end CCIs to the European economy, Bain Report 2020:link) 4

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