Interesų grupė
Assomela response to European Commission Public Consultation for a ‘Review of the requirements for packaging and other measures to prevent packaging waste’ Packaging is an essential element of the Italian apple supply chain. Producers and traders use packaging to provide safe, high quality and fresh apples to consumers. Assomela supports the European Green Deal’s ambitions to increase the sustainability of packaging use through enhanced reusability and recyclability of packaging as well as the commitment to tackle over-packaging and waste generation, which is also reflected in the new Circular Economy Action Plan (CEAP 2.0). While much effort has been made by the Italian apple sector to address packaging use through innovations in packaging materials and design as well as reductions in over-packaging, there remains scope for change to further boost the sustainability of the sector.
…well as reductions in over-packaging, there remains scope for change to further boost the sustainability of the sector. Even if Assomela welcomes the review of the Directive 94/62/EC on Packaging and Packaging Waste and the requirements of packaging and other measures to prevent packaging waste, Assomela would like to underline the need for a full and detailed analysis of the impact of proposed changes to packaging legislation, which will have both direct and indirect implications for the apple sector. Functional packaging in the apple sector Packaging for apples is predominantly used by the sector for the following reasons: • Product containment • Extend product shelf life: Fresh apples crosses many stages in the supply chain before arriving at the home or in foodservice for consumption.
Fresh apples crosses many stages in the supply chain before arriving at the home or in foodservice for consumption. Apples are delicate and perishable and during each stage of the supply chain must be protected so that they arrive at the consumer in good condition as per marketing standards. In this way packaging extends the shelf life of products by limiting minor damage to products that eventually may increase product perishability. • Prevent food spoilage and waste: By extending the shelf life of products, protection provided by packaging prevents food waste by limiting product damage and maintaining freshness at each stage of the chain and in the home. • Prevent microbiological contamination • Product information display: Packaging offers the sector possibilities to communicate to both supply chain actors and consumers with obligatory and essential product information.
…to communicate to both supply chain actors and consumers with obligatory and essential product information. Obligatory and essential information includes but is not limited to variety, colour, size, traceability, branding, country of origin, PLU codes, organic distinction from conventional products and fraud detection, EU quality schemes’ logos. • Consumption promotion • Consumption facilitation • Consumer confidence: Packaging gives confidence to consumers in guaranteeing both product safety and quality. Particularly during health crises, such as the current COVID-19 pandemic, packaging provides food safety and quality certainty to consumers, which facilitates continued consumption Ref. Ares(2021)82440 - 05/01/2021 levels vital for the good health of citizens (demand for prepacked apples were at + 40% during the COVID-19 first wave).
…vital for the good health of citizens (demand for prepacked apples were at + 40% during the COVID-19 first wave). Assomela asks that the above-mentioned aspects of packaging used in the apples sector and more in general in the fresh fruit and vegetable sector are adequately reflected in the European Commission proposal. Essential packaging & packaging waste policy aspects in the review of Directive 94/62/EC Assomela would like to highlight the most important aspects regarding waste prevention and increasing packaging reusability and recyclability that must be taken into consideration. EU harmonisation is essential: Without EU harmonisation divergent measures at Member State and regional levels will disrupt the circulation of products on the internal market. Assomela supports the use of EU standards where possible.
…disrupt the circulation of products on the internal market. Assomela supports the use of EU standards where possible. Waste prevention must be supported by a harmonised EU waste management system Appropriate transition periods are necessary: For any new measures imposed at EU or Member State level appropriate transition periods must be included. These transition periods must be discussed with supply chain actors to guarantee feasibility to achieve targets. Unintended sustainability consequences, such as food waste, must be avoided: The review of Directive 94/62/EC must not result in unintended consequences that are detrimental to the fresh fruit and vegetable sector’s efforts to enhance product sustainability. Packaging plays an important and in some cases vital role in food waste prevention and therefore the overall sustainability of the product.
…and in some cases vital role in food waste prevention and therefore the overall sustainability of the product. While the sector is continually innovating to facilitate the sale of unpackaged products, packaging continues to be often used as an essential tool for food waste prevention in the chain, especially for products with high perishability. Food contact materials remain a barrier to recyclability and reusability: Ensuring food safety for the health of European consumers should remain a top priority. Innovation in this area must be facilitated, for instance through EU harmonisation of food contact material legislation. R&I funding must be provided: Specific funding for research, innovation and development for sustainable packaging solutions and infrastructure must be provided alongside other measures.
…and development for sustainable packaging solutions and infrastructure must be provided alongside other measures. Assomela remains concerned by some of the policy options outlined in the Inception Impact Assessment: Assomela does not support 1) any material-specific packaging waste reduction targets or waste generation limits, and 2) any consumption reduction targets/limits targeting specific packaging types or applications. Packaging product-specific concerns related to the review of Directive 94/62/EC In view of the review of Directive 94/62/EC Assomela would like to outline a number of concerns relating to packaging that is product-specific in the fresh fruit and vegetable sector.
…to outline a number of concerns relating to packaging that is product-specific in the fresh fruit and vegetable sector. Fresh fruit and vegetable sticker packaging Assomela, that has followed the subject through Freshfel Europe, would like to remind the European Commission of the following aspects relating to apples sticker packaging that must be taken into consideration: • Fresh fruit and vegetable stickers are an indispensable form of packaging in the European and global fresh produce sector. In particular, stickers play a vital role in the communication of obligatory and essential information for actors along the supply chain as well as for consumers that would otherwise necessitate further product pre-packaging.
…actors along the supply chain as well as for consumers that would otherwise necessitate further product pre-packaging. This includes variety, color, traceability, branding, country of origin, organic, quality schemes… • Assomela supports the European Commission’s vision to increase the sustainability of fruit stickers in light of the need to reduce packaging waste. As a form of highly minimal pre-packaging that has extensive marketing and communication benefits to the sector, retaining their use in Europe and globally is paramount. However, the recent adoption of varying Member State legislation (e.g., in Belgium) highlights the need for EU harmonization of any proposed legislation for these widely used products to avoid disruption of the circulation of fresh fruit and vegetable products on the internal market.
…products to avoid disruption of the circulation of fresh fruit and vegetable products on the internal market. • As only a very small percentage of the fruit and vegetable sticker market (<2%) currently represents industrially certified compostable stickers (often for organic products dues to price differentiation) and in consideration that a certified home compostable construction that is food safe for fresh fruit and vegetable stickers is not available on the EU market or globally, regulation for compostable fruit and vegetable stickers must include an appropriate transition period. • In defining an appropriate transition period, it must be taken into account that sticker construction development can take a minimum of three years and further compost testing to meet standards must subsequently be completed (6-10 months for industrially compostable sticker) after this period.
…to meet standards must subsequently be completed (6-10 months for industrially compostable sticker) after this period. Therefore, any transition period must be discussed with supply chain actors to guarantee feasibility to achieve targets. In consideration of a current lack of certified home compostable stickers on the market today, it could take 5-10 years for sector transition to a switch to certified home compostable offerings globally. Fresh cut fruit and vegetable packaging Packaging for the fresh cut category in the fresh fruit and vegetable sector must be carefully considered if packaging requirements were to change under this review of Directive 94/62/EC as fresh cut packaging requirements are highly specific, especially regarding oxygen permeability and strength requirements.
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