INTERGRAF · Trade and business associations · BE
Printing Industry & Packaging Position paper for the Public Consultation to inform the review of the requirements for packaging and other measures to prevent packaging wasteDecember 2020 About usIntergraf is the European federation for print and digital communication . We represent 21 national printing federations from 20 countries, and, in turn, our members represent a large portion of the printing industry in Europe. Intergraf shares its secretariat with FTA Europe, which represents the flexo grap hic printing industry. Flexo is the single largest technology used for printed packaging , with an over 50% market share .Printers are at the heart of the packaging value chain . • The majority of consumer packaging sold in the EU is printed (flexible packaging over 75%; corrugated over 80%; and carton over 90%).
…packaging sold in the EU is printed (flexible packaging over 75%; corrugated over 80%; and carton over 90%). • The printing industry (EU + UK) consists of over 110,000 companies and 600,000 employees . • Printers have a turnover of €160 billion from printed packaging as well as graphic print such as books, newspapers and advertising. • 95% of the industry are SMEs , employing fewer than 20 employees – often fewer than 10 . • Printers use many different materials (plastic, paper & board , metals etc .), either printing directly on the substrate, or on a label. • Printers range in the influence they have on the final packaging – some are involved in the design process, some just advise on the components, others have n o influence at all. • The work of a printer changes all the time – paper type or thickness, inks, packaging layers – it is always a unique product.
…of a printer changes all the time – paper type or thickness, inks, packaging layers – it is always a unique product. The printer needs to be able to offer these wide -ranging options to their customer , or the customer will go e lsewhere . Ref. Ares(2020)7883383 - 22/12/2020 Our 7 call s to the European Commission
…or the customer will go e lsewhere . Ref. Ares(2020)7883383 - 22/12/2020 Our 7 call s to the European Commission 1. Packaging serves a n essential purpose Packaging protects the product, from its journey from the printer to the shelves in the shop. It prolongs shelf life and prevents damage. It makes food last longer – a crucial way to combat food waste which is a major contributor to consumers’ environmental footprints. Packaging also provides consumers with information, such as ingredients, us age instructions , and branding . Notions like ‘over -packaging’ or ‘unnecessary to protect the product’ are extremely vague and risk damage to products (creating waste) if new rules do not work in harmony with the functionality of packaging . Lessons must be learnt from the quickly adopted Single Use Plastics Directiv e, and the delayed guidelines : definitions and clarity is of paramount…
…hygiene and health is the central issue. Clearly, packaging is an essential product for all our lives. 2. Sustainability should be the goalAchieving sustainability must the European Commission’s goal. Target setting and design requirements in t hemselves as the aim risk hitting the target but missing the goal. Recyclability is not more important than sustainability . Overall life -cycle analyses (LCA) to determine CO2 emissions must be carried out for all new initiatives, such as encouraging the uptake of reusables or ‘loose’ products. The sustainable solution must take into account the source of the material, transport, and ease of disposal.A recent study 1 has found that focussing on single product attributes such as recyclability, being biobased, or having a certain recycled content level is the wrong approach .
…attributes such as recyclability, being biobased, or having a certain recycled content level is the wrong approach . The authors state : “ Life cycle thinking, consistent application of existing product category rules, and widespread adoption and further development of environmental production declarations should be used as the primary methods when aiming to reduce the environmental impacts .” Printers use a full range of materials because every product has a different requirement. In order to avoid spo ilage or contamination of products, all materials must be readily available. W e already see examples of reusable industrial packaging in the printing industry ; for instance, boxes or the inner rolls of film being returned to the printer. But this is not always possible: consider biscuits baked and packed in Belgium which are shipped to Chin a .
…printer. But this is not always possible: consider biscuits baked and packed in Belgium which are shipped to Chin a . These are packed to last 1 year, and the CO2 cost of shipping back their empty wrappings cannot be justified.A strong distinction should also be made between reducing ‘packaging waste ’ and reducing packaging . In order to create an economically viable secondary -material market, packaging m ust be collected and processed. And ,of course, it should never end up littered in the environment. 1 ‘The Significance of Environmental Attributes as Indicators of the Life Cycle Environmental Impacts of Packaging and Food Serv ice Ware ’ https://pubs.acs.org/doi/10.1021/acs.est.9b07910 3. Cost and availability are the barrier s to uptake of recycled materials Many printing companies are ahead of regulation when it comes to sustainability .
…to uptake of recycled materials Many printing companies are ahead of regulation when it comes to sustainability . Alternative materials and water -based inks have been on offer in many printed packaging companies for 10 years or more. Some printers even have in - house recycling facilities to create secondary materials . However, ultimately, the final choice is made by the brand owner . Biofilms , for example, can be up to 2.5 times more expensive than regular films. Virgin paper is also often cheaper than recycled – and does not pose any risk for food contamination . Due to the fall in oil prices in 2020, virgin plastics materials are currently cheaper than secondary .Combined with the low levels of plastic recycling, availability worsens the situation. Faced with the high cost, in most brand owners’ eyes, this is a quick choic e.
…availability worsens the situation. Faced with the high cost, in most brand owners’ eyes, this is a quick choic e. If the European Commission wants to achieve higher usage of recycled content in packaging, making it the cheap choice is the single most impactful task . Closely following this number one priority : a review of waste management infrastructures in the EU should be carried out .If the packaging is not recycled in the first place, or is not profitable to process, then a scarcity of recycled content is cr eated , meaning low availability for printers. Packaging ending up in landfill or the ocean is a wasted res ource . We call for the Commission to create a competitive market for recycled materials for non -food packaging, so that sustainability does not mean higher costs .
…competitive market for recycled materials for non -food packaging, so that sustainability does not mean higher costs . 4. FCM must be exempt from targets for recycled co ntent Food contact materials must be exempt from any future requirements for recycled content in packaging. Whilst advances in product passporting, and materials tracking is happening, we see the situation now where brands are choosing virgin over r ecycled materials to minimise the risk of contaminatio n . New rules must not undermine legislation on food contact materials. The necessity of adding a barrier layer between the recycled material and t he food would then increase the packaging used for these products. We welcome the European Commission’s review of food contact material legislation and stand ready to provide input. 5.
…welcome the European Commission’s review of food contact material legislation and stand ready to provide input. 5. Consumers must play their part – and be helped to do so While 9 in 10 consumers say protecting the environment is important to them, according to Eurobarometer, only 22 % had bought products with an environmental label, 31 % avoided buying overpackaged products, only 32 % repaired a product rather than replacing it, a nd only 66 % said they separated most of their waste for recycling 2 . Evidence shows that there is a gap between consumers’ good intentions, and what they actually do. Consumers act on many considerations, including price, convenience, habits, peer pressure, an d emotional appeal 3 .The consumer has also changed: more packaging is used in the EU today in part due to lifestyle changes. For instance, a person living alone requires a smaller loaf of bread.
…in the EU today in part due to lifestyle changes. For instance, a person living alone requires a smaller loaf of bread. This creates more packaging. We strongly urge the Commission to place consumer behaviour at the core of the EU’s circular economy strategy and future legislation . 2Special Eurobarometer https://ec.europa.eu/commfrontoffice/publicopinion/index.cfm/survey/getSurveydetail/instruments/special/surveyky/2257 3European Parliament briefing ‘Sustainable consumption -Helping consumers make eco -friendly choices’, October 2020. Closely tied to the choices which consumers make, is the actions they take post -consumption . Th e most recyc lable packaging has been designed in vain if its not disposed of (and then collected and processed) correctly . Recycled content will not be readily available if the consumers do not first dispose of the packaging correctly.
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Intergraf feedback: Reducing packaging waste – review of rules August 2020 About usIntergraf is the European federation for print and digital communication . We represent 21 national printing federations from 20 countries, and, in turn, our members represent a large portion of the printing industry in Europe. Intergraf shares its secretariat with FTA Europe, which represents the flexo printing industry. Flexo is the single largest technology used for printed packaging. • The printing industry (EU + UK) consists of over 110,000 companies and 600,000 employees . • Printers have a turnover of €160 billion from printed packaging as well as graphic print such as books, newspapers and advertising. • 95% of the industry are SMEs , employ ing fewer than 20 employees – often fewer than 10. Feedback Printers are at the heart of the packaging value chain .
…fewer than 20 employees – often fewer than 10. Feedback Printers are at the heart of the packaging value chain . We bring together all the components which are required to make the resulting packaging. Printers are also highly active in the circular economy, utilising recycled materials in our products, and deploying innovative printing processes and chemicals to reduce environmental impact. Intergraf supports harmonised packaging requirements at EU level and the ambition to reduce the environmental impact of waste. We therefore welcome the European Commission’s review of rules for packaging and packaging waste in the EU. We urge the European Commission to pay particular attention to the following points: • Although packaging design and industry is an important part of the process, it is one part of a chain of actions required to reduce the environmental impact of packaging.
…part of the process, it is one part of a chain of actions required to reduce the environmental impact of packaging. The best de signed, environmentally friendly packaging still needs the consumer to dispose of it correctly, and the recycling plant to process it. Therefore, structural issues with the waste system must be prioritised over new design requirements. • Packaging functionality is essential. No single material should be singled out as less environmentally friendly than others. All materials used for packaging are selected on the basis Ref. Ares(2020)4116456 - 05/08/2020 of how well they will protect the product. Analysis of the complete pict ure as well as scientific evidence is required to evaluate the environmental footprint of packaging: from the processes which make it, to transport, to consumption and recycling.
…the environmental footprint of packaging: from the processes which make it, to transport, to consumption and recycling. • Any future changes to the PPWD must be developed in close collaboration wit h both producers and recycling authorities to ensure a coherent and industry -led solution with high levels of compliance and achievement of environmental aims. • Evidence related to assumptions and terms like “over -packaging”, “single -use”, or the degree to which packaging is recycled must be carefully assessed and clarified. Packaging protects the product, prolongs shelf life, and reduces food waste – which all co ntribute to environmental goals. • Food waste, food safety, and packaging are closely interlinked issues.
…which all co ntribute to environmental goals. • Food waste, food safety, and packaging are closely interlinked issues. The review of the PPWD there fore should be carried out in parallel to, and in harmony with, the European Commission’s review of legislation applicable to food contact materials. • A key target for the European Commission should be to stimulate a competitive market for all recycled materials to make high quality materials read ily available for printers. • Harmonised European legislation on packaging and waste is crucial t o solve European - wide issues and to coordinate an industry that crosses borders. The European Commission must preserve the integrity of the Single Market and intervene in the numerous national measures that could pose obstacles to the free trade of packaging within the EU.
…and intervene in the numerous national measures that could pose obstacles to the free trade of packaging within the EU. We remain at your disposal for further information and look forward to working with the European Commission in the next steps of this process.