European Potato Trade Association

Rue des Deux Églises 26 1000 Brussels • Belgium [email protected] • www.europatat.eu 28 March 2023 Europatat feedback on the EU Commission Proposal for a Regulation on Packaging and Packaging Waste Europatat is the European Potato Trade Association, comprising both national associations and individual companies involved in the trade of seed, ware and early potatoes throughout Europe. Its members include a wide range of traders (including breeders, distributors, storers, packers, importers and exporters) delivering seed potatoes to farmers, raw material to the food industry, and packed potatoes to the retailers and food service sector. Europatat members use packaging throughout the entire supply chain to provide safe, high quality and fresh potatoes to consumers.

…members use packaging throughout the entire supply chain to provide safe, high quality and fresh potatoes to consumers. Whilst potato traders fully welcome and support European Green Deal’s objectives in terms of packaging and sustainability, the sector also needs an EU harmonised and rational legislative basis to avoid the fragmentation of EU’s single market due to inconsistent national packaging law. Therefore, Europatat wishes to contribute to the feedback period open by the European Commission on the Proposal for a Regulation on Packaging and Packaging Waste (PPWR). Summary of key messages from the potato trade sector: • Europatat fully supports PPWR’s objective to increase harmonisation and clarity on requirements for packaging and packaged goods at EU level.

PPWR’s objective to increase harmonisation and clarity on requirements for packaging and packaged goods at EU level. • Before adopting PPWR’s targets and restrictions as proposed, these should first be assessed following a science-based and a case-by-case approach and taking in consideration the respect to EU legislation on hygiene and food safety currently in place. • Europatat supports PPWR’s ambition to increase the use of minimum recycled content in plastic packaging but remain concerned in relation to the market availability of safe compliant recycled content due to differences in packaging waste collection, sorting and recycling infrastructure at Member States’ level.

…due to differences in packaging waste collection, sorting and recycling infrastructure at Member States’ level. • Although there is not clear indication in the PPWR whether potatoes are considered as vegetables for the effects of the proposed regulation, Europatat disagrees with the discriminatory approach towards the fresh sector through the proposed ban of packaging for less than 1,5 kg fresh fruit and vegetables and reiterates and defends the essential role of packaging all along the potato supply chain. • Europatat calls on the inclusion of a clear timeframe for the adoption of the delegated acts that will lay down the lists of exceptions necessary to safeguard plant health and food safety in the EU. Ref.

…acts that will lay down the lists of exceptions necessary to safeguard plant health and food safety in the EU. Ref. Ares(2023)2241740 - 28/03/2023 Rue des Deux Églises 26 1000 Brussels • Belgium [email protected] • www.europatat.eu - Legal instrument and legal basis In a trading environment with increasing costs for potato operators, higher consumer prices and a steady decreasing trend in fresh produce consumption, any measures adding additional costs and trade barriers along the potato supply chain, namely diverging packaging requirements across Member States, should be avoided. A harmonised and impact assessment-based EU packaging legislation is key to avoid any distortions on Europe’s Single Market. In this sense, Europatat welcomes the choice of a Regulation as legal instrument and an internal market legal basis for amending the EU rules on packaging and packaging waste.

…as legal instrument and an internal market legal basis for amending the EU rules on packaging and packaging waste. Moreover, to make sure a full harmonisation is achieved, Europatat calls on the European Commission to formally oppose to the proliferation of divergent national measures on packaging that are jeopardising the potato trade in the EU single market. - Impact assessment of the proposed measures While proposing a new Regulation on packaging and packaging waste is necessary to harmonise the production, use and waste management of packaging in Europe, there is a need for a thorough and science- based assessment of any proposed targets and restrictions regarding packaging.

…is a need for a thorough and science- based assessment of any proposed targets and restrictions regarding packaging. More concretely, it appears that a full and detailed analysis of the impact of restricting packaging for fresh fruits and vegetables has not been properly undertaken in the Commission’s impact assessment of the PPWR. Potential and unintended consequences related to product safety, consumer health and even food waste should be carefully analysed as, if adopted, this measure can have negative economic impacts on the fresh potato supply chain without a clear and proved added environmental value. Therefore, Europatat calls on the Commission and co-legislators to assess in a science-based and a case-by- case approach PPWR’s targets and restrictions before their adoption.

…to assess in a science-based and a case-by- case approach PPWR’s targets and restrictions before their adoption. - Article 7: Minimum recycled content in plastic packaging Since many years, potato packers are investing in testing and using alternatives to reduce the use of virgin plastic in packaging. One of those alternatives is Post-Consumer Recycled material (PCR). While the sector does not oppose to PPWR’s ambition to increase to 10% the minimum recycled content made by plastic materials other than PET by 2030, exceptions should be allowed in case of lack of availability, excessive prices and food safety standards of specific recycled plastics (specially of those in contact-sensitive applications such as food).

…safety standards of specific recycled plastics (specially of those in contact-sensitive applications such as food). Current differences in packaging waste collection, sorting and recycling infrastructure at Member States’ level are slowing down the development of a European market for secondary raw materials, which is indispensable to meet the targets set in the PPWR. Europatat encourages the Commission to support Member States in speeding up their national recycling infrastructure and capabilities to secure the market availability of safe compliant recycled content to be used in potato packaging.

…and capabilities to secure the market availability of safe compliant recycled content to be used in potato packaging. Rue des Deux Églises 26 1000 Brussels • Belgium [email protected] • www.europatat.eu - Article 22 and Annex V: Restriction on packaging formats According to EU legislation, fresh potatoes are not included in the list of products covered by the fruit and vegetables sector as established in Part IX of Annex I to Regulation (EU) No 1308/2013. However, in some EU countries, potatoes are being included in the scope of packaging bans for the fresh produce sector in formats of less than 1,5 kg. In a sector where businesses’ decisions and investments must be taken in a medium and long-term basis, legal clarity and homogenisation are vital to ensuring the competitiveness and sustainability of potato companies around Europe.

…and homogenisation are vital to ensuring the competitiveness and sustainability of potato companies around Europe. In this regard, Europatat calls on the Commission to clarify whether fresh potatoes fall under the scope of the packaging restrictions for fruit and vegetables as proposed in Article 22 and Annex V. A proper definition and list of products covered by ‘fruit and vegetables’ should be included in the PPWR.

…and Annex V. A proper definition and list of products covered by ‘fruit and vegetables’ should be included in the PPWR. However, although in the current PPWR’s proposal there is no indication whether potatoes are considered as vegetables for the effects of Article 22.1/annex V.2., Europatat disagrees with the discriminatory approach towards the fresh fruit and vegetable sector of this article: - As mentioned above, the lack of a detailed, product-oriented and science-based impact assessment of the restriction on use of single use packaging for formats of less than 1,5kg appears to be missing, which poses a problem regarding the rationality of the measure. Moreover, a more specific definition of ‘single-use packaging’ in relation with the definition included in the Single-Use Plastics (SUP) Directive and its Guidelines should also be developed.

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