FEA · Trade and business associations · BE
…3 March 2023 Page 1 of 2 Proposal for a Packaging & Packaging Waste Regulation1 Position Paper Aerosol containers are generally made from aluminium or steel – permanent recyclable materials with established market demand. When separated during collection or sorting, post-consumer aerosols can be recovered and recycled as part of the appropriate packaging material stream. Large numbers of empty aerosols are already being recycled successfully in Europe and around the world. The European Aerosol Federation (FEA) welcomes that all packaging shall be recyclable and comply with design for recycling criteria. FEA considers that all aerosols – independently of the container material – should be covered by these legal provisions. In the Annex II Table 1, the format ‘aerosols’ is correctly included in the categories No 5 Metal / Steel and No 7 Metal / Aluminium.
Table 1, the format ‘aerosols’ is correctly included in the categories No 5 Metal / Steel and No 7 Metal / Aluminium. However the format ‘aerosols’ is missing in the categories No 2 Glass / Composite packaging, of which the majority is glass and No 12 Plastic / PET – rigid. Aerosol dispensers – independently of the container material – fall under the scope of the Aerosol Dispenser Directive 75/324/EEC and the Inland Transport of Dangerous Goods Directive 2008/68/EC. Like aluminium and steel aerosols, glass and plastic aerosols have been placed on the EU internal market for many years. Even if they represent less than 1% of the entire aerosol market, glass and plastic aerosols should be covered by the same provisions. This will bring legal clarity and certainty, as well as a level playing field within the aerosol industry.
…provisions. This will bring legal clarity and certainty, as well as a level playing field within the aerosol industry. FEA advocates to include the format ‘aerosols’ in the categories No 2 Glass / Composite packaging, of which the majority is glass and No 12 Plastic / PET – rigid in the Annex II Table 1. 1 Proposal for a Regulation of the European Parliament and the of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC, COM(2022) 677, 2022/0396(COD) Ref. Ares(2023)1757175 - 10/03/2023 3 March 2023 Page 2 of 2 About FEA The FEA (Fédération Européenne des Aérosols or European Aerosol Federation) was founded in 1959. Today, the FEA represents 18 European countries which include more than 350 small and medium sized enterprises (SMEs) and multinationals active in the aerosol industry.
…include more than 350 small and medium sized enterprises (SMEs) and multinationals active in the aerosol industry. It has also close links with aerosol associations worldwide. Within the aerosol industry, the FEA community works towards achieving sustainable economic growth by focusing on social and environmental responsibilities. In practice this means: - placing safe aerosol products on the market. - offering a unique, convenient and high-performance product for everyday life. - constantly working towards technical and economic solutions to reduce the environmental footprint of aerosol products. - developing guidelines on industrial safety and promoting good industrial safety practices. - supporting safe and sustainable innovations by proactively proposing updated legal frame.
…safety practices. - supporting safe and sustainable innovations by proactively proposing updated legal frame. For more information: www.aerosol.org Alain D’haese – FEA Secretary General, [email protected] FEA’s public ID number in the Transparency Register of the European Commission is 32814201372-84.