TomatoEurope Processors Association

…1 Tel. + 32 2 761 16 57 Fax + 32 2 761 16 99 [email protected] - TVA BE 878.355.784 - www.tomatoeurope.eu TomatoEurope represents the tomato processing industry covering more than 95% of the European business. Active since 1979, it acts as an umbrella organization for national associations, indirectly representing more than 200 tomato processing entities. TomatoEurope welcomes the initiative from the Commission to further combat packaging waste and increase packaging circularity across the European Union. We believe that the Packaging and Packaging Waste Regulation (PPWR) represents a most indicated legislative tool to attain this goal. As such, we welcome the PPWR’s general principles of substantial packaging reduction and better circularity of raw materials.

…we welcome the PPWR’s general principles of substantial packaging reduction and better circularity of raw materials. Furthermore, we are most appreciative that the Commission aims at strongly protecting the fluidity of its Single Market. We therefore strongly support:  Article 4, which stresses the importance of free movement of packaging across the EU;  Article 11.1 which sets up harmonized sorting labels across the EU, allowing consumers to properly sort their packaging which will contribute to improving recycling rates;  Article 6 supporting the development of a harmonized definition of ‘recyclable packaging’ at EU level;  And the choice of a Regulation over a Directive which strengthens a uniform application of the provisions across Member States.

…choice of a Regulation over a Directive which strengthens a uniform application of the provisions across Member States. We believe however that Article 26 on the re-use and refill targets contains overly ambitious targets difficult to attain by the tomato industry. In particular, Article 26 paragraphs 12-13 and its linked definition of ‘transport packaging’ (Article 3.4) are ambiguous as to the inclusion of the drums we use in our business, but we understand that the aseptic bags that they transport inside are completely outside of the scope of this article (see figure 1 and 2 below). Moreover, we believe that these paragraphs are especially stringent and worrisome for our industry in case of inclusion: These paragraphs oblige our industry to make use of fully re-usable drums for the transport of our main product i.e., tomato pulp and/or paste. (see figure 1 and 2 below).

…fully re-usable drums for the transport of our main product i.e., tomato pulp and/or paste. (see figure 1 and 2 below). The point is that these drums/bins or crates could be re-usable which they already are in many cases. In so being, they are also compliant with the Article 10 definition of ‘re-usable’. On the other hand, the primary packaging used (aseptic flexible bags) is highly gamma- sterilized and cannot be reused more than once for obvious sanitary reasons considered as common hygiene practice in the industry. Ref. Ares(2023)2891773 - 24/04/2023 2 Tel.

…sanitary reasons considered as common hygiene practice in the industry. Ref. Ares(2023)2891773 - 24/04/2023 2 Tel. + 32 2 761 16 57 Fax + 32 2 761 16 99 [email protected] - TVA BE 878.355.784 - www.tomatoeurope.eu Figure 1 Figure 2 More specifically, as our products are completely aseptically processed and aseptically packed, it is necessary to use a completely aseptic packaging as the flexible bag that used is. Therefore, it is completely impossible to re-use the aseptic bag as, according to its own definition, the sterility of the bag and of course of the product it-self, is lost once the packaging is opened.

…own definition, the sterility of the bag and of course of the product it-self, is lost once the packaging is opened. We hence ask the Commission to explicitly exempt these aseptic bags from the obligation to be re-usable as the tomato industry would not be able to find any other hygiene-compliant alternative for them at this point. We are also concerned with the Article 22 bans in particular its linked Annex 5.1. This latter annex would prohibit all products group-wrapped with plastic packaging for convenience reasons and would in essence ban all cans of tomatoes packed together to make one unit of sale. This goes against the nature of our products which are most often sold in cans to preserve their freshness for longer periods of time and are consequently often bought in bulk as they serve as a staple for many culinary applications.

…periods of time and are consequently often bought in bulk as they serve as a staple for many culinary applications. Moreover, we feel that the absence in Article 22 of scientific and/or researched and measurable criteria shaping the eventual Annex 5 list is dangerous and might pave the way to future arbitrary and unsubstantiated bans of certain products as per delegated acts foreseen in Article 22 paragraph 4. In conclusion, we ask that explicit criteria be used for establishing Annex 5 and that plastic wrappings could still be used for staple products. Lastly, in the same vein as our previous concerns, we feel that Annex 5.4, banning all single-use sachets, tubs, trays, boxes for single-serve portions of tomato ketchup could lead to unsanitary situations in fast food restaurants or the HORECA in general.

…portions of tomato ketchup could lead to unsanitary situations in fast food restaurants or the HORECA in general. Additionally, single portions are well-known to help counter food waste, the latter occurring easily when left to the consumer’s personal choice of serving. As Annex 5.4 poses certain hygiene and food waste risks, we plead for a possible reconsideration of this ban. Finally, we believe that the PPWR has the potential to accelerate the transition towards a circular economy for all packaging. As this necessitates major adaptations for the industry, we remain confident that the Commission will take our remarks into due consideration. Marco Baldoli, Secretary General, TomatoEurope Transparency Register Number: 35628678901-76

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