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AREFLH MIN de Brienne, 110 quai de Paludate - BP26 - 33800 BORDEAUX Tel : +33.5.33.89.10.19 www.areflh.org – [email protected] ASSEMBLY OF EUROPEAN HORTICULTURAL REGIONS 21 APRIL 2023 AREFLH COMMENTS ON THE DRAFT REGULATION ON PACKAGING AND PACKAGING WASTE The Assembly of European Horticultural Regions (AREFLH) main missions are: • to represent its 16 member regions, 32 POs and AOPs and 8 associated members (experts), from 10 European countries; • to defend the economic and social interests of the fruit, vegetable, and horticultural sectors in Europe; • to foster exchanges of best practices, partnerships and joint projects between regions and professional organisations; • to actively seek new solutions for the main issues affecting the future of the fruit and vegetables production in Europe.
…actively seek new solutions for the main issues affecting the future of the fruit and vegetables production in Europe. Click to select your language: English/ Français / Italiano / Español EN: AREFLH COMMENTS ON THE DRAFT REGULATION ON PACKAGING AND PACKAGING WASTE As AREFLH, we follow developments related to the green transition and the agriculture sector’s role within it with great interest. As the transition into the new CAP programming period takes place at a time of economic uncertainty and increased pressure on the food supply chain, we wish to bring DG ENV’s attention to certain elements relating packaging and packaging waste that directly affect the optimal functioning of Producer Organisations in the sector.
…packaging and packaging waste that directly affect the optimal functioning of Producer Organisations in the sector. The proposed regulation that amends Regulation 2019/1020 and Directive 2019/904 that will govern packaging and packaging waste after the repeal of Directive 94/62/EC has raised some concerns from our members regarding potential impacts on the fruit and vegetable sector. Below are our observations on the proposed regulation that have come to our concern. LACK OF ACKNOWLEDGEMENT OF DIFFERENT NEEDS The proposed regulation does not appear to recognise the needs for packaging of different fruit and vegetables, or the reasons for the use of packaging in general, using the 1,5 kg cut- off for packaging use in a general manner. Ref.
…the reasons for the use of packaging in general, using the 1,5 kg cut- off for packaging use in a general manner. Ref. Ares(2023)2841350 - 21/04/2023 AREFLH MIN de Brienne, 110 quai de Paludate - BP26 - 33800 BORDEAUX Tel : +33.5.33.89.10.19 www.areflh.org – [email protected] Certain products are highly susceptible to bruising that will reduce the amount of produce that can be sold fresh, and therefore need specific packaging for quality to be guaranteed and for transport to markets far from producers and packers. Additionally, certain crops are frequently sold with very specific packaging formats (e.g., mushrooms are generally sold in pre-package formats of under 750 grams per unit), and the same quality and shelf life is not guaranteed with a switch to larger formats or bulk sales.
…grams per unit), and the same quality and shelf life is not guaranteed with a switch to larger formats or bulk sales. Similarly, it appears not to take into consideration what the markets for different products are, and therefore the logistics that need to be accounted for, which influence what packaging is needed to guarantee the products’ integrity in its transit towards its final market. This would indicate a limited understanding of the role of packaging, as it is not an element in which the product is sold, it is part of the product itself. It is therefore necessary to evaluate the need for packaging according to the product’s entire life cycle rather than within the framework of generalised targets that miss the specificities of certain products.
…cycle rather than within the framework of generalised targets that miss the specificities of certain products. EXCESSIVE PRESSURE ON PRODUCER ORGANISATIONS Recital 70 of the proposed regulation opens to granting exemption to certain business to the proposed rules, and paragraph 14 of Article 26 also confirms exceptions for certain economic operators to the targets for reusable packaging. This places Producer Organisations in the fruit and vegetable sector in a position of having to operate under stringent targets all while continuing to maintain production levels and deliveries to destination markets at the same level.
…targets all while continuing to maintain production levels and deliveries to destination markets at the same level. Additionally, as the regulation would work to restrict the use of all packaging types, this increases the difficulties for Producer Organisations that need to sell in markets far from their production and collection sites, severely limiting their economic opportunities and viability. As Producer Organisations have often invested in moving towards recyclable single-use packaging (e.g., investing in the machines necessary for preparing four-fruit cardboard baskets), this could mean that investments co-financed with European funds through their operational programmes would no longer be usable and investments must be made from scratch to satisfy the new requirements.
…programmes would no longer be usable and investments must be made from scratch to satisfy the new requirements. It is advisable to consider an exemption for Producer Organisations in the fruit and vegetable sector in order to work on recycling rather than a switch to reuse, allowing for improvements in the supply chain and product life cycle in its current form rather than an extensive reorganisation of supply chains. AVAILABILITY OF ALTERNATIVES The proposed regulation needs to take into consideration what alternatives to packaging are available for specific products. While the use of recycled materials is an admirable objective that merits support, it is not clear whether the necessary quantities of material that complies with the standards set out in the proposed regulation are currently available.
…quantities of material that complies with the standards set out in the proposed regulation are currently available. AREFLH MIN de Brienne, 110 quai de Paludate - BP26 - 33800 BORDEAUX Tel : +33.5.33.89.10.19 www.areflh.org – [email protected] If this is not the case, the fruit and vegetable sector will be forced to use packaging that increases the risk of produce loss both in transit to sales points and at sales points, leading to an increase in food waste, or forego packaging entirely and likewise increase losses. It is also important to take into consideration the increasing use of organic packaging, that, while not always recyclable, offers a biodegradable alternative to single-use plastic and can therefore continue to operate in the agricultural value chain, for example by contributing to compost.
…plastic and can therefore continue to operate in the agricultural value chain, for example by contributing to compost. HARMONISED EUROPEAN RULES As this regulation will require major changes to packaging across the Single Market, there must be uniform requirements for the packaging that will be permitted to avoid market distortions. This needs to be outlined in clear terms, otherwise individual Member States could interpret these requirements in their own way and risk divergence within the Single Market. A harmonised European label, as outlined in Paragraph 5 of Article 11 in the draft regulation, is essential to communicating a common understanding of rules and common standards applicable across the Single Market, to avoid a patchwork of national rules that complicate the management of said packaging and the goods it carries.
…to avoid a patchwork of national rules that complicate the management of said packaging and the goods it carries. Harmonisation of rules at the European level is therefore essential to ensure that trade within the Single Market can continue unimpeded and packaging norms need not be adapted for differing national standards, which would entail serious difficulties in recovering packaging from beyond national borders or investments to adapt packaging to different national markets. AVOID GREENWASHING ATTEMPTS The proposal in the regulation for stickers used on fruit and vegetables to be biodegradable could be exploited for the purpose of greenwashing, as it could be used to channel investments towards the development of such stickers rather than more consistent investments that can have a greater positive impact on sustainability.
…of such stickers rather than more consistent investments that can have a greater positive impact on sustainability. The question of stickers would be better addressed by working to include them in existing recycling channels, allowing the materials to be processed and reused according to technology that is already available in the sector rather than investing large sums in developing new stickers. It is therefore necessary for the regulation to set out standards that meaningfully improve sustainability and limit opportunities for investments that bring little improvement to the overall environmental and resource footprint of the operation and serve mainly to greenwash.
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