Assomet · Trade and business associations · IT
Via Sant'Uguzzone, 29 - 20126 Milano MI Tel.: +39/0266146580 Fax: +39/0266146599 www.assomet.it e-mail: [email protected] Cod. Fiscale: IT 02776350155 Banca Popolare di Sondrio Iban: IT 40 X 05696 01628 000002889X44 COMMENTS ON PACKAGING AND PACKAGING WASTE REGULATION PROPOSAL ASSOMET, the Italian non Ferrous Metals Industries Association Key messages Assomet welcomes the objectives of the proposal for a Regulation on Packaging and Packaging Waste (PPWR) of increasing the sustainability and circularity of packing products. As a permanent material, aluminium may be a key contributor to these objectives based on the material properties and the excellent results achieved in recycling and waste reduction in the EU and in particular in Italy. We call on the Commission to duly value the materials’ properties when defining the policy on packaging.
…in Italy. We call on the Commission to duly value the materials’ properties when defining the policy on packaging. The use of packaging made by permanent material and effectively collected and recycled, such as those in aluminium, should be allowed and encouraged. In Italy, the aluminium packaging’s recycling targets set for 2030 have extensively been overcome. The mandatory requirements on compostability for coffee and tea capsules (art. 8, par.1) would prevent the usage of aluminium for the production of coffee and tea single serve units, with severe impacts on the market without a real benefit for the environment. The aluminium capsules are 100% recyclable and designed to optimize and reduce the waste related to the packaging material and its content, preserving the quality of the beverage for a long time.
…the waste related to the packaging material and its content, preserving the quality of the beverage for a long time. Therefore, we do ask to maintain the neutrality of the choice of material for the production of beverage capsules and the neutrality of choice of the end-of-life solutions (recyclability or compostability). A general ban for single use applications is a very severe form of market restriction and need to be carefully assessed on a product-by-product case considering the properties of the materials, their recycling rates and the potential negative impacts that a ban could have on food waste, consumer behaviour, food safety, hygiene and the environment. Therefore, we urge the Commission to delete article 22. Assomet agrees to the need of reducing the generation of packaging waste.
…urge the Commission to delete article 22. Assomet agrees to the need of reducing the generation of packaging waste. However, we are extremely concerned that reuse targets, in particular the ones for food and beverages, lack of solid scientific analysis on the environmental impacts on a product-by-product level as well as impact on hygiene, food safety and food waste. We believe that the most balanced and suitable approach for optimizing the environmental sustainability of the use of packaging is to give Member States the choice of the best solution between reuse and/or recycling on a case by case basis. Therefore, we recommend deleting the Article 26 and, in particular, the reuse obligations envisaged, by 2030 and 2040, for take-away packaging referred to in paragraph 3. Ref.
…particular, the reuse obligations envisaged, by 2030 and 2040, for take-away packaging referred to in paragraph 3. Ref. Ares(2023)2854004 - 22/04/2023 2 Via Sant'Uguzzone, 29 - 20126 Milano MI Tel.: +39/0266146580 Fax: +39/0266146599 www.assomet.it e-mail: [email protected] Cod. Fiscale: IT 02776350155 Banca Popolare di Sondrio Iban: IT 40 X 05696 01628 000002889X44 Introduction Assomet represents the Italian producers and processors of non-ferrous metals: aluminium, lead, copper, zinc, precious metals, etc Overall, the sector is made up of 1.000 companies employing 26.000 people with an annual turnover of €28 billion euros. The aluminium foils production and aluminium packaging sector is very relevant among Assomet’s membership as well as in Italy as a whole.
…production and aluminium packaging sector is very relevant among Assomet’s membership as well as in Italy as a whole. According to 2021 data, the aluminium packaging sector in Italy is constituted by 28 companies with a total turnover of €3.6 billion, with an output of 249.000 tons1. PPWR Proposal: general remarks Assomet agrees to the objectives of the proposal for a Regulation on Packaging and Packaging Waste (PPWR) of increasing the sustainability and circularity of packing products. We fully support the objective to reducing the total environmental impacts of production and consumption of packaging and packaged goods and to reducing the waste production in line with the EU Green Deal goals. Consequently, the PPWR proposal aims to make the packaging more recyclable and to address the increase in packaging waste generation.
…the PPWR proposal aims to make the packaging more recyclable and to address the increase in packaging waste generation. It also aims to help Member States achieve recycling targets as agreed in the 2018 waste legislative package in a cost-effective way. As a permanent material, aluminium may be a key contributor to these objectives based on the material properties and the excellent results achieved in recycling and waste reduction in the EU and in particular in Italy. Sustainability and circularity of aluminium packaging Aluminium is the ideal solution for the production of sustainable packaging being 100% and infinitely recyclable whilst keeping all its characteristics as malleability, resistance to impacts and corrosion and its ability to guarantee a “barrier effect” that protects from light, air, humidity and bacteria.
…and corrosion and its ability to guarantee a “barrier effect” that protects from light, air, humidity and bacteria. Secondary aluminium has a very high value and a consolidated and well-functioning market already in place2. Moreover, aluminium allows, in each recycling phase, an average energy saving capacity of 95% comparing to the use of primary metal. 1 Istituto Italiano Imballaggio, Imballaggio in cifre 2022, 2022, p. 39 2 European Environment Agency, Investigating Europe′s Secondary Raw Material, 2022, pp.13-15 3 Via Sant'Uguzzone, 29 - 20126 Milano MI Tel.: +39/0266146580 Fax: +39/0266146599 www.assomet.it e-mail: [email protected] Cod. Fiscale: IT 02776350155 Banca Popolare di Sondrio Iban: IT 40 X 05696 01628 000002889X44 In Italy, on average, more than 70% of aluminum packaging is recycled, going well beyond the EU targets of 50% by 2025 and 60% by 2030.
…more than 70% of aluminum packaging is recycled, going well beyond the EU targets of 50% by 2025 and 60% by 2030. In particular, the aluminum can is the most recycled beverage container in the world and today in Italy the recycling rate of beverage cans alone is over 90% of the ones put in the market (compared to the European average rate of 76.1%3). In light of the above, Assomet calls on the Commission to duly value the materials’ properties when defining the policy on packaging and the advanced results already accomplished by the aluminium industry in the reduction of packaging waste and the circular economy. Legal basis The PPWR has also the general objective to ensuring a well-functioning internal market through fully harmonised rules on packaging while tackling negative impacts on environment and health from packaging and packaging waste.
…rules on packaging while tackling negative impacts on environment and health from packaging and packaging waste. Assomet welcomes the opportunity to ensure a uniformed regulatory scenario throughout the EU allowing economic operators to achieve ambitious objectives of sustainability and circularity at European level: promoting the free movement of goods within the single shared market, simplifying operational activities, thus giving medium and long-term visibility to economic operators and allowing them to invest in the development of new sustainable, recyclable and effectively recycled packaging solutions, taking advantage of economies of scale.
…of new sustainable, recyclable and effectively recycled packaging solutions, taking advantage of economies of scale. In order to achieve the harmonization between Member States, it is paramount to make sure that packaging is subject to the same labelling and information, for example in accordance with the alphanumeric coding provided for by Decision 129/97/EC, for which companies have already invested considerable economic resources. Any further national labelling should therefore remain only on a voluntary basis and should not affect the possibility of the free movement of the product (with its packaging) on the domestic market. A robust EU single market is key to preserving the free movement of packaging raw materials and packaged goods.
…market. A robust EU single market is key to preserving the free movement of packaging raw materials and packaged goods. Therefore, Assomet fully supports the choice to maintain an internal market legal basis (Article 114 TFEU) and to be preserved during the legislative process, paying attention not to penalize possible virtuous experiences of each country. At the same time, the provisions that allow Member States to maintain or introduce further specific requirements at national level (for example art. 4.4 and art. 45) should be erased from the text. Should an environmental legal basis be introduced according to Article 192 TFEU (environmental protection) the potential for harmonisation would be weakened by a patchwork of national packaging legislations, to the detriment of consumers, environmental protection and the competitiveness of the European industry.
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