Citeo

…1/26 One-minute read Citeo strongly welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to review requirements for packaging and other measures to prevent packaging waste. Citeo shares the Commission’s findings on the need for clearer and more specific requirements on the composition and the reusable and recoverable, including recyclable, nature of packaging.

…requirements on the composition and the reusable and recoverable, including recyclable, nature of packaging. The review of the Essential Requirements is necessary to ensure they are in line with: ✓ the Plastics Strategy’s commitment to ensure that plastic packaging is reusable or recyclable in an economically viable manner by 2030; ✓ the new Circular Economy Action Plan and the EU Green Deal which broadens this commitment to all packaging and commits to additional measures; ✓ the European Plastics Pact’s ambition to prevent and reduce overpackaging and packaging waste; ✓ the Circular Plastics Alliance which aims to increase the recycled content of new packaging. Citeo fully endorses the EU’s vision for a packaging circular economy, urging for the material to transform from waste to economically, socially and environmentally beneficial resource.

…urging for the material to transform from waste to economically, socially and environmentally beneficial resource. As such, Citeo endeavors for improving the circularity of all type of packaging, while also ensuring its net environmental improvement over the product’s lifecycle. This contribution includes several elements we hope will be considered by the Commission: ✓ First, in order to support waste reduction at source more efficiently, Citeo recommends defining the concept of overpackaging with clear criteria. ✓ Then, a coherent definition of recyclability – but also compostability and biodegradability – enabling producers to produce packaging in a congruent way with the industrial technologies available, as well as with the existing collection and sorting systems in place in the different Member States, is a pre-requisite for improving the recyclable nature of packaging.

…in place in the different Member States, is a pre-requisite for improving the recyclable nature of packaging. Moreover, the development of eco-design, through specific recommendations developed at the packaging level and investments and supports in concrete and innovative solutions, should be supported. Eco-design can also be encouraged by eco-modulation schemes. ✓ Because authorities are taking a much greater interest in reusable packaging, we need to anticipate new framework at the EU level, especially with a clearer definition of reuse and the conditions in which any reusable packaging scheme is compliant with the internal market. ✓ Finally, in order to tackle the limited competitiveness of secondary materials from recycled packaging relative to virgin stock in view of its quality and availability, Citeo recommends several actions to support the promotion of secondary raw materials.

…of its quality and availability, Citeo recommends several actions to support the promotion of secondary raw materials. Citeo’s feedback to the EU Inception Impact Assessment on the initiative “Review of the requirements for packaging and other measures to prevent packaging waste” 6 August 2020 Ref. Ares(2020)7779841 - 19/12/2020 2/26 This contribution also aims to give a more comprehensive view of national actions in France, including the anti-waste law for a circular economy. Do not hesitate to contact us should you have any question on these. REDUCTION AT SOURCE 1.1 A clear and transparent definition of “overpackaging” should be set up The Green Deal identified a need for “new legislation, including targets and measures for tackling over- packaging and waste generation”1.

…a need for “new legislation, including targets and measures for tackling over- packaging and waste generation”1. Moreover, the Plastics Strategy committed the Commission to “look into the issue of over-packaging as part of the future review of the essential requirements for packaging”2. Thus, “overpackaging, the use of ‘excessive’ quantities of packaging for goods, is recognized as a problem”3 at the EU level. The current Essential Requirements require “the packaging volume and weight be limited to the minimum adequate amount to maintain the necessary level of safety, hygiene and acceptance for the packed product and for the consumer”4. While the objective of supporting waste prevention is relatively clear, this requirement is too vague to be operational and enforceable.

…of supporting waste prevention is relatively clear, this requirement is too vague to be operational and enforceable. Indeed, “there is little guidance for producers, fillers and regulators as to what constitutes the ‘minimum adequate amount’ and the evaluation of the Essential Requirements concluded that the inherent subjectivity inhibits compliance and enforcement”5. “The generic term ‘over-packaging’ is used to designate a wide range of packaging systems: envelopes within envelopes, multi-packs, packaging that is (or is perceived to be) over-sized (too big, too thick), packing (wedging elements), labels, notices, etc.”6. In the absence of a general agreement on what does constitute overpackaging, Citeo recommends setting a definition at the EU level to ensure that there is no ambiguity for producers, consumers and enforcement bodies.

…a definition at the EU level to ensure that there is no ambiguity for producers, consumers and enforcement bodies. To assess whether there is overpackaging, Citeo recommends considering the elements of the packaging system from the point of view of the functions they perform or help perform with regard to the product and/or users. Indeed, “packaging is first a provider of a variety of functions with regard to a product and its users before being an object or a material”7. The functions of packaging should be analyzed throughout the cycle of life of the packaged product and can include the protection and preserving of the product it contains, grouping products together for transport and storage, identifying the product and protecting the consumer, being a vehicle for information and contributing to the user- friendliness of the product.

…and protecting the consumer, being a vehicle for information and contributing to the user- friendliness of the product. Citeo recommends to clearly define the functions that are considered as essential and therefore justify the presence of packaging elements, excluding overpackaging. Particularly, reducing packaging at source should not result in underpackaging and the related food waste. Indeed, it is important to consider, as recalled in the Farm to Fork Strategy, that “food packaging plays a key role in the sustainability of food systems”8. If packaging needs to meet functionalities in order to avoid product or food losses, these functionalities should be preserved. Thus, Citeo recommends that the impact assessment considers food waste/product waste arising from packaging reduction but also from transition to reuse models (e.g. implication on food waste of bulk sales).

…from packaging reduction but also from transition to reuse models (e.g. implication on food waste of bulk sales). For instance, Article 779 of the French anti-waste law for a circular economy requires that, by 2022, any retail business selling unprocessed fresh fruits and vegetables should sell them without packaging made 1 Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions, The European Green Deal, COM(2019) 640 final, p.8. 2 A European Strategy for Plastics in a Circular Economy, p.13. 3 Eunomia, “Effectiveness of the Essential Requirements for Packaging and Packaging Waste and proposals for reinforcement”, February 2020, p.23. 4 European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste, Annex II (1).

European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste, Annex II (1). 5 Eunomia, “Effectiveness of the Essential Requirements for Packaging and Packaging Waste and proposals for reinforcement”, February 2020, p.82. 6 CNE, Position paper “Definition and assessment of overpackaging”, 26 June 2009, p.1. 7 CNE, Position paper “Definition and assessment of overpackaging”, 26 June 2009, p.2. 8 Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions, A Farm to Fork Strategy for a fair, healthy and environmentally-friendly food system, COM(2020) 381 final, p.12. 9 https://www.ecologique-solidaire.gouv.fr/sites/default/files/en_DP%20PJL.pdf 3/26 entirely or partly of plastic10.

…9 https://www.ecologique-solidaire.gouv.fr/sites/default/files/en_DP%20PJL.pdf 3/26 entirely or partly of plastic10. However, this obligation does not apply to fruits and vegetables packaged in batches of 1.5 kilograms or more as well as to fruits and vegetables presenting a risk of deterioration during their sale in bulk. Thus, the French law provides for exceptions taking into account the essential functionalities of the packaging for certain products for which bulk sales would result in increased food waste. Regarding the requirements for producers to measure and report ratios of packaging weight, volume and planar area, Citeo underlines the necessity to take into consideration common criteria for all packaging (of all materials and for all products) and the impact of potential switch to plastics packaging.

119 → 12

originalus šaltinis (PDF) ↗

…1/26 One-minute read Citeo strongly welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to review requirements for packaging and other measures to prevent packaging waste. Citeo shares the Commission’s findings on the need for clearer and more specific requirements on the composition and the reusable and recoverable, including recyclable, nature of packaging.

…requirements on the composition and the reusable and recoverable, including recyclable, nature of packaging. The review of the Essential Requirements is necessary to ensure they are in line with: ✓ the Plastics Strategy’s commitment to ensure that plastic packaging is reusable or recyclable in an economically viable manner by 2030; ✓ the new Circular Economy Action Plan and the EU Green Deal which broadens this commitment to all packaging and commits to additional measures; ✓ the European Plastics Pact’s ambition to prevent and reduce overpackaging and packaging waste; ✓ the Circular Plastics Alliance which aims to increase the recycled content of new packaging. Citeo fully endorses the EU’s vision for a packaging circular economy, urging for the material to transform from waste to economically, socially and environmentally beneficial resource.

…urging for the material to transform from waste to economically, socially and environmentally beneficial resource. As such, Citeo endeavors for improving the circularity of all type of packaging, while also ensuring its net environmental improvement over the product’s lifecycle. This contribution includes several elements we hope will be considered by the Commission: ✓ First, in order to support waste reduction at source more efficiently, Citeo recommends defining the concept of overpackaging with clear criteria. ✓ Then, a coherent definition of recyclability – but also compostability and biodegradability – enabling producers to produce packaging in a congruent way with the industrial technologies available, as well as with the existing collection and sorting systems in place in the different Member States, is a pre-requisite for improving the recyclable nature of packaging.

…in place in the different Member States, is a pre-requisite for improving the recyclable nature of packaging. Moreover, the development of eco-design, through specific recommendations developed at the packaging level and investments and supports in concrete and innovative solutions, should be supported. Eco-design can also be encouraged by eco-modulation schemes. ✓ Because authorities are taking a much greater interest in reusable packaging, we need to anticipate new framework at the EU level, especially with a clearer definition of reuse and the conditions in which any reusable packaging scheme is compliant with the internal market. ✓ Finally, in order to tackle the limited competitiveness of secondary materials from recycled packaging relative to virgin stock in view of its quality and availability, Citeo recommends several actions to support the promotion of secondary raw materials.

…of its quality and availability, Citeo recommends several actions to support the promotion of secondary raw materials. Citeo’s feedback to the EU Inception Impact Assessment on the initiative “Review of the requirements for packaging and other measures to prevent packaging waste” 6 August 2020 Ref. Ares(2020)4141544 - 06/08/2020 2/26 This contribution also aims to give a more comprehensive view of national actions in France, including the anti-waste law for a circular economy. Do not hesitate to contact us should you have any question on these. REDUCTION AT SOURCE 1.1 A clear and transparent definition of “overpackaging” should be set up The Green Deal identified a need for “new legislation, including targets and measures for tackling over- packaging and waste generation”1.

…a need for “new legislation, including targets and measures for tackling over- packaging and waste generation”1. Moreover, the Plastics Strategy committed the Commission to “look into the issue of over-packaging as part of the future review of the essential requirements for packaging”2. Thus, “overpackaging, the use of ‘excessive’ quantities of packaging for goods, is recognized as a problem”3 at the EU level. The current Essential Requirements require “the packaging volume and weight be limited to the minimum adequate amount to maintain the necessary level of safety, hygiene and acceptance for the packed product and for the consumer”4. While the objective of supporting waste prevention is relatively clear, this requirement is too vague to be operational and enforceable.

…of supporting waste prevention is relatively clear, this requirement is too vague to be operational and enforceable. Indeed, “there is little guidance for producers, fillers and regulators as to what constitutes the ‘minimum adequate amount’ and the evaluation of the Essential Requirements concluded that the inherent subjectivity inhibits compliance and enforcement”5. “The generic term ‘over-packaging’ is used to designate a wide range of packaging systems: envelopes within envelopes, multi-packs, packaging that is (or is perceived to be) over-sized (too big, too thick), packing (wedging elements), labels, notices, etc.”6. In the absence of a general agreement on what does constitute overpackaging, Citeo recommends setting a definition at the EU level to ensure that there is no ambiguity for producers, consumers and enforcement bodies.

…a definition at the EU level to ensure that there is no ambiguity for producers, consumers and enforcement bodies. To assess whether there is overpackaging, Citeo recommends considering the elements of the packaging system from the point of view of the functions they perform or help perform with regard to the product and/or users. Indeed, “packaging is first a provider of a variety of functions with regard to a product and its users before being an object or a material”7. The functions of packaging should be analyzed throughout the cycle of life of the packaged product and can include the protection and preserving of the product it contains, grouping products together for transport and storage, identifying the product and protecting the consumer, being a vehicle for information and contributing to the user- friendliness of the product.

…and protecting the consumer, being a vehicle for information and contributing to the user- friendliness of the product. Citeo recommends to clearly define the functions that are considered as essential and therefore justify the presence of packaging elements, excluding overpackaging. Particularly, reducing packaging at source should not result in underpackaging and the related food waste. Indeed, it is important to consider, as recalled in the Farm to Fork Strategy, that “food packaging plays a key role in the sustainability of food systems”8. If packaging needs to meet functionalities in order to avoid product or food losses, these functionalities should be preserved. Thus, Citeo recommends that the impact assessment considers food waste/product waste arising from packaging reduction but also from transition to reuse models (e.g. implication on food waste of bulk sales).

…from packaging reduction but also from transition to reuse models (e.g. implication on food waste of bulk sales). For instance, Article 779 of the French anti-waste law for a circular economy requires that, by 2022, any retail business selling unprocessed fresh fruits and vegetables should sell them without packaging made 1 Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions, The European Green Deal, COM(2019) 640 final, p.8. 2 A European Strategy for Plastics in a Circular Economy, p.13. 3 Eunomia, “Effectiveness of the Essential Requirements for Packaging and Packaging Waste and proposals for reinforcement”, February 2020, p.23. 4 European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste, Annex II (1).

European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste, Annex II (1). 5 Eunomia, “Effectiveness of the Essential Requirements for Packaging and Packaging Waste and proposals for reinforcement”, February 2020, p.82. 6 CNE, Position paper “Definition and assessment of overpackaging”, 26 June 2009, p.1. 7 CNE, Position paper “Definition and assessment of overpackaging”, 26 June 2009, p.2. 8 Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions, A Farm to Fork Strategy for a fair, healthy and environmentally-friendly food system, COM(2020) 381 final, p.12. 9 https://www.ecologique-solidaire.gouv.fr/sites/default/files/en_DP%20PJL.pdf 3/26 entirely or partly of plastic10.

…9 https://www.ecologique-solidaire.gouv.fr/sites/default/files/en_DP%20PJL.pdf 3/26 entirely or partly of plastic10. However, this obligation does not apply to fruits and vegetables packaged in batches of 1.5 kilograms or more as well as to fruits and vegetables presenting a risk of deterioration during their sale in bulk. Thus, the French law provides for exceptions taking into account the essential functionalities of the packaging for certain products for which bulk sales would result in increased food waste. Regarding the requirements for producers to measure and report ratios of packaging weight, volume and planar area, Citeo underlines the necessity to take into consideration common criteria for all packaging (of all materials and for all products) and the impact of potential switch to plastics packaging.

119 → 12

originalus šaltinis (PDF) ↗