European Power Tool Association

…21 April 2023 European Power Tool Association (EPTA) statement on the European Commission’s proposal for a Regulation on packaging and packaging waste EPTA, the European Power Tool Association, represents 25 European power tool manufacturers and 90% of all corded and cordless power tools sold in Europe. Power tools are used by professionals, skilled tradesmen and DIY consumers. EPTA members are committed to the highest possible standards of quality and safety of their tools. Innovation and advanced technologies as well as customer-friendly applications are key to our companies’ economic growth, competitiveness and the creation of jobs. More information can be found at http://www.epta.eu/.

…economic growth, competitiveness and the creation of jobs. More information can be found at http://www.epta.eu/. As an industry that is already heavily investing into innovative, high-quality and sustainable packaging solutions, we welcome the European Commission’s ambitious push for a more circular and sustainable European economy. In this context we also appreciate the approach to harmonise European rules for packaging using a Regulation with a single market legal basis as an instrument. The proposal for a Packaging and Packaging Waste Regulation (PPWR) can avoid fragmentated national efforts, hindering the free movement of goods in the European single market, and align the different approaches of countries in a multi-speed Europe. This is especially important as national labelling schemes and similar requirements (e.g.

…in a multi-speed Europe. This is especially important as national labelling schemes and similar requirements (e.g. on recyclability, re-use, recycled content) can lead to an increased burden on economic operators and negative effects on the environment. To avoid such downsides, the best solution from our point of view is a harmonised European label, which does not use colour-coded or language-dependent signage. Different methods of application should be usable, such as printing, engraving, or casting and most importantly a QR code. This QR code should be compatible with similar digital data carriers required in other European legislation to avoid a multitude of QR codes on the packaging or product. In this regard, a single QR code for both, product and packaging should be able to be used but should not be mandatory.

In this regard, a single QR code for both, product and packaging should be able to be used but should not be mandatory. A uniform European label for packaging would also have the added value of being understandable to all European citizens everywhere in the Union and stop the confusing effects of a multitude of labels on the same unit of packaging, facilitating its positive effects on for example sorting. We believe fragmented national labelling requirements lead to additional efforts such as more complex logistics, causing higher energy use and CO2-Emmissions. Additionally, a sufficient transitional period for a harmonised label should be given for industry to adapt.

Additionally, a sufficient transitional period for a harmonised label should be given for industry to adapt. Lastly, we also want to stress that as an industry, the power tools sector is already now mainly using sturdy boxes, kit boxes and containers, that serve to contain, transport and protect the power tools during their entire lifetime, and which serve as an integral part of our products to our customers. These boxes, kit boxes and containers are used on a daily basis to transport the wide array of power tools necessary for a given construction site to the site in vans and other vehicles and are then again used to distribute the tools on-site, to make sure that the required accessories such as different drills or sawblades, batteries and chargers are always accessible.

…sure that the required accessories such as different drills or sawblades, batteries and chargers are always accessible. In this regard, we call on the legislators to include power tool boxes, kit boxes and containers as an indicative example of non-packaging in Annex I, in the same way as boxes for traditional mechanical tools. We as EPTA want to thank the European legislators for this chance to be in dialogue and are looking forward to further involvement as stakeholders in the PPWR legislative process. More details regarding our main concerns can be found in the attached joint position paper. Ref.

…legislative process. More details regarding our main concerns can be found in the attached joint position paper. Ref. Ares(2023)2886156 - 24/04/2023 Electro and Digital Industry Association Statement on the European Commission’s proposal for a Packaging and Packaging Waste Regulation March 3, 2023 General remarks We welcome the possibility to comment the European Commission’s proposal for a new Packaging and Packaging Waste Regulation (PPWR). ZVEI e.V. - Germany’s Electric and Digital Industry association and EPTA – the European Power Tool Association represent many companies that are concerned by the draft proposal. Packaging is a fundamental part of our industry since it protects goods and helps to convey information in the b2c and b2b sector.

…a fundamental part of our industry since it protects goods and helps to convey information in the b2c and b2b sector. Over the last years, the approach to packaging itself has fundamentally changed: It is now not only seen as a way of protecting goods, but also as a relevant aspect when it comes to the protection of our environment. The European Union strives to achieve a circular economy; consequently, the whole world of consumption needs to adapt. It is no longer only about the product itself, but also about the materials it comes with. The electrical and digital industry has already been working on improving products’ impact on the environment for years, driven by ecodesign requirements and energy labelling. Now, the European Commission plans to review another aspect, packaging.

…by ecodesign requirements and energy labelling. Now, the European Commission plans to review another aspect, packaging. After carefully having analysed the draft and its annexes, we highlight certain points in the following: Our main recommendations and concerns are: 1) We support the change from directive to regulation. 2) We do not support re-use requirements for transport packaging and for the special case of household appliances without a proper assessment. Before setting up re-use requirements, an impact assessment on feasibility and concrete transposition needs to be conducted. 3) The foreseen recycling targets are too ambitious. Recycling targets must be adapted to the available material resources. In addition, conflicts of objectives with other goals, e.g., the reduction of material used, must be resolved.

In addition, conflicts of objectives with other goals, e.g., the reduction of material used, must be resolved. 4) We support the planned introduction of a harmonised label. The need for harmonisation of labelling on European level is high. Member states should not have the possibility to set up individual, national labels for their EPR systems or information requirements, since this permission contradicts the harmonisation efforts. Additionally, it should be reviewed if well-known, already used systems can be used instead of new labels. In any case, producers should be able to convey the necessary information independent of the method used like printing, engraving, embossing etc., which is why colour-coding is not feasible. Digital methods of information should be preferred.

…embossing etc., which is why colour-coding is not feasible. Digital methods of information should be preferred. 5) A declaration of conformity for packaging creates an unnecessary bureaucratic burden. Especially when focusing on small and medium enterprises, any non-expedient bureaucratic burden must be avoided. A storage time of ten years for the technical documentation of packaging material and the creation of a DoC itself is not appropriate. 6) Setting up design for recycling criteria, not on material-basis but based on efficient sorting, collection, and recycling, is only efficient if the collection and recycling structures in all member states are aligned with each other quickly. Otherwise, this requirement will distort the internal market.

…in all member states are aligned with each other quickly. Otherwise, this requirement will distort the internal market. 7) The aim of packaging minimisation needs further clarification of wording and exceptions. The special shape of some of our products makes it barely possible to comply with these specifications. In general, the environmental impact over the entire lifecycle as such should be the basis for the new requirements. Under some conditions neither re-use nor the use of a certain percentage of recycled material is beneficial for the environment. This should be properly considered. We highly encourage the European legislators to prioritize goals. 2 Detailed comments 1. Change from Directive to Regulation and Protection of the Free movement of goods The European Commission envisages to change the political framework of the packaging issue.

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