European Council of the Paint, Printing Ink and Artists' Colours Industry

…4 August 2020 CEPE contribution to EU consultation Review of the requirements for packaging and other measures to prevent packaging waste CEPE, in principal, supports any meaningful initiative aimed at preventing packaging waste. Therefore, we welcome the possibility to comment on the inception impact assessment on the review of requirements for packaging and other measures to prevent packaging waste in an economically viable manner by 2030. While striving for improvements, the achieved packaging functionalities of which many contribute to resource efficiency and sustainability, must be cautiously considered and properly safeguarded when drafting this legislative initiative. Packaging is a value- and function-preserving attribute for almost every product. It protects a product or its content and increases its shelf-life. In the case of paints, it serves as container.

It protects a product or its content and increases its shelf-life. In the case of paints, it serves as container. Packaging must also be printed in order to provide information on the packed product. The following advantageous functionalities derive from packaging: Primary function: • Protection of products during transport (primary and secondary packaging) • Preservation against outside in contamination (dirt, bacteria, etc.) Both contribute to increased sustainability and resource efficiency, as once a good is damaged or spoiled, all resources along its supply chain are wasted as well.

…and resource efficiency, as once a good is damaged or spoiled, all resources along its supply chain are wasted as well. With respect to the above it is important to realise that e-commerce in particular increases the requirements on transport protection leading to additional (often secondary) packaging as required by transport regulation such as European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR). Additional functions: • Packaging provides valuable space for communication (e.g. ingredients, best- before-information, health & safety statements but also marketing information) We understand that packaging waste accounts for a large proportion of all consumer waste. Companies in the coatings and printing ink industry are continuously striving to minimise the environmental impact of their products and the packaging they revert to.

…are continuously striving to minimise the environmental impact of their products and the packaging they revert to. For example, EuPIA actively works towards higher recyclability by collaborating and engaging with all stakeholders relevant to packaging recycling, working on specific areas where the ink industry can contribute to the discussion, both for post-industrial and post-consumer printed plastic waste and for packaging and graphic papers. Ref. Ares(2021)139330 - 07/01/2021 In addition, many paint manufacturers are reducing their secondary packaging, are light- weighting packaging and are looking for opportunities to use recycled plastic or other ways to re-use packaging.

…light- weighting packaging and are looking for opportunities to use recycled plastic or other ways to re-use packaging. The upcoming measures stemming from the results of the inception impact assessment should cater for: • An extension of the whole life cycle of the product Packaging has a function and should not be assessed on its own as this has the inherent risk that the measures could have a negative impact on the shelf-life, damageability of and the whole lifetime of the packed product. • Innovation is key to product/packaging development and sustainability Therefore, new measures should not jeopardise the efforts of industry to develop new, more innovative products.

…new measures should not jeopardise the efforts of industry to develop new, more innovative products. Considering that the European Commission (EC) has issued an ambitious Circular Economy Action Plan setting binding targets for 2030 for the recycling of all packaging waste (70%), as well as for plastic packaging being recyclable (55%) – it is now time to consider ways forward. For an optimum solution, issues of circularity (carbon content, emissions, environmental footprint, now recycled materials) should not be looked at in isolation, but with a holistic view, linking European and national strategies.

…materials) should not be looked at in isolation, but with a holistic view, linking European and national strategies. In preparation of the legislative measure scheduled for Q2 2021, the EC has commissioned the study ‘Effectiveness of the Essential Requirements for Packaging and Packaging Waste and Proposals for Reinforcement’ which reviews the latest packaging trends, the essential requirements of packaging and suggest options with different measures suitable to improve the design for reuse and promoting high quality recycling, as well as strengthening enforcement. We are pleased to offer our views regarding some of the investigated measures: • Regarding hazardous substances in packaging, the study considers the following measures: a) rely on REACH, Food Contact Material regulation etc.

…in packaging, the study considers the following measures: a) rely on REACH, Food Contact Material regulation etc. to adequately address the use of hazardous substances in packaging; and b) to include requirements to phase out the use of SVHC in packaging through reference to Annex XIV of REACH. Of the both options, we clearly favour option a, as it relies on established procedures which are well known among the supply chain. Nevertheless, before any policy decisions, we suggest to further reflect on industrial processes aimed at protecting human health or the environment.

…decisions, we suggest to further reflect on industrial processes aimed at protecting human health or the environment. • Regarding the recyclable nature of packaging, the study notes that the essential requirements already contain a condition (“A certain percentage by weight must be recyclable if the packaging is intended for recycling”) and states that this requirement “should be replaced by a requirement for all packaging placed on the market to be recyclable by 2030, not just a certain percentage by weight.” Furthermore, the study investigates various measures relating to how ‘recyclable’ could be defined. In this matter we support the approach to define ‘recyclable by qualitative statements only’, as it sets basic principles which support the internal market, ensures material neutrality and will be flexible towards innovation.

…principles which support the internal market, ensures material neutrality and will be flexible towards innovation. We do however reject the approach to use design for recycling criteria to set a list of recyclable or non-recyclable formats, e.g. positive lists of criteria that define what types of packaging can be allowed on the market and negative lists of incompatible or disruptive components that hinder recycling processes. Such lists risk to be too prescriptive in the design rules, thereby are known to stifle innovation and risk to not consider packaging functionalities. In conclusion, the achieved packaging functionalities of which many contribute to resource efficiency and sustainability, e.g.

…the achieved packaging functionalities of which many contribute to resource efficiency and sustainability, e.g. protection during transport, protection against external contamination, mechanical requirements for palletization and use in the shakers and mixing machines, and product information printed on the packaging, must be cautiously considered and properly safeguarded when drafting this legislative initiative. About CEPE: The European Council of the Paint, Printing Ink and Artists' Colours Industry (CEPE) represents 85% of the industry in Europe with a worth of approximately 17 billion Euro and 100.000 direct employees. Most of our members are small and medium size companies.

originalus šaltinis (PDF) ↗

…4 August 2020 CEPE contribution to EU consultation Review of the requirements for packaging and other measures to prevent packaging waste CEPE, in principal, supports any meaningful initiative aimed at preventing packaging waste. Therefore, we welcome the possibility to comment on the inception impact assessment on the review of requirements for packaging and other measures to prevent packaging waste in an economically viable manner by 2030. While striving for improvements, the achieved packaging functionalities of which many contribute to resource efficiency and sustainability, must be cautiously considered and properly safeguarded when drafting this legislative initiative. Packaging is a value- and function-preserving attribute for almost every product. It protects a product or its content and increases its shelf-life. In the case of paints, it serves as container.

It protects a product or its content and increases its shelf-life. In the case of paints, it serves as container. Packaging must also be printed in order to provide information on the packed product. The following advantageous functionalities derive from packaging: Primary function: • Protection of products during transport (primary and secondary packaging) • Preservation against outside in contamination (dirt, bacteria, etc.) Both contribute to increased sustainability and resource efficiency, as once a good is damaged or spoiled, all resources along its supply chain are wasted as well.

…and resource efficiency, as once a good is damaged or spoiled, all resources along its supply chain are wasted as well. With respect to the above it is important to realise that e-commerce in particular increases the requirements on transport protection leading to additional (often secondary) packaging as required by transport regulation such as European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR). Additional functions: • Packaging provides valuable space for communication (e.g. ingredients, best- before-information, health & safety statements but also marketing information) We understand that packaging waste accounts for a large proportion of all consumer waste. Companies in the coatings and printing ink industry are continuously striving to minimise the environmental impact of their products and the packaging they revert to.

…are continuously striving to minimise the environmental impact of their products and the packaging they revert to. For example, EuPIA actively works towards higher recyclability by collaborating and engaging with all stakeholders relevant to packaging recycling, working on specific areas where the ink industry can contribute to the discussion, both for post-industrial and post-consumer printed plastic waste and for packaging and graphic papers. Ref. Ares(2020)4147127 - 06/08/2020 In addition, many paint manufacturers are reducing their secondary packaging, are light- weighting packaging and are looking for opportunities to use recycled plastic or other ways to re-use packaging.

…light- weighting packaging and are looking for opportunities to use recycled plastic or other ways to re-use packaging. The upcoming measures stemming from the results of the inception impact assessment should cater for: • An extension of the whole life cycle of the product Packaging has a function and should not be assessed on its own as this has the inherent risk that the measures could have a negative impact on the shelf-life, damageability of and the whole lifetime of the packed product. • Innovation is key to product/packaging development and sustainability Therefore, new measures should not jeopardise the efforts of industry to develop new, more innovative products.

…new measures should not jeopardise the efforts of industry to develop new, more innovative products. Considering that the European Commission (EC) has issued an ambitious Circular Economy Action Plan setting binding targets for 2030 for the recycling of all packaging waste (70%), as well as for plastic packaging being recyclable (55%) – it is now time to consider ways forward. For an optimum solution, issues of circularity (carbon content, emissions, environmental footprint, now recycled materials) should not be looked at in isolation, but with a holistic view, linking European and national strategies.

…materials) should not be looked at in isolation, but with a holistic view, linking European and national strategies. In preparation of the legislative measure scheduled for Q2 2021, the EC has commissioned the study ‘Effectiveness of the Essential Requirements for Packaging and Packaging Waste and Proposals for Reinforcement’ which reviews the latest packaging trends, the essential requirements of packaging and suggest options with different measures suitable to improve the design for reuse and promoting high quality recycling, as well as strengthening enforcement. We are pleased to offer our views regarding some of the investigated measures: • Regarding hazardous substances in packaging, the study considers the following measures: a) rely on REACH, Food Contact Material regulation etc.

…in packaging, the study considers the following measures: a) rely on REACH, Food Contact Material regulation etc. to adequately address the use of hazardous substances in packaging; and b) to include requirements to phase out the use of SVHC in packaging through reference to Annex XIV of REACH. Of the both options, we clearly favour option a, as it relies on established procedures which are well known among the supply chain. Nevertheless, before any policy decisions, we suggest to further reflect on industrial processes aimed at protecting human health or the environment.

…decisions, we suggest to further reflect on industrial processes aimed at protecting human health or the environment. • Regarding the recyclable nature of packaging, the study notes that the essential requirements already contain a condition (“A certain percentage by weight must be recyclable if the packaging is intended for recycling”) and states that this requirement “should be replaced by a requirement for all packaging placed on the market to be recyclable by 2030, not just a certain percentage by weight.” Furthermore, the study investigates various measures relating to how ‘recyclable’ could be defined. In this matter we support the approach to define ‘recyclable by qualitative statements only’, as it sets basic principles which support the internal market, ensures material neutrality and will be flexible towards innovation.

…principles which support the internal market, ensures material neutrality and will be flexible towards innovation. We do however reject the approach to use design for recycling criteria to set a list of recyclable or non-recyclable formats, e.g. positive lists of criteria that define what types of packaging can be allowed on the market and negative lists of incompatible or disruptive components that hinder recycling processes. Such lists risk to be too prescriptive in the design rules, thereby are known to stifle innovation and risk to not consider packaging functionalities. In conclusion, the achieved packaging functionalities of which many contribute to resource efficiency and sustainability, e.g.

…the achieved packaging functionalities of which many contribute to resource efficiency and sustainability, e.g. protection during transport, protection against external contamination, mechanical requirements for palletization and use in the shakers and mixing machines, and product information printed on the packaging, must be cautiously considered and properly safeguarded when drafting this legislative initiative. About CEPE: The European Council of the Paint, Printing Ink and Artists' Colours Industry (CEPE) represents 85% of the industry in Europe with a worth of approximately 17 billion Euro and 100.000 direct employees. Most of our members are small and medium size companies.

originalus šaltinis (PDF) ↗