The European Consumer Voice in Standardisation

July 2020 The annex below regards ANEC suggestions on how to tackle excessive packaging As we mention in the feedback we provide, it is key to promote the establishment of clear-cut and enforceable rules for the prevention of excessive packaging (in certain areas) and to define measurable quantitative criteria for this. This should be based on either a maximum ratio between the volume of the packaging and the volume of the packed product or, preferably, a maximum ratio between the surface of packaging and the volume of the packed product. A member of ANEC has commissioned a study many years ago which established a criterion for an acceptable surface/volume ratio and demonstrated the applicability for various product groups. Annex 2 in the brochure below explains and illustrates the quantitative prevention criterion.

…various product groups. Annex 2 in the brochure below explains and illustrates the quantitative prevention criterion. The last page annexed here also shows as an example the Austrian AF-standard bottle for soft drinks. Further examples exist at the national level. Ref. Ares(2020)4052008 - 31/07/2020 Packaging Waste March 2005 Packaging Waste page 2 I ntroduction (a) The prevention of waste in general and the prevention of packaging waste in particular has been a political goal for many years. As early as 1975 the European Directive on Waste (75/442/EEC) declared the prevention of waste as a first priority of waste management.

…the European Directive on Waste (75/442/EEC) declared the prevention of waste as a first priority of waste management. The European Directive on Packaging and Packaging waste (94/62/EC) adopted in 1994 stipulated: "Packaging shall be so manufactured that 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.” However, the Packaging Directive does not establish any detailed rules or guidance for the implementation of this provision. Hence, it is not surprising that it had little effect in practice.

…guidance for the implementation of this provision. Hence, it is not surprising that it had little effect in practice. In 1996 the European Commission mandated the European standardisation organisation CEN to elaborate various standards which were intended to complement the Packaging Directive and to provide the missing detailed specifications for prevention, reuse, recycling, composting and energy recovery. Due to a number of shortcomings these standards were objected by some Member States and the Commission judged that only the standard dealing with composting was in compliance with the Packaging Directive and the mandate. Another mandate was given in 2002.

…with composting was in compliance with the Packaging Directive and the mandate. Another mandate was given in 2002. The revised standards were adopted in 2004 and were subject to harsh criticism from consumer and environmental organisations (ANEC-ECOS position paper on revised packaging standards prepared under the second standardisation mandate M317, January 2005) because the new standards were not significantly different from the old ones. The standard dealing with prevention (EN13428: Requirements specific to manufacturing and composition – prevention by source reduction) offers no measurable criteria nor incentive to companies to reduce excessive packaging. In addition, the standard allows for the use of substances that are harmful for the environment.

…excessive packaging. In addition, the standard allows for the use of substances that are harmful for the environment. A description of the major elements of this standard and a critical review of its contents can be found in Annex 1 of this documentation. The Consumer Council at the Austrian Standards Institute commissioned a study to review the prevention standard and to develop an alternative approach including a clear-cut quantitative criterion. In fact, this study built upon the results of an earlier study financed by the Austrian Ministry of Environment which was carried out in 1999 (CEN Standards Related to Packaging and Packaging Waste, Technical Office Hauer). The method suggested in the first study was further refined and tested in practice by evaluating about 70 different packages.

…suggested in the first study was further refined and tested in practice by evaluating about 70 different packages. The study (Part 1: Quantitative criteria for the prevention of packaging – an alternative to the European standard EN 13428, Part 2: Collection of examples, Technical Office Hauer) can be obtained from the Consumer Council. This brochure contains a selection of the packages contained in the study report. It focuses on typical cases of waste packages and gives possible packaging alternatives which would be in conformity to the proposed limits. The quantitative criterion is based on a packaging surface to product volume ratio. Special provisions exist for certain types of products and packages falling below a certain minimum area are exempted. A summary of the approach is given in Annex 2.

…products and packages falling below a certain minimum area are exempted. A summary of the approach is given in Annex 2. The aim of this brochure is to promote the establishment of clear-cut and enforceable rules for the prevention of superfluous packaging. Dr.

…is to promote the establishment of clear-cut and enforceable rules for the prevention of superfluous packaging. Dr. Franz Fiala Consumer Council Austrian Standards Institute tel: 0043 1 21300 709 fax: 0043 1 21300 328 e-mail: [email protected] web: http://www.verbraucherrat.at Packaging Waste page 3 Content Building Materials 4 Cosm etics 7 Cleaning 10 Electronics 11 Food 13 Softw are 16 Toys 19 Various 24 Annex 1 26 Annex 2 28 I ntroduction 2 Existing packaging Recommended alternative packaging Packaging Waste page 4 Building Materials Product: Com pany: LUX-Tools Drive-in nut M4 , 2 0 pieces Possible Packaging (a) A reduction of the cuboid to 5 cm x 5 cm x 2 cm and a reduction of the two-dimensional surface to 8 cm x 7 cm would result in a total surface of about 120 cm² and would be in accordance with the proposed exception rule for small packages.

…in a total surface of about 120 cm² and would be in accordance with the proposed exception rule for small packages. Description Dimensions: h = 11,5 cm , w = 7,5 cm , d = 3 cm (cuboid: H = 8,5 cm, w = 6 cm, d = 3 cm) 3 Product volume: 20,6 cm 2 Packaging surface: 220,7 cm 3 Packaging volume: 153 cm 20 pieces of nuts loosely poured Existing packaging Recommended alternative packaging Packaging Waste page 5 Building Materials Product: Com pany: Cross-over covers for skirting boards, 2 pieces Parador, Living system s Possible Packaging (a) A reduction of the cardboard cuboid packaging to 7 cm x 5 cm x 3 cm would be in accordance with the proposed limit.

…reduction of the cardboard cuboid packaging to 7 cm x 5 cm x 3 cm would be in accordance with the proposed limit. Description Dimensions: h = 8 cm , w = 12 cm , d = 3,5 cm 3 Product volume: 55 cm 2 Packaging surface: 332 cm 3 Packaging volume: 336 cm 2 pieces of covers loosely poured Existing packaging Recommended alternative packaging Packaging Waste page 6 Building Materials Product: Com pany: Parador, Living system s Gypsum plaster screw s 3 ,9 x 2 5 m m , 2 0 0 pieces Possible Packaging (a) A reduction of the cardboard box height from 13 cm to 9 cm would be in accordance with the proposed limit.

…reduction of the cardboard box height from 13 cm to 9 cm would be in accordance with the proposed limit. Description Dimensions: h = 15,5 cm , w = 8 cm , d = 4,5 cm (cuboid: h = 13 cm, w = 8 cm, d = 4,5 cm) 3 Product volume: 180 cm 2 Packaging surface: 413,5 cm 3 Packaging volume: 468 cm 200 pieces of screws loosely poured Existing packaging Recommended alternative packaging Packaging Waste page 7 Cosm etics Product: Day and night cream Com pany: Juvena of Sw itzerland Possible Packaging (a) An elimination of the large gift cardboard box together with a slight adjustment at the area/volume ratio of the cream containers would be in accordance with the proposed limit.

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ANEC position paper on revised EU Rules for packaging and packaging waste POSITION PAPER Contact: Michela Vuerich – [email protected] The European Consumer Voice in Standardisation aisbl Rue d’Arlon 80 – 4th Floor - B-1040 Brussels, Belgium T: +32-2-7432470 / [email protected] / www.anec.eu Ref: ANEC-SUST-2023-G-005 ANEC is supported financially by the European Union & EFTA 16/03/2023 Raising standards for consumers Ref. Ares(2023)1935497 - 17/03/2023 SUMMARY ANEC welcomes the proposed regulation on packaging and packaging waste, as it will provide consumers with more convenient options for reducing their packaging waste. ANEC agrees with the choice of a regulation as the legal instrument as it will ensure equal implementation across Member States, unlike a directive.

…a regulation as the legal instrument as it will ensure equal implementation across Member States, unlike a directive. We welcome that it places emphasis on prevention and reuse, information requirements, mandatory deposit return systems, and the 90% objective for large household appliances to be delivered in reusable packaging by 2030. Nevertheless, we see several areas for improvement: Prevention targets for (unnecessary) packaging must be more ambitious if we are to avoid a forecast increase in waste. The lack of restrictions on harmful substances is a serious concern, given these are a precondition for the reuse and recycling targets. The initiative focuses heavily on recyclable packaging and recycled content in plastic packaging.

…recycling targets. The initiative focuses heavily on recyclable packaging and recycled content in plastic packaging. While safe recycling can play a role in achieving the circular economy and save resources, ANEC believes that the proposed regulation should be first and foremost more ambitious in terms of preventing (especially avoidable) packaging waste, and restrictions on harmful substances in packaging. Only then can the targets for reuse and recycling be truly beneficial for the environment and consumers. It is crucial for the next steps of the revision process to follow more firmly the waste hierarchy, and assess the impact on health and environment of the measures taken. High ambitions for recycling require measures/requirements for the minimisation or phase out of hazardous substances in packaging materials, and possibly also objectives for improvement of the quality (e.g.

…out of hazardous substances in packaging materials, and possibly also objectives for improvement of the quality (e.g. decrease or absence of hazardous substances in packaging materials). With these ambitions missing, the quantitative objectives for high-recycling rate risks an incentive to achieve low-quality recycling and an increase in contaminated recycled materials, resulting in increased exposure of humans and the environment. ANEC believes prevention of packaging waste needs to remain the primary goal of legislation. Reuse systems should be prioritised over single-use packaging, where environmental impacts in the life-cycle are lower than for the single use packaging, with standardised formats and hygiene requirements to ensure consumer trust in safety.

…for the single use packaging, with standardised formats and hygiene requirements to ensure consumer trust in safety. Finally, recycling should play a role only if it is sensible for the environment and human health, and should not be the sole or preferred way to attain circularity. CONTENTS Introduction ............................................................................. 4 1 | How the PPWR proposal addresses our recommendations so far . 5 2 | Prevention of packaging waste ............................................... 6 2.1 Urgent need to include restrictions for hazardous chemicals ...... 7 3 | Reuse ................................................................................. 7 3.1 Consumer trust in reuse systems ........................................... 8 4 | Recyclability, recycling and recycled content ..........................

…8 4 | Recyclability, recycling and recycled content .......................... 11 4.1 Hazardous substances need to be restricted at the onset ........ 11 4.2 Recycled plastics in food packaging ...................................... 12 5 | Return and collection Systems ............................................. 13 6 | Compostability requirements (Art. 8) .................................... 14 7 | Labelling and packaging waste collection ............................... 15 8 | Governance and Role of standards ....................................... 16 9 | Conclusions .......................................................................

…16 9 | Conclusions ....................................................................... 17 Raising standards for consumers ANEC-SUST-2023-G-005 – 16/03/2023 4 Introduction ANEC’s broad assessment of the proposal ANEC welcomes the proposed Regulation, as the improvements put forward should help provide convenient choice to consumers in reducing their packaging waste. It proposes important requirements on prevention and reuse, in line with our position. Nevertheless, we regret the initiative promotes recyclable packaging and use of recycled content in plastic packaging. We also expected prevention and reuse targets to be more ambitious, and first of all for there to be further restrictions on substances of concern in packaging. This is a crucial precondition, especially for packaging to which consumers are exposed (food, drinks etc.).

…packaging. This is a crucial precondition, especially for packaging to which consumers are exposed (food, drinks etc.). Prevention and reuse targets should be based on technical studies (reviewing all the relevant types of materials and uses). Reuse should be prioritised if environmental impacts – considering the overall life cycle – are lower than for single use packaging. In addition, reuse packaging should be developed to take into account its durability and recyclability at the end of its life. While we favour material-neutrality for this regulation, it is important to note the advantages of inert materials from a consumer safety perspective. It is crucial in the next steps of the revision – as for all Circular Economy measures – that actions reflect the waste hierarchy and the assessment of health and environmental impacts.

Economy measures – that actions reflect the waste hierarchy and the assessment of health and environmental impacts. We have criticised how the present Directive’s core requirements are too ambiguous, do not provide clear guidance to business, and are therefore challenging to enforce. We are glad to note in the proposal that the Regulation would be implemented by delegated acts in conjunction with European standardisation. Nevertheless, we urge key criteria are set by the regulator, and not delegated to European Standardisation Organisations where business has the resources and economic interest to ensure the strongest voice. Raising standards for consumers ANEC-SUST-2023-G-005 – 16/03/2023 5 1 | How the PPWR proposal addresses our recommendations so far Aspects in line with ANEC position: ⚫ A Regulation as the legal instrument instead of a directive.

…so far Aspects in line with ANEC position: ⚫ A Regulation as the legal instrument instead of a directive. This will ensure simultaneous and equal implementation of the measures across Member States, to the benefit of consumers and the environment. ⚫ More emphasis on prevention and reuse while also addressing overpackaging: o it sets requirements to minimise the weight, volume and layers of packaging, with attention to safety and functionality. o a ban on certain forms of unnecessary packaging. o it addresses the maximum empty space allowed in packaging used by the e- commerce sector. ⚫ Information requirements on all packaging to facilitate consumer sorting. ⚫ A mandatory deposit return system for plastic bottles and aluminium cans. ⚫ The objective for 90% of large household appliances to be delivered in reusable packaging by 2030.

…aluminium cans. ⚫ The objective for 90% of large household appliances to be delivered in reusable packaging by 2030. ⚫ Reference to fast-moving goods, recognising the role of packaging in preserving the quality of the product. Improvements could still be made in these areas: ⚫ Prevention targets are too low. ⚫ The reuse and refill targets (Article 26) are lower than expected, but we note ambitious measures can succeed only if combined with the necessary targets and restrictions to reduce the content of hazardous substances. While the revision of the Packaging Directive (94/62/EC) still includes limits only for heavy metals1: ⚫ We wanted to see the proposal ensure stricter requirements, and phase out other substances of concern from packaging materials in a generic fashion (especially CMRs and EDCs).

…and phase out other substances of concern from packaging materials in a generic fashion (especially CMRs and EDCs). ⚫ The lack of general restrictions on harmful substances may be of concern, notably as regards the targets for recycled content foreseen in sensible packaging (such as food contact materials, medicines etc.). As some measures resulting from the otherwise successful single-use plastics directive showed, when replacing a material or packaging by another one, it needs to be proven that the replacement has less environmental impact and at least the same performance. It is imperative to avoid that “the disease worsens with treatment”. 1 Article 5 Raising standards for consumers ANEC-SUST-2023-G-005 – 16/03/2023 6 In the chapters below, we further develop our recommendations for improvement.

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