Trade unions and professional associations · IT
Assomela’s position on PPWR Assomela, the Italian association of apple producers, supports the efforts to harmonize the packaging market in Europe and supports the will to increase sustainable packaging solutions. The Italian apples sector is highly concerned about the discriminative targeting of the fresh produce sector in Article 22, Annex V, point 2 and the possible consequences this could have in terms of food safety, information transparency and food waste. Assomela calls for the European institutions to reconsider the ban on packaging for fresh produce studying the effects this could have for the sector and to establish a reasonable timeline which permits to the sector to ensure transparency and no major discriminations in the market.
…a reasonable timeline which permits to the sector to ensure transparency and no major discriminations in the market. The Italian apples sector has made huge efforts in the last years in finding and using innovative solutions for packaging in terms of materials and designs. The sector welcomes the initiative to move towards sustainable packaging solutions, however it is highly concerned on the discriminative approach used for the F&V sector, specifically targeted in art. 22 annex V, point 2. The requests to the sector and to a specific product category are disproportionate if compared to the general objective of the proposed regulation which is to reduce the environmental impact of packaging. The fact that part of the F&V – and apples therefore – are sold in bulk, does not mean that everything could be sold without packaging.
…of the F&V – and apples therefore – are sold in bulk, does not mean that everything could be sold without packaging. Moreover, if the EU wants to reduce food waste and enhance the consumption of F&V, these requests really don’t help the EU the reach the fixed goals. For these reasons, Assomela highlights the need to have a detailed and complete assessment on the impact of the proposed changes. Considering that the plastic packaging represents only around 1,5% of all plastic packaging used in retail, a ban covering specifically the sector is disproportionate. In the apples sector packaging is highly functional for a series of different reasons: - Product transportation and Product containment – for effective and efficient operations and logistics from the warehouses to the retailers’ products should be well contained.
…and efficient operations and logistics from the warehouses to the retailers’ products should be well contained. Standard plastic and paper boxes and palettes are just an example of sustainable and cost-efficient packaging. - Protection of the product – apples are very perishable (especially certain varieties) and they must be protected in every single step of the supply chain to be at the point of sales in good condition to the consumers. The packaging also avoids microbiological contamination and maintains hygiene. This function of packaging has been highly recognized by the consumers during the COVID-19 pandemic – in fact, the sales of packaged apples and F&V increased. - Extend product shelf life - Packaging extends the shelf life of apples and avoid bruises. - Prevent food waste – avoiding bruises packaging helps in preventing food waste.
…life of apples and avoid bruises. - Prevent food waste – avoiding bruises packaging helps in preventing food waste. - Communication and information to the consumers Packaging offers to the sector possibilities to communicate to both supply chain actors and consumers with obligatory and essential product information. Information is given by a large variety of packaging from paper-based palettes, to containers, wrappers and small labels. Legally obligatory information includes but is not limited to variety, traceability, country of origin, organic distinction from conventional products and fraud detection. Essential information for the benefit of trade and consumers includes among others color, branding, PLU codes, barcodes, quality, storage and/or preparation messages (for example ‘ready to eat’). Ref.
…color, branding, PLU codes, barcodes, quality, storage and/or preparation messages (for example ‘ready to eat’). Ref. Ares(2023)2804004 - 20/04/2023 - Differentiation of the products and consumer confidence Packaging remains a tool for informing consumers about progress and product segmentation initiatives, whether they are official signs of quality and origin (PDO/PGI/ST), private quality approaches and, specifically for apples, different varieties, both traditional and new ones. - Consumption promotion and facilitation To stimulate the apples consumption (which is decreasing) in Europe is fundamental to increase the availability of a diverse range of products and varied portion sizes for consumers to suit their changing lifestyles.
…availability of a diverse range of products and varied portion sizes for consumers to suit their changing lifestyles. Packaging facilitates these efforts by providing different mediums of fruit and vegetable consumption to suit different demographics’ lifestyle and consumption patterns, which are continually evolving. Considering all the above-mentioned functionalities of fresh produce packaging, Italian apples producers warn the European Commission that Article 22 Annex V point 2 may lead to severe direct and indirect negative consequences regarding food safety and quality, food waste, unfair competition on the Single Market and labelling requirements among others. The apple sector in the last years has proven commitment on its strive for sustainable solutions and environmental efforts, continuously balancing sector needs with sustainability ambitions and consumer safety.
…and environmental efforts, continuously balancing sector needs with sustainability ambitions and consumer safety. For example, the apples sector has been one of the first to use the 4-6 fruit carton pack – in the last years the investments for new packing machineries for these carton packs have been important (only in Trentino South Tyrol – the main Italian producing region - the total investments for these machinery by the POs were more than 1,5 million euros also financed by the operational programs) Therefore, Assomela urges EU institutions to consider the following points: • Reconsider the explicit ban of Article 22, Annex V, point 2 on single-use packaging of fresh fruits and vegetables, acknowledging the wider implications of such a ban.
V, point 2 on single-use packaging of fresh fruits and vegetables, acknowledging the wider implications of such a ban. A complete ban on the packaging of fresh produce would not only put food safety and consumer interests at stake, but it would also severely impact the fresh produce sector’s potential in supplying a diverse selection of quality products, (different categories, but also different varieties), the EU’s efforts to reduce food waste, and competition on the Single Market. • Refocus on recyclability and waste management instead of re-use/no re-use. • Promote innovation and research on sustainable and efficient packaging solutions and materials so to have possible options. • To understand the risky implications of the regulation application, further impact assessments must be undertaken.
• To understand the risky implications of the regulation application, further impact assessments must be undertaken. Such impact assessments must consider consumer’s health, food security and food waste, as well as clarify how this proposal aligns with the ambitions of the Green New Deal, the Farm to Fork, or the EU Food Waste Reduction targets. • Any interference in the allowed use of packaging materials and packaging formats must leave a sufficient time frame for sectors to adapt and no restrictions should enter into force a clear timeline is defined. Moreover, Assomela welcomes Article 8(1) on compostability of sticky labels on fresh fruit and vegetables and the harmonization of fruit and vegetable stickers it brings.
…of sticky labels on fresh fruit and vegetables and the harmonization of fruit and vegetable stickers it brings. Apples are among the main F&V products which widely use stickers – to communicate both different varieties (especially the new ones) and brands, which are quite important in the Italian and European apples sector. Over the past three years, the fresh produce sector has worked intensively on compostable solutions for fruit and vegetable labels to provide viable industrially and home compostable label solutions for all products and the effort has been very challenging (no solution until now has been found, for example, for stickers that begin the degradation process during long transit time). Assomela is concerned that Article 8(1) lacks labelling quality specification as no specific standard is mentioned in it for industrial compostability, such as EN13432.
…quality specification as no specific standard is mentioned in it for industrial compostability, such as EN13432. Additionally, Article 8(1) does not mention any requirement for certification. Thus, Assomela strongly recommends that labelling quality specification is included in Article 8(1) to ensure verification of labelling quality and to avoid greenwashing. Furthermore, industrial compostable requirements should be met for all the components of the stickers (face stock, adhesive and ink). Assomela welcomes the extensive consultations the EC had with the stakeholders, nevertheless it reiterates the need to reconsider the discriminative targeting of one specific sector, and the need to conduct full and science-based life cycle analyses for the packaging measures proposed, in particular for the fresh fruit and vegetable sector.