F.E.E.D.M. · Trade and business associations · DE
F.E.E.D.M. ▪ Grosse Bäckerstrasse 4 ▪ 20095 Hamburg ▪ Germany Tel.: +49 40 37 47 19 13 ▪ Fax: +49 40 37 47 19 19 ▪ E-Mail: [email protected] ▪ Web: www.feedm.com All information is supplied without guarantee and excluding all liability. JG/ZK 24 April 2023 F.E.E.D.M. Statement EU proposal for a revision of the EU legislation on Packaging and Packaging Waste F.E.E.D.M. welcomes this public consultation and the opportunity to provide comments on the Commission’s proposal for a revision of the EU legislation on Packaging and Packaging Waste. F.E.E.D.M. represents the interests of the European honey packers and distributors, mainly small and medium-sized enterprises (SME). The priority of the association is to defend and promote honey as a pure and natural product. The association supports good apiculture practices and aims at improving the quality standards of the product.
…product. The association supports good apiculture practices and aims at improving the quality standards of the product. The members of F.E.E.D.M. commit themselves to the integrity and quality of the products, which are subject to their business. Planned ban on single-use portion packs in the HORECA sector (hotel, restaurant, catering): F.E.E.D.M’s proposal is for a continued allowance of single-use honey portion packs, especially in sensitive areas (e.g. hospital, military). Reasonable transition periods against food waste are essential. Cost increase and logistical disadvantages The Commission’s proposal to ban single-use packaging in the HORECA sector would have a negative impact on companies and consumers. Additionally, it would require major changes in the supply chain.
…have a negative impact on companies and consumers. Additionally, it would require major changes in the supply chain. New recycling schemes, for example small reusable glass jars, would lead to a significant increase in costs especially for SMEs, which will then be passed on to the consumers. Compared to plastics, the transport of glass containers is much more space and energy consuming. The transport weight is many times higher, even higher than the food portion contained. Additionally, there is a risk of breakage with glass packaging, which - added on the risk of injury - can lead to high losses during transport. The increased energy required for the production of small glass packaging and the high energy costs for cleaning reusable containers must also be taken into account.
…of small glass packaging and the high energy costs for cleaning reusable containers must also be taken into account. Mandatory use of reusable containers made of glass, could also lead to difficulties in availability and thus to problems in the supply chain. Single-use portion packaging already consists of materials with a high recyclable content up to 100 % - without the use of composite films - and can therefore already be integrated into the recycling loop. In case of individual packaging, the ratio of packaging weight to the food portion is usually much more favourable than for larger packaging. This makes transport even more efficient. Ref. Ares(2023)2883040 - 24/04/2023 F.E.E.D.M.
…than for larger packaging. This makes transport even more efficient. Ref. Ares(2023)2883040 - 24/04/2023 F.E.E.D.M. ▪ Grosse Bäckerstrasse 4 ▪ 20095 Hamburg ▪ Germany Tel.: +49 40 37 47 19 13 ▪ Fax: +49 40 37 47 19 19 ▪ E-Mail: [email protected] ▪ Web: www.feedm.com All information is supplied without guarantee and excluding all liability. Limitation of the variety of honey products In case of a ban of single-use packaging, the option of choice would be to move towards larger honey dispensers with a pump. Dispensers would be hygienic and also easy for consumers to use. However, this would result to the use of solely liquid-form honey in the HORECA sector since some more solid formats of honey could not be placed in this type of dispenser. This would then lead to discrimination against the honey packers that provide a more solid form of honey.
…of dispenser. This would then lead to discrimination against the honey packers that provide a more solid form of honey. Food safety and food waste concerns Single-portion packaging in the HORECA sector develops a high standard of hygiene that cannot be maintained in case of larger packaging. It ensures moisture stability and contributes to microbiological safety. It helps to keep the freshness and quality of the honey as it is sealed and protected from external contamination sources such as air, moisture, and light. This helps to prolong the shelf life of the honey and also ensures that it retains its natural aroma and flavour. The single-portion packaging also makes a clear labelling for each portion possible and thus contributes to a transparent flow of information for consumers.
…a clear labelling for each portion possible and thus contributes to a transparent flow of information for consumers. Additionally, and most importantly, single-use portion packs support portion control, which prevents excessive portioning and thus unnecessary food waste. Need of single-use portion packs in sensitive areas Single-use portion packs are essential, especially in areas such as hospitals and the military field. In the field operation, the use of glass containers is not feasible due to transport weight and risk of breakage. When supplying patients in hospitals, the high hygiene standards must be maintained, which can only be guaranteed by single-use portion packs. F.E.E.D.M. therefore demands that single-use portion packs are continued to be allowed in sensitive areas such as hospitals and the military field.
…that single-use portion packs are continued to be allowed in sensitive areas such as hospitals and the military field. Transition periods In case of a ban of single-use packaging, F.E.E.D.M calls for a reasonable transition period allowing stocks of single-use portion packs to be used up. Companies should also be given time to gradually adapt to the new regulation. Furthermore, with respect to sustainability goals, a constant (re)evaluation of the status quo is needed in order to monitor if the outcome of the regulation results in not only decreased packaging waste but increased food waste. If this would be the case, adjustments should be made possible. F.E.E.D.M.
…packaging waste but increased food waste. If this would be the case, adjustments should be made possible. F.E.E.D.M. ▪ Grosse Bäckerstrasse 4 ▪ 20095 Hamburg ▪ Germany Tel.: +49 40 37 47 19 13 ▪ Fax: +49 40 37 47 19 19 ▪ E-Mail: [email protected] ▪ Web: www.feedm.com All information is supplied without guarantee and excluding all liability. Conclusion In conclusion, F.E.E.D.M. embraces the Commission’s proposal to decrease the amount of packaging and packaging waste. However, single-use packaging for honey offers crucial benefits for companies and consumers in the areas of food safety, cost-effectiveness, control of food waste and guaranteed hygienic standards in sensitive areas. Therefore, F.E.E.D.M. calls for the continued allowance of single-use portion packs for honey, especially in sensitive areas.
F.E.E.D.M. calls for the continued allowance of single-use portion packs for honey, especially in sensitive areas. In case of a ban of single-use packaging, F.E.E.D.M stresses the importance of providing a reasonable transition period, allowing single-use portion pack stocks to be used up. This would give companies the time to align with the new regulation and avoid waste of packaged products that are not compliant anymore. Thank you for the consideration of our statement. We remain to your disposal for a constructive exchange. Best regards, F.E.E.D.M. Jeanette Gonnermann General Secretary