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Visitas suggestions for amendments UTKAST UPPDATERAT 2023-03-08 European Commission proposal (20221130) Visitas suggestions for amendments Visitas comments to suggestion for amendments Art 22 and Point 3 of Annex V Art 22: Restrictions on use of certain packaging formats 1. Economic operators shall not place on the market packaging in the formats and for the purposes listed in Annex V. 2. By way of derogation from paragraph 1, economic operators shall not place on the market packaging in the formats and for the purposes listed in point 3 of Annex V as of 1 January 2030. 3. Member States may exempt economic operators from point 3 of Annex V if they comply with the definition of micro- I. Add an exemption when it is beneficial from environmental and climate perspective: Art 22 p 1:

…of micro- I. Add an exemption when it is beneficial from environmental and climate perspective: Art 22 p 1: 1. Economic operators shall not place on the market packaging in the formats and for the purposes listed in Annex V, except if the single use packaging according to for example a life cycle analysis is more beneficial than reusable packaging from an environmental and climate perspective. Alternatively, Art 22 p 3: 3. Member States may exempt economic operators from point I. This ban is too strict and does not take into account the fact that in some cases single-use items may be environmentally and climatically advantageous.

…into account the fact that in some cases single-use items may be environmentally and climatically advantageous. As an increased use of reusable packaging will, for example, lead to more transport and increased water use, it is crucial to have an overall sustainability perspective and therefore there should be an exemption for when single use is beneficial from environmental and climate perspective. Ref. Ares(2023)2656845 - 14/04/2023 company in accordance with rules set out in the Commission Recommendation 2003/361, as applicable on, and where it is not technically feasible not to use packaging or to obtain access to infrastructure that is necessary for the functioning of a reuse system.

…to use packaging or to obtain access to infrastructure that is necessary for the functioning of a reuse system. P 3 of Annex V: Restrictions on use of packaging formats “Single use packaging for foods and beverages filled and consumed within the premises in the HORECA sector, which include all eating area inside and outside a place of business, covered with tables and stools, standing areas, and eating areas offered to the end users jointly by several economic operators or third party for the 3 of Annex V if they comply with the definition of micro- company in accordance with rules set out in the Commission Recommendation 2003/361, as applicable on, and where it is not technically feasible not to use packaging or to obtain access to infrastructure that is necessary for the functioning of a reuse system.

…to use packaging or to obtain access to infrastructure that is necessary for the functioning of a reuse system. Member States may also exempt economic operators from point 3 if the use of single use packaging according to for example a life cycle analysis is more beneficial than reusable packaging from an environmental and climate perspective. II. Increase the exemption in point 3 for other companies than micro- companies: II. It will be much harder for companies outside the cities/out in the country to comply with the suggested ban and therefore there should be a possibility for Member States to be able to exempt not only micro- companies but also companies from the ban where it's not technically feasible to use packaging or to obtain access to necessary infrastructure. III. The ban means that many companies need to change their food and waste management completely.

III. The ban means that many companies need to change their food and waste management completely. A new food and waste system leads to large investment costs. Hence the implementation date should be set to purpose of food and drinks consumption” “Illustrative examples” “Trays, disposable plates and cups, bags, foil, boxes” Art 22 p 3: Member States may exempt economic operators from point 3 of Annex V if they comply with the definition of micro- company in accordance with rules set out in the Commission Recommendation 2003/361, as applicable on, and other companies and where it is not technically feasible not to use packaging or to obtain access to infrastructure that is necessary for the functioning of a reuse system. III. Add an exemption if there are exceptional reasons Art 22 p 1:

…is necessary for the functioning of a reuse system. III. Add an exemption if there are exceptional reasons Art 22 p 1: 1. Economic operators shall not place on the market packaging in the formats and for the purposes listed in Annex V, except if the single use packaging according to for example a life 2035 in order for the companies to still be financially sustainable. III. An exception should also be inserted when there are very special reasons. For example, disposable items may be needed when serving on the premises in, for example, prisons, schools and hospitals, for example for safety, hygiene and health reasons. Food that is delivered to such kitchens and places may need to be handled in a special way to guarantee, for example, lack of allergens and to achieve health aspects. IV. For the sake of clarity and for the companies' legal security, the list of prohibited products needs to…

…packaging from an environmental and climate perspective or if there are exceptional reasons. Alternatively Art 22 p 3: 3. Member States may exempt economic operators from point 3 of Annex V if they comply with the definition of micro- company in accordance with rules set out in the Commission Recommendation 2003/361, as applicable on, and where it is not technically feasible not to use packaging or to obtain access to infrastructure that is necessary for the functioning of a reuse system. Member States may also exempt economic operators from point 3 if the use of single use packaging according to for exhaustive and not exemplary. example a life cycle analysis is more beneficial than reusable packaging from an environmental and climate perspective or if there are exceptional reasons. IV. The list of restricted packaging formats must be exhaustive and not exemplary: Point 3 of Annex V:…

Restricted packaging formats Art 22 and Point 4 of Annex V Art 22: “Restrictions on use of certain packaging formats” 1. Economic operators shall not place on the market packaging in the formats and for the purposes listed in Annex V. (…) 3. Member States may exempt economic operators from point I. Add an exemption when it is beneficial from environmental and climate perspective: Art 22 p 1:

…from point I. Add an exemption when it is beneficial from environmental and climate perspective: Art 22 p 1: 1. Economic operators shall not place on the market packaging in the formats and for the purposes listed in Annex V, except if the single use packaging according to for example a life cycle analysis is I. This ban does not take into account the fact that in some cases single-use items may be environmentally and climatically advantageous. It is crucial to have an overall sustainability perspective and therefore there should be an exemption for when single use is beneficial from 3 of Annex V if they comply with the definition of micro- company in accordance with rules set out in the Commission Recommendation 2003/361, as applicable on, and where it is not technically feasible not to use packaging or to obtain access to infrastructure that is necessary for the functioning of a reuse…

…and climate perspective. II.Increase the exemption in accordance with the exemption for Point 3 of Annex V: Art 22 p 3: 3. Member States may exempt economic operators from point 3 and 4 of Annex V if they comply with the definition of micro- company in accordance with rules set out in the Commission Recommendation 2003/361, as applicable on, and where it is not technically feasible not to use packaging or to obtain access to infrastructure that is necessary for the functioning of a reuse system. III. Add an exemption if there are exceptional reasons environmental and climate perspective. II. There should be an equal exemption from this ban as from Point 3 of Annex V for businesses where it is not technically feasible not to use packaging or to obtain access to infrastructure that is necessary for the functioning of a reuse system. III. An exception should also be inserted when there are…

…without the need of any further preparation” “Illustrative examples – Sachets, tubs, trays, boxes” Art 22 p 1: 1. Economic operators shall not place on the market packaging in the formats and for the purposes listed in Annex V, except if the single use packaging according to for example a life cycle analysis is more beneficial than reusable packaging from an environmental and climate perspective or if there are exceptional reasons. IV. The list of restricted packaging formats must be exhaustive and not exemplary: Point 4 of Annex V: (…) Illustrative examples Restricted packaging formats V. Extend the implementation period to 2030: Art 22 p 2 to 2030:

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