Bundesverband der Pharmazeutischen Industrie e.V.

Politik Europa/ Büro Brüssel Rue Marie de Bourgogne 58 | 1000 Brüssel | www.bpi.de Telefon: +32 25 00 89 61 | E-Mail: [email protected] BPI e.V. response to the consultation on Commission adoption to Reducing packaging waste The BPI e.V., representing more than 270 members, comprises the whole spectrum of the pharmaceutical industry, ranging from multinational corporations to SMEs, Mid-Caps as well as Start-ups. These companies ensure timely and safe drug supply for all patients across the EU and globally. We welcome the European Commission’s initiative to review the requirements on packaging and packaging waste to encourage “circular economy” in the EU. Please find our detailed comments on individual articles below. Article 5 does not differentiate between packaging for private use (B2C) and commercial/ industrial use (B2B).

…below. Article 5 does not differentiate between packaging for private use (B2C) and commercial/ industrial use (B2B). Both types of packaging must not be treated in the same way, as the intended use, material flows and filling goods are too different. Article 5, point 2 limits also cullet content of glass packaging. We suggest to keep the existing limit for recycled glass packaging of 200 ppm (limit is mentioned in Decision of the Commission from 19.2.2001 (2001/171/EG), Art. 5) because this ensures safety while at the same time enabling a higher quota of recycling. Article 6, Point 4 would also include any kind of applicator, pipette, special or re-usable dispenser/diffuser/sprayer. These kind of accessible packaging components are essential for elderly and disabled people. It is uncertain that recyclable alternatives can be developed until 2030.

…essential for elderly and disabled people. It is uncertain that recyclable alternatives can be developed until 2030. Furthermore, the development of new designs would lead to higher costs for the pharmaceutical industry. In case of prescription drugs, it would harm the company itself and would weaken the location for business in the EU. In case of OTC products, the price increase could be forwarded to the patient. We suggest to make special provisions for these kind of components, e.g. longer transition phases. To Article 7, recycling requires openness to technology. Accordingly, chemical recycling should be recognized as a building block of the circular economy and recycling in all national and European regulations on a non-discriminatory basis. Through supplementary chemical recycling, the minimum percentage of recycled content can also be achieved in contact- sensitive packaging.

…chemical recycling, the minimum percentage of recycled content can also be achieved in contact- sensitive packaging. In the case of contact-sensitive packaging, all possible interactions between the packaging material and the packaged product as well as the potential resulting consequences (contamination or change in packaging properties) during the entire service life should be taken into account. The requirements from Article 11, Point 1 may lead to bigger labeling space and interfere recyclability. Bigger labeling area is contradicting recyclability (especially regarding glass bottles and containers). Article 11 should provide an option to be able to place all necessary information under a QR Link. Ref. Ares(2023)2498996 - 06/04/2023

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