European Ceramic Industry Association

…1 CERAME UNIE REPLY TO PPWD REVIEW CONSULTATION Reference: Response to the Public Consultation on the Review of the Packaging and Packaging Waste Directive 6 January 2021 Cerame-Unie (the European Ceramic Industry Association) and its member association FEPF (the European Federation of Table- and Ornamentalware) would like to thank the European Commission for the opportunity to partake in the public consultation and set out the industry’s view in respect of the revision of the Packaging and Packaging Waste Directive (PPWD). In addition to the responses provided in the online questionnaire, Cerame-Unie would like to further elaborate the industry’s position in the sections below, in order to provide additional background with reference to ceramic packaging.

…position in the sections below, in order to provide additional background with reference to ceramic packaging. According to the current PPWD, ceramic containers should adhere to a “Return, Collection and Recovery System”, although the nature of these products clearly distinguish them from other types of packaging waste. Ceramic packaging containers are placed in the market in negligible volumes and it is neither economically nor environmentally reasonable to set up a specific collection and treatment system for ceramics. In this regard, Cerame-Unie wishes to highlight that ceramic is a non-polluting material entailing no risk for natural sources like water, air and soil, nor for human health, animals and plants. Ceramic packages are designed and manufactured to be marketed indiscriminately as packaging, kitchenware or tableware.

Ceramic packages are designed and manufactured to be marketed indiscriminately as packaging, kitchenware or tableware. For instance, research by our member companies shows that ceramic food containers are long-lasting products that consumers are willing to keep (75-95% of the cases) and reuse as kitchenware or tableware: they generate no unwanted smell and can resist remarkable temperature changes, and they can be reused multiple times simply by being washed and dried. Therefore, ceramic packaging containers are key products in the prevention of waste. The features of ceramic packages perfectly dovetails with the concept of reusable packaging laid out in the PPWD, as these items are conceived and marketed to be reused multiple times throughout their lifecycle.

…in the PPWD, as these items are conceived and marketed to be reused multiple times throughout their lifecycle. The current measures set out in the PPWD result in inefficiencies and shortcomings on multiple levels, which namely affect: (i) Packaging Waste Management Systems, since they have to separate ceramic containers from other types of packaging; (ii) Producers of ceramic containers, who are being excluded from the market due to the high fees imposed to ceramics containers in some Member States resulting from a lack of a harmonised implementation in the EU based on eco-modularity principles; Ref. Ares(2021)145456 - 07/01/2021 2 (iii) Ceramic containers fillers, who are required to financially contribute to the Packaging Waste Management System without having a specific pick-up, transportation, storage and recycling system in place.

Waste Management System without having a specific pick-up, transportation, storage and recycling system in place. The high fees for ceramic containers in some Member States are already having negative effects on the industry as container fillers are encouraged to shift to cheaper but more contaminant packaging materials. That situation is particularly dramatic in France, where there has been a severe increase in fees in the last years on the grounds that there is no specific collecting/recycling channel for ceramic items, without taking into account the environmental harmlessness of such products and the wide range of applications in which it can be recycled. This situation could potentially be replicated in other Member states as long as the lack of harmonisation at EU level remains and the eco-modularity principle is left out.

Member states as long as the lack of harmonisation at EU level remains and the eco-modularity principle is left out. This scenario is hindering the objectives set out in the European Green Deal as the current legislation does not incentivise the use of packaging materials that are inert and reusable like ceramics, which are inherently conceived to prevent the creation of packaging waste. For all these reasons, Cerame-Unie advocates that the PPWD should be reviewed to exclude ceramic containers fillers from Packaging Integrated Waste Management Systems as this product is mostly reused and does not generate packaging waste (if any, in a negligible way). Additionally, it is worth reiterating that ceramic packaging is entirely made of an inert material that causes no harm to nature.

…it is worth reiterating that ceramic packaging is entirely made of an inert material that causes no harm to nature. In this regard, ceramic containers waste should be treated as municipal and household domestic waste so as to be treated in Eco-parks to put an end to inefficient systems. In this sense, Cerame-Unie calls on the European Commission to amend the PPWD and exclude ceramic packaging waste from the Packaging Waste Management System and implement a harmonisation mechanism on the basis of the eco-modularity principle.

Packaging Waste Management System and implement a harmonisation mechanism on the basis of the eco-modularity principle. In the alternative, Cerame-Unie calls on the European Commission to make use of Article 20 of the Packaging Directive by adopting a delegated act addressing more specifically the situation of ceramic containers (See Article 20 of the Packaging Directive: “The Commission is empowered to adopt delegated acts in accordance with Article 21a in order to supplement this Directive where necessary to deal with any difficulties encountered in applying the provisions of this Directive, in particular, to inert packaging materials placed on the market in very small quantities (i.e. approximately 0,1 % by weight) in the Union, primary packaging for medical devices and pharmaceutical products, small packaging and luxury packaging”).

…the Union, primary packaging for medical devices and pharmaceutical products, small packaging and luxury packaging”). Considering the inert, pollutant-free, reusability, high recyclability and dependence on locally available raw materials (clay), the EU legal framework should ensure that food and drinks containers opting for ceramic containers cannot be discriminated against through the imposition of disproportionately high recycling (green dot) fees as it is the case in France.

originalus šaltinis (PDF) ↗

CERAME-UNIE aisbl Rue Belliard 12 – 1040 Brussels Tel. +32.2.808.38.80 - E-Mail : [email protected] www.cerameunie.eu 7 January 2026 The European ceramic industry calls for realistic targets on the re-use of transport packaging under the new Packaging and Packaging Waste Regulation Cerame-Unie welcomes the draft Delegated Act on the exemption of plastic wrapping and straps from the 100% reuse obligations under the new Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR). While we appreciate the efforts made, we urge the European Commission to ensure that the Regulation is implemented through economically and technically achievable targets, without undermining the competitiveness and productivity of the industries concerned, particularly with regard to pallet wrappings, straps, and pallets.

…and productivity of the industries concerned, particularly with regard to pallet wrappings, straps, and pallets. Reusability obligation for pallets wrappings and straps Through the proposed delegated act, the Commission introduces a targeted exemption for plastic wrapping and straps from the 100% reuse obligations set out in Article 29(2) and (3), while preserving the horizontal reuse targets established under Article 29(1). In this context, the delegated act confirms that, as of 1 January 2030, economic operators using transport packaging or sales packaging for transport purposes (including pallet wrappings and straps), are required to ensure that at least 40% of such packaging is reusable within a reuse system. In addition, from 1 January 2040, operators are expected to make efforts to reach a reuse share of at least 70% for the same categories of packaging within a reuse system.

…to make efforts to reach a reuse share of at least 70% for the same categories of packaging within a reuse system. Pallet wrappings and straps are essential tools in securing the stabilisation and protection of products during transportation, preventing possible breakages or damages and ensuring the safe handling of the load. They are often stretched or shrunk while being secured to the load, and they can suffer damages during packaging, storage, transport and handling. In most of the cases, operators are also required to cut open wrappings and straps when unloading pallets, thus preventing any further reutilisation. For their inherent characteristics, they cannot be fully recovered after being detached from the packed material, neither they can be re-used while providing the same performance in terms of efficiency, safety and conservation of the load.

…they can be re-used while providing the same performance in terms of efficiency, safety and conservation of the load. Due to their specific function and attributes, pallet wrappings and straps cannot be considered reusable packaging, as defined by Article 11 of the PPWR. Therefore, Cerame-Unie asks the European Commission to exempt plastic wrappings and straps from the requirements of article 29 (1). Reusability obligation for pallets While the ceramic industry reaffirms its support to the exemption of pallet wrappings and straps from the above-mentioned targets, Cerame-Unie highlights that a 100% reusability obligation is similarly not achievable for pallets. We therefore urge the European Commission to consider the challenges and limitations currently experienced by the industry while ensuring a realistic and reasonable implementation of the PPWR. Ref.

…currently experienced by the industry while ensuring a realistic and reasonable implementation of the PPWR. Ref. Ares(2026)113494 - 07/01/2026 CERAME-UNIE aisbl Rue Belliard 12 – 1040 Brussels Tel. +32.2.808.38.80 - E-Mail : [email protected] www.cerameunie.eu In the ceramic bricks and tiles industry, pallets are subject to rough handling due to the weight and bulk of the products. This leads to significant wear and tear, causing damage that renders many pallets unfit for reuse after a few cycles. Reusable pallets have a narrow lifetime (six to seven uses) and the use of standard formats is often hampered by technical requirements related to production or transportation needs, further limiting their efficiency and environmental advantages. Pallets are often stored outdoor and face extreme weather conditions, and long transport distances, which accelerate their deterioration.

…outdoor and face extreme weather conditions, and long transport distances, which accelerate their deterioration. These factors reduce the number of times they can be reused, undermining their sustainability benefits. High quality of pallets and avoidance of material damage to the pallets is crucial for the safe handling (transport) of ceramic building materials. Reusable pallets require regular maintenance and repair to remain in usable condition. Consequently, a transition to 100% reusable pallets employed in business-to-business transportation seems completely unrealistic for many companies in the next few years. In many regions, there is no established infrastructure to efficiently return reusable pallets to their origin for reprocessing. The high costs and complexity of pallet returns, especially in cross-border operations, make it difficult to maintain a circular system.

…complexity of pallet returns, especially in cross-border operations, make it difficult to maintain a circular system. In addition to those logistic barriers, regional discrepancies across Member States should be considered: some countries in the EU focus on single- use pallets due to the absence of return logistics, making reuse impractical. Thus, the ceramic sector is confronted with significant regional differences in pallet handling. Different plants in the EU often rely on a mix of single-use and reusable pallets depending on their specific needs. Certain production lines and handling systems are designed to work only with single- use pallets, and retrofitting these systems would require significant investments. In some countries, the conveyor belt must be converted so that the production line can accommodate reusable EUR- pallets which in turn entails immense investment costs.

…so that the production line can accommodate reusable EUR- pallets which in turn entails immense investment costs. On the other hand, due to the wide variety of formats in some countries, transforming the unloading and packaging lines to a layer-by-layer de- hacking system and implementing a stacker system with robots must be used which in turn entails investments. In addition, some of the products manufactured by the ceramic industry require pallets with specific dimensions and load capacities: these specific requirements cannot be met by using standardised pallet formats, further limiting their implementation.

…these specific requirements cannot be met by using standardised pallet formats, further limiting their implementation. While reaffirming its commitment to implementing realistic solutions for the promotion of circularity and environmental sustainability throughout all the supply chain, Cerame-Unie requests the European Commission to exempt pallet wrappings and straps from the scope of Article 29 (1) as well as pallets from the scope of Article 29 (2) and (3).

originalus šaltinis (PDF) ↗