GroentenFruit Huis

Fresh Produce Centre, Louis Pasteurlaan 6, NL-2719 EE Zoetermeer, PO Box 5007, NL-2701 GA Zoetermeer The Netherlands T +31 79 368 11 00 E [email protected] W www.freshproducecentre.com CCI 404 112 50 Bankaccount nr. NL74 ABNA 0532 8275 03 VAT code NL00.2877.314.B01 To the European Commission INTRODUCTION Fresh Produce Centre is an industry body from the Netherlands that represents the interests of fruit and vegetables growers, their Producer Organisations, traders and wholesalers. The members of Fresh Produce Centre account for over 80% of total vegetables and fruit sales in the Netherlands. Our number the in EU-transparency register is 824033130961-66.

…of total vegetables and fruit sales in the Netherlands. Our number the in EU-transparency register is 824033130961-66. Date : April 21, 2023 Regarding : Input consultation PPWR on behalf of FPC To whom it may concern, With this letter, we convey the reaction of the Fresh Produce Centre (FPC) with regard to the 'Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on packaging and packaging waste, amending Regulation (EU) 2019/1020, and repealing Directive 94/62/EC'. On behalf of our members we would like to ask your attention to the specific requirements included in this proposal with regard to the packaging of fruit and vegetables. Needless to say, we support all efforts to reduce packaging and packaging waste. Similarly, we want to comply with the European legislation regarding packaging and food safety, quality and hygiene.

Similarly, we want to comply with the European legislation regarding packaging and food safety, quality and hygiene. However, there seems to be a conflict in legislations. The Netherlands is an important player in the production, import and export of fruit and vegetables. A complete assortment is supplied to the European retailers and food service. Although we endorse the need for packaging to be more sustainable, the proposed legislation will have a significant negative impact on the sector. The sector benefits from unambiguous policy across the various EU Member States to enable the free movement of goods. The proposed legislation gives Member States a possibility to deviate implementation from European legislation if the requirements are stricter than described in EU law.

…to deviate implementation from European legislation if the requirements are stricter than described in EU law. This in turn can lead to a range of different measures per Member State and does not contribute to a 'one single market'. Fruit and vegetables are fresh, living products that are still undergoing development from the time of harvesting to consumption. Packaging has an important function when it comes to maintaining quality, product protection, food safety, traceability and preventing food waste. It is quite possible that existing legal regulations for fruit and vegetable packaging and labelling conflict with a potential ban on fruit and vegetable packaging > 1.5 kg. Failure to pack fruit and vegetables will further lead to moisture loss, resulting in lower quality, but also loss of economic value.

…fruit and vegetables will further lead to moisture loss, resulting in lower quality, but also loss of economic value. In the Netherlands, about 70% of all fruit and vegetables are currently packaged in supermarkets. Banning packaging under 1.5 kg will much more often lead to food waste and is therefore in conflict with the objective of the Green Deal to halve food waste by 2030. Banning packaging under 1.5 kg Ref. Ares(2023)2845244 - 21/04/2023 Pagina 2 van 2 therefore has a substantial negative environmental impact as a result and a negative effect on the availability of fruit and vegetables. The limit of 1.5 kg is also insufficiently substantiated and seems arbitrarily chosen.

…of fruit and vegetables. The limit of 1.5 kg is also insufficiently substantiated and seems arbitrarily chosen. In many cases, packaging makes an important contribution to another objective of Europe, namely to stimulate the consumption of fruit and vegetables, which in turn contributes to the health of citizens, and it also concerns a diet with a low environmental impact. Consumers are looking for convenience. With packaged products for different eating moments, such as snack vegetables for snacks, lunch salads and meal kits, consumers are helped to make a healthier and environmentally conscious choice. They are increasingly opting for these convenience products. The share of packaged fruit and vegetables in the total volume of packaging waste is relatively small at approximately 1.6% of the total packaging amount in the Netherlands (source: KIDV.nl).

…waste is relatively small at approximately 1.6% of the total packaging amount in the Netherlands (source: KIDV.nl). The proposed legislation specifically for fruit and vegetables is therefore disproportionate given this low share of packaging and its positive contribution in terms of shelf life, quality and traceability. In addition, the ban on packaging up to 1.5 kg does not do justice to the companies that have switched from plastic to cardboard packaging for fruit and vegetables in recent years. These companies have often invested heavily in new packaging concepts and packaging lines, and they are now left out in the lurch because single us paper/cardboard packaging would also no longer be allowed. Scientific research has to point out which product can be produced and traded without or with sustainable packaging.

Scientific research has to point out which product can be produced and traded without or with sustainable packaging. The use of circular raw materials in the European Union is appropriate if the waste system in the 27 member states can provide enough reusable and circular (bio)plastics and recyclable cardboard for safe, good and clean fruit and vegetables without food waste. We therefore ask you to reconsider the proposal to ban packaging under 1.5 kg for fruit and vegetables. More research is needed into the environmental impact of packaging fruit and vegetables under 1.5 kg. Forgoing packaging is not always the option with the lowest environmental impact. In addition, more research is needed to scientifically substantiate the optimal way of distributing and offering the various products and what role packaging plays in this.

…substantiate the optimal way of distributing and offering the various products and what role packaging plays in this. The availability of recycled plastic as a raw material for plastic packaging should also be taken into account. The availability of sufficient food grade recyclate is currently a problem in making plastic packaging more sustainable. Yours sincerely, Janine Luten CEO Fresh Produce Centre Louis Pasteurlaan 6 NL-2719 EE Zoetermeer

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