Interesų grupė
The following feedback is related to the “Consultation Strategy Review of the requirements for packaging and other measures to prevent packaging waste” and will focus on biodegradable and compostable plastics (certified according to the standard EN 13432). We would highlight the following issues covered by the consultation:
…according to the standard EN 13432). We would highlight the following issues covered by the consultation: 1. Definition of “recyclability” or “recyclable” The definition of “recyclability” or “recyclable” packaging should be in line with article 3 of the Waste Framework Directive: ‘recycling’ means any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes. It includes the reprocessing of organic material but does not include energy recovery and the reprocessing into materials that are to be used as fuels or for backfilling operations Therefore, the WFD includes organic recycling in the overall definition. Compostable plastic packaging certified according standard EN 13432 is organically recyclable, in fact the Packaging and Packaging Waste Directive recognizes the contribution given by compostable…
Directive issued in 1994, thus the definition of “recyclability” or “recyclable” shall encompass organic recycling. 2. The Essential Requirements for biodegradable and compostable plastic packaging The suggested idea to fix by law what could be done with compostable plastics in the absence of health and safety reasons represents a discrimination for these class of materials and would potentially have a negative impact on both innovation and employment in Europe. Regarding the current Essential Requirements, we would suggest rationalizing the two categories (Packaging recoverable in the form of composting and Biodegradable packaging) by merging the two requirements, which would help to avoid confusion between biodegradable and compostable.
…packaging) by merging the two requirements, which would help to avoid confusion between biodegradable and compostable. 3. Revision of the standard EN 13432 “Requirements for packaging recoverable through composting and biodegradation” On the revision of the standard EN 13432, it should be duly noted that after 20 years and being confirmed in three systematic reviews (2005,2010, and 2015), the standard has proved to be a valid test scheme with robust evaluation criteria for the organic recycling of compostable packaging. While we would welcome the idea of an update/revision of the EN 13432, we fail to grasp the sense generic statements – reported in the consultation – such as “ensure actual composting conditions are taken into account”. It goes without saying that when the technical standards are reviewed, they are subjected to analysis to verify their adequacy with respect to any…