Trade and business associations · SE
Swedish Food federations input to Commissions proposal for packaging and packaging waste regulationLivsmedelsföretagen 849925514506 - 35 (Swedish Food Federation) is an industry an d employer organization for food companies in Sweden. The f ederation have approximately 800 members who represent all varieties of Swedish food companies; small and large with Swedish and foreign owners, family -owned, agricultural cooperatives, listed on the stock exchange and more. Livsmedelsföretagen is grateful for the opportunity to submit comments to this “Hav e you r say ” initiative . SummaryThe new packaging and packaging waste regulation needs to; ➢ Ensure that recycling and reuse are complementary options to achieve circularity of packaging. ➢ Ensure a functioning internal market for food packaging and harmonization between Member States and equal conditions for all economic operators.
…market for food packaging and harmonization between Member States and equal conditions for all economic operators. ➢ Facilitate a faster transition to a circular economy for food packaging throu gh continued support for investment in infrastructure and rapid approval of new recycling technologies so that more recycled materials are approved as food contact materials. ➢ Recognition of the investments in recycling systems already made by the industry. ➢ Ensure that there are realistic targets and transition times for a smooth and pragmatic implementation throughout the value chain and that special consideration is given to small and medium size companies' opportunities to take on the transition as these make up 99% of the food industry in the EU.
…and medium size companies' opportunities to take on the transition as these make up 99% of the food industry in the EU. ➢ The legislation needs to be consistent with other legislation that covers food packaging such as the Waste directive, Materials in contact with food and the Single -use plastics directive etc. ➢ Freedom of material choi ce to ensure sustainable investments that allow space to innovate and to compete while focusing on improved overall product environmental footprint. ➢ E ncourage and facili tate collaboration along the entire food packaging value chain.
…environmental footprint. ➢ E ncourage and facili tate collaboration along the entire food packaging value chain. Comments to the articles in the proposalArticle 3 Definitions (1) Although we elsewhere in this proposal cannot conclude that crockery that is used and reused in restaurants and cafes is covered by this proposal, we believe that the definition of packaging is not completely clear on this point as the definition includes "all materials covered”, “used to present the product” and designed and intended to be filled at the point of sale”. Article 3 § 1 (e) tries to clarify and refers to "perform a packing function" which we assume refers to § 1. However, we believe that § Ref. Ares(2023)1760974 - 10/03/2023 1 needs to be clarified to ensure that croc kery and serving dished in restaurants and cafes are not covered.
…needs to be clarified to ensure that croc kery and serving dished in restaurants and cafes are not covered. ( 1 ) (f) Here we propose that the text is changed to; Compostable coffee bags and system single - serve units or tea bags, necessary to contain a tea or coffee product and intended to be used and disposed of together wit h the product . Linked to this do we also want to see an adjustment in Annex I Beverage system capsules (e.g. coffee, cacao, milk) intended to be disposed empty after use. (28) The definition of "refill" should be broadened and i.a. include refilling bever ages at home, on the go and refilling at taps within a distributor's closed premises. There is a growing market segment where consumers fill sparkling water and soft drinks at home in reusable bottles, but there are also new formats such as powders and con centrates.
…water and soft drinks at home in reusable bottles, but there are also new formats such as powders and con centrates. In our opinion, these should be included in the targets for refill/reuse within the proposals for reuse. A broadening of the definition also provides the opportunity to include future innovations that can contribute to reaching the targets . A ca lculation model based on equivalent units would enable a transparent calculation of all reuse and refill solutions. (32) "recycle at scale" It needs to be stated in the legislation when the Commission will adopt the delegated act that will define what this will mean in practice and how it will be calculated. Ideally, we would like to see this happen in connection with the regulation coming into force.
…it will be calculated. Ideally, we would like to see this happen in connection with the regulation coming into force. It can be positive that this goal is set at Union level, but t here are challenges with this as almost all other requirements and goals are set at country level. It also does not consider whether certain types of packaging are used more or less in different countries, w ith the consequence that the development of the infrastructure for recycling is adapted to that . It may then be difficult to achieve the target if it is calculated as an average for the entire Union. (43) "plastic" This definition should be clarified by adding the text in recital 27 that packaging mater ial produced from paper pulp should not be included in the plastic definition.
…text in recital 27 that packaging mater ial produced from paper pulp should not be included in the plastic definition. As this legislation covers the same type of packaging that is also covered by the Single Use Plastics Directive, it should be made clear that polymer materials like colours, ink s and glues should not be covered by this regulation and not be included in the definition. (recital 11 in 2019/904)There is a lack of a definition of "high quality recycling". The Swedish food federation suggest that the requirements set out in Article 6 (a) -(d) are used here so that other or conflicting definitions of what this term refers to are not introduced.
(a) -(d) are used here so that other or conflicting definitions of what this term refers to are not introduced. However, it should be added in Article 6 2§ (d) that the recycled material must not only replace primary material, but the recycled material mus t principally be used in the same way as the packaging from which the recycled material comes , e.g. material in contact with food . This will ensure that circular systems are truly achieved, and that recycled material will be available to a greater extent for the packaging that is required by law to use recycled material. There is no definition "recycling rate" Article 6 § 6 ( c). Article 4 Free movementTo ensure that this regulation achieves the goal of a harmoni sed management of packaging and packa ging waste, we support paragraphs 1 - 4 and 6 in this article.
…goal of a harmoni sed management of packaging and packa ging waste, we support paragraphs 1 - 4 and 6 in this article. But we do not see it necessary to require that the extended producer responsibility schemes can be labelled as we currently do not do it in Sweden and it has been no issue . § 4 The Swedish food federation think the wording of this paragraph is good and should be retained to ensure free movement within the Union, as it appears in the current writing that no one actually need to follow the national s ustainability requirements if th ey follow the proposed packaging - and packaging waste regulation ( PPWR ) . Article 5 requirements for substances in packaging § 4 It is good that it is emphasi sed here that delegated acts linked to this legislation shall not regulate substances based on the ir chemical safety as this is regulated in other legislation.
…legislation shall not regulate substances based on the ir chemical safety as this is regulated in other legislation. Article 6 Recyclable packaging § 1 T he statement " A ll packaging shall be recyclable" is unspecified both with respect to time and to what level. This type of objective is better suited in recitles than in the legal text itself. Claiming this also puts parts of the waste hierarcy out of play and does not allow for the inclusion of necessary exce m ptions. Therefore, we propose that this sentence is removed or changed to the following to align with the following paragraph s ;All packaging shall be recyclable .
…is removed or changed to the following to align with the following paragraph s ;All packaging shall be recyclable . C onformity with this article shall be assessed based on paragraph 2 of this Article § 2Here it should be added in (d) that the recycled material must not only replace primary material, but the recycled material must principally be used in the same way as the packaging from which the recycled material comes, e.g. material in contact with food . This will help ensure that circular systems are truly achieved and that recycled material will be available to a greater extent for the packaging that is required by law to use recycled material. § 3 In paragraph 3, it is stated that recycl able packaging must meet criteria for design for recycling (DfR) from 2030. Criteria that the Commission is empowered to adopt in a delegated act.
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