JRAIA · Trade and business associations · JP
日冷工2023 第74 号 1 24th April, 2023 JRAIA’s comments on the Proposal for a Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) representing manufacturers of refrigeration and air conditioning equipment in Japan, and its member companies are committed to maintaining and improving living standards by providing environmentally sustainable refrigeration and air conditioning products/services for human comfort and industrial processes. JRAIA supports the Commission's proposal to repeal the existing EU Packaging Waste Directive and to renew the regulation on “packaging and packaging waste” as a legislative act. We believe that this revision will explicitly limit Member State-specific…
Circular Economy Action Plan. We deeply appreciate the Commission to take our comment below for further consideration; 1. Packaging Materials for Refrigeration, Air Conditioning and Heat Pump Equipment (RACHP) and Auxiliary Equipment Products such as RACHP and their auxiliary equipment (such as remote controllers) should be distinguished from so-called shopping bags and packaging materials that are disposed of by consumers as household waste. We strongly believe that these items should not be regulated by the same requirement, as the packaging materials for these items are collected and disposed generally by installers rather than consumers. We believe that marking requirements for B2C products and provision of information for proper disposal for general consumers, as required in certain countries, are not necessary. Requirements such as subscription to recycling schemes should also…
Product characteristics and weight should also be considered, which cannot be addressed by the same requirement. 2. Article 4 (Free movement) JRAIA supports Commission’s proposal of Point 3 “Member States shall not prohibit, restrict or impede the placing on the market of packaging that complies with the labelling and information requirements set out in Article 11 of this Regulation”. Currently, some Member States require country-specific labelling requirements, which manufacturers are struggling to deal with. We would like to propose that the new Regulation should specifically state that these country-specific requirements are eliminated and that labelling requirements are fully harmonized within the EU level. Since manufacturers often unify their packaging designs worldwide, we would also like to request that the labelling requirements for non- EU markets be exempted as long as they…
…be exempted as long as they do not conflict with this Regulation. Ref. Ares(2023)2877079 - 24/04/2023 日冷工2023 第74 号 2 3. Article 13 (Obligations of manufacturers) Article 13 states “Before placing packaging on the market, manufacturers shall carry out the relevant conformity assessment procedure referred to in Article 33 and draw up to keep the technical documentation”. However, JRAIA believes that this requirement should be withdrawn as we consider it to be excessive for the following reasons; ・ Article 5(Requirements for substances in packaging) The provisions required by the Packaging Waste Directive to date have allowed for operation without the preparation of technical documentation. It is therefore considered sufficient to stipulate compliance with the existing REACH and CLP regulations.
It is therefore considered sufficient to stipulate compliance with the existing REACH and CLP regulations. ・ Article 9 (Packaging minimization) The packaging of machinery including RACHP equipment and electrical and electronic equipment including remote controllers are intended to protect the product during transport, and maximum effort has been taken for downsizing the weight of packaging materials to reduce transport costs. The obligation for technical documentation and evaluation for individual packaging will become excessive burden on operators. In order to make the regulation more effective, the criteria and method for determining minimization require further discussion with stakeholders.
…more effective, the criteria and method for determining minimization require further discussion with stakeholders. If the Commission decide to implement the requirement non the less, a grace period of at least 24 months after the date of entry into force of this Regulation should be allowed as manufacturers require time to prepare the scheme to carry out the relevant conformity assessment procedure referred to in Article 33 and to provide the technical documentation.
…out the relevant conformity assessment procedure referred to in Article 33 and to provide the technical documentation. 4. Article 6 (Recyclable packaging) In order to sufficiently protect from damage during the transport process, specialized packaging and cushioning is required especially for precision equipment such as RACHP equipment which contain refrigerant and electrical and electronic equipment. We request to exempt such products. If the Commission were to submit a report under the Delegation as required by point 4, nine months before the end of the five-year period after the entry into force of this Regulation (by four years and three months), and then adopt delegated acts, the publication of the delegated acts would be roughly the same time of the implementation of the 'recyclable packaging' requirement set out as 1 January 2030 in the point 2 and 3 of this Article. This will…
…4.”. The other option will be to obligate the Commission to complete the delegated acts by 31 December 2026.
…in Section 4.”. The other option will be to obligate the Commission to complete the delegated acts by 31 December 2026. 5. Article 7 (Minimum recycled content in plastic packaging) Mitigation measures should be put in place for the reuse of packaging plastics in open-loop recycling, as it can be difficult to obtain information on the evidence for Article 5 (Requirements for substances in packaging) owing that several materials may be mixed during the recycling stream and become untraceable. It should be added to the Regulation that Member States, suppliers of packaging and service providers should take consideration to the commercial availability of recycled content. The plastic made from recycled content may retain impurities, and hence, it is not always suitable for using the recycled contents, especially in the case of semiconductors. JRAIA would like to request an exemption for such…
…they do not comply with Article 9 (Packaging minimisation) and Article 21 Obligation related to excessive packaging). 6. Article 11 (Labelling of packaging) This new regulation on packaging and packaging waste should harmonise with the revision of the Ecodesign Regulation currently under review. Declarations of conformity and technical documents for electrical and electronic equipment, are to be prepared in line with these two regulations, and thus it would make confusion if the definitions of the two regulations are not harmonised. 7. Article 26 (Re-use and refill targets） Reuse may negatively impact to environment due to additional transport of returned used packaging, as well as increased water and energy consumption for washing and drying. Appropriate disposal of such packaging should be considered also. 8.
…and energy consumption for washing and drying. Appropriate disposal of such packaging should be considered also. 8. Publication of the guidelines The guidelines are required to provide examples of specific measures to be taken during actual implementation. We strongly request the Commission to consider specific rules and guidelines with industry stakeholders and to harmonize with enacting subordinate regulations. Subordinate regulations, guidelines and rules should be made public as soon as possible. About JRAIA The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) was originally established in February 1949 as the Japan Refrigerating Machine Manufacturers Association which was thereafter reorganized in February 1969 to become an incorporated association and renamed as it is at present.
…was thereafter reorganized in February 1969 to become an incorporated association and renamed as it is at present. JRAIA is the industry association representing over 160 manufacturers of refrigeration and air conditioning equipment in Japan. We, the members of JRAIA, have so far been dedicated to offering quality products to the markets of EU. JRAIA aims to promote and improve production, distribution and consumption of refrigeration and air conditioning equipment and their applied products, as well as auxiliary devices and components, automatic controls and accessories and thereby contribute to the steady development of Japanese industry and the improvement in people's standard of living. For more information, please see JRAIA’s website: www.jraia.or.jp EU Transparency Register number : 857375848714-69 Email: [email protected]