COLEAD · Trade and business associations · FR
COLEAD RESPONSE TO PUBLIC CONSULTATION ON THE EU PROPOSAL FOR A REGULATION: “REDUCING PACKAGING WASTE – REVIEW OF RULES” April 2023 The Committee Linking Entrepreneurship-Agriculture-Development (COLEAD) thanks the European Commission for the opportunity to contribute to this consultation process on behalf of our members. The purpose of the Association is to facilitate and implement all actions that, directly and/or indirectly, increase the contribution of the agricultural sector, and horticulture in particular, to the achievement of the Sustainable Development Goals (SDGs). This response from COLEAD addresses points relating to the adoption of the Regulation in the context of its potential impact on developing countries, in particular for the horticultural sector in Africa- Caribbean-Pacific (ACP) countries.
…on developing countries, in particular for the horticultural sector in Africa- Caribbean-Pacific (ACP) countries. The overall goal is to reduce poverty, improve food security and food safety, and ensure sustainable and inclusive growth by strengthening the agri-food export sector. The European Commission’s proposal is a welcome and ambitious initiative aimed at a significant reduction in packaging and packaging waste. From the perspective of the agri-food supply chain in low-and middle-income countries, for companies with sufficient capacity to adjust to new norms, the development of a Regulation that harmonises packaging rules across the EU will greatly simplify access to the market. The trend towards substituting plastic, reinforced by this proposal, may also prove beneficial to countries that are suppliers of natural materials that substitute plastic.
…this proposal, may also prove beneficial to countries that are suppliers of natural materials that substitute plastic. Nevertheless, the proposed new requirements raise concerns both for operators in low-and middle- income countries looking to export final food products, as well as for packaging manufacturers who supply the food industry in these countries. The general logic of the ‘Brussels effect’ – the raising of standards in third countries to meet compliance is rewarded by access to the lucrative EU market – will depend on the extent to which the new requirements are achievable in these countries. Specific Comments from COLEAD Packaging manufacturers in low- and middle- income countries Will packaging manufacturers have the technical expertise and resources to implement such extensive and complex rules?
…packaging manufacturers have the technical expertise and resources to implement such extensive and complex rules? Packaging manufacturers in third countries are predominantly oriented to the domestic market; will they be prepared to establish such complex systems for a minor sub-section of their customers? If local manufacturers are not able to supply according to the new rules, will export companies be forced to import packaging materials (which could then substantially increase costs)? Agri-food exports from low- and middle- income countries If costs substantially increase as a result of the new packaging requirements, it could create a barrier that prevents food businesses (and countries) from moving away from the export of raw materials towards the development of higher value processed products. Ref.
…from moving away from the export of raw materials towards the development of higher value processed products. Ref. Ares(2023)2889942 - 24/04/2023 Fresh produce (fruit and vegetable) exporters often pack food to avoid physical damage, to prevent microbiological contamination, and to increase shelf-life (and minimise waste). Packaging is also critical to maintain strict segregation between organic and conventional produce, essential to maintain organic status. Fruit and vegetable suppliers are facing a blanket ban on single-use plastic packaging, single-use composite packaging or other single- use packaging for fresh fruit and vegetables less than 1.5 kg.
…single-use composite packaging or other single- use packaging for fresh fruit and vegetables less than 1.5 kg. A more thorough analysis and definition of what constitutes ‘necessary’ and ‘unnecessary’ packaging should be undertaken to help ensure a balance between the environmental ambitions of new packaging rules, against potential implications for food safety, food waste, and continued access to the EU market by operators in low- and middle- income countries. Policy coherence for development While this proposal is a significant step forward in the EU’s pursuit of SDG 15 12.5 (to substantially reduce packaging waste generation through prevention, reduction, recycling and reuse by 2030), its contribution to food waste, as well as the social and economic aims of other SDGs, is insufficiently understood.
…its contribution to food waste, as well as the social and economic aims of other SDGs, is insufficiently understood. In the European Commission impact assessment that was conducted to accompany the proposal, limited attention is paid to the potential direct and indirect effects on development. The impact assessment document briefly indicates that “efforts will be made to mitigate possible adverse effects if need be (for example, via capacity building to ensure a better understanding of the Essential Requirements or the definition of recyclability)”. It is important to note that capacity building alone may not be sufficient to mitigate adverse impacts, in particular where new rules cause cost increases that affect the financial viability of trade.
…adverse impacts, in particular where new rules cause cost increases that affect the financial viability of trade. Ensuring that the new rules do not have negative developmental impacts requires from the EU a better understanding of the technical and organisational obstacles that will be faced by low-and middle-income countries. It may also require a level of flexibility in the implementation of the requirements in the context of least developed countries, for example in the timeframe required for transitioning to new rules. Policy-coherence for development in the context of this proposal needs to be more systematically addressed in the upcoming institutional discussions. COLEAD is a network of companies, professional organisations and experts committed to inclusive and sustainable agriculture.
…is a network of companies, professional organisations and experts committed to inclusive and sustainable agriculture. As a private sector (not-for-profit) organisation, our purpose is to support activities that aim to increase the agricultural sector’s contribution to achieving the Sustainable Development Goals. We design, manage and implement development programmes in the low and middle income countries with a specific emphasis in member countries of the Organisation of Africa, Caribbean and Pacific States (OACPS). Online and in the field, we supply technical assistance; vocational training; and support services that offer research and innovation brokerage, monitoring of regulations and standards, market insights, networks and alliances, and access to finance.