Interesų grupė
…x SERRED’s contribution to the European Commission’s public consultation on reducing packaging waste SERRED, the European association representing, defending and promoting the interests of industrial packaging reconditioners, welcomes the European Commission’s ambitions to reduce packaging waste via its proposal for a Packaging and Packaging Waste Regulation (PPWR). We agree with the proposal’s objective to reduce waste by promoting reuse and refill of packaging on the EU market. We fully support the aspiration to harmonise national and regional measures on packaging and the management of packaging waste via a regulation and encourage the EU institutions to strengthen the cross-border market aspect. Industrial packaging (being sales and transport packaging) can be collected, reconditioned and reused, with substantial material, energy and carbon savings compared to the recycling process.
…reconditioned and reused, with substantial material, energy and carbon savings compared to the recycling process. SERRED members are committed to contributing to a truly circular economy in the respect of the EU waste hierarchy. We recondition in an environmentally responsible way millions of drums and IBCs (intermediate bulk containers) used in industry, extending their useful lives of many cycles and recycling them when reuse is no longer possible. As negotiations in the European Parliament and the Council are starting, we wish to raise some crucial points to the attention of the Commission and EU lawmakers ● Setting a simple and clear framework for reusable industrial packaging Based on the current text of the PPWR, “(re)usable packaging in a reconditioning process is normally not considered to be waste”.
…current text of the PPWR, “(re)usable packaging in a reconditioning process is normally not considered to be waste”. This provision leaves much room for interpretation which will likely continue to lead to differences in subsequent national and regional interpretations and implementations. To ensure legal clarity and consistency with the definition of waste as of Art. 3 (60), the legislator should properly recognise that “conveying reusable packaging to reconditioning shall not be considered waste” and include such provision in Art. 24, and not just in Recital 64. ● Strengthening the EU Single Market It is essential to fully harmonise in the EU rules on reuse, notably Art. 24 and 26, to avoid a fragmented regulatory landscape affecting the cross-border circulation (countries and regions) of used packaging.
…a fragmented regulatory landscape affecting the cross-border circulation (countries and regions) of used packaging. As for now, barriers and restrictions have prevented industrial packaging for reconditioning from circulating freely on the EU market: thousands of perfectly viable drums and IBCs are written off as waste, jeopardising packaging reuse rates and environmentally friendly reconditioning across the continent. This has hampered the circularity of our industry and prevented the creation of an efficient single market in the industrial packaging sector. The PPWR needs to state clearly and unambiguously that reuse of industrial packaging should be the norm, allowing drums and IBCs in a reconditioning process to circulate freely on the internal market.
…should be the norm, allowing drums and IBCs in a reconditioning process to circulate freely on the internal market. ● Clarifying packaging labelling We understand the European Commission’s intention to introduce a label providing information on packaging reusability but the proposed QR code laid down in Art. 11 risks adding confusion. It seems to insinuate that manufacturers and/or packers/fillers will be entitled to apply such a code on packaging, resulting in excessive freedom for packers/fillers to mark perfectly reusable drums as single-use. In the upcoming negotiations, it will be important to clarify the wording of this provision to avoid inconsistencies in the application of the QR code. For instance, it will be essential to shed some light on the nature of the information provided by the code, on the operator(s) entitled to apply it and on how the QR Ref.
…on the nature of the information provided by the code, on the operator(s) entitled to apply it and on how the QR Ref. Ares(2023)2890721 - 24/04/2023 x code will work in case of extra-EU shipping. We suggest including an exemption from this QR code requirement for B2B sales and transport packaging. About SERRED Founded in 1975, SERRED is the European association representing, defending and promoting the interests of industrial packaging reconditioners. SERRED represents 22 professional reconditioners and country associations of reconditioners from 11 EU Member States (+ Norway & Switzerland), working according to the Code of Good Practice. A frontrunner of the circular economy, SERRED has a turnover of €400 million, directly employing over 3500 people, and covering about 80% of the industry.
SERRED has a turnover of €400 million, directly employing over 3500 people, and covering about 80% of the industry. There are three main product groups that SERRED members recondition, every year processing over 10 million steel drums, 2 million plastic drums and 5 million intermediate bulk containers (IBC).