EAACA · Trade and business associations · DE
EAACA Response to Packaging Waste The European Autoclaved Aerated Concrete Association (EAACA) welcomes the European Commission’s initiative to enhance the Construction Products Regulation and would like to thank the Commission for the opportunity to provide its views on the associated roadmap. EAACA was founded in 1988 and has members from 18 countries, operating more than 100 production sites and producing around 16 million cubic metres of autoclaved aerated concrete (AAC) annually. Firstly, we would like to stress that we appreciate and commend the Commission’s ongoing efforts to review requirements for packaging and other measures to prevent packaging waste.
…the Commission’s ongoing efforts to review requirements for packaging and other measures to prevent packaging waste. We agree that there would seem to be a mix of drivers that have contributed to the overall increase including growing per capita consumption, with a shift from reusable towards single-use and disposable packaging, growing online sales as well as the often still over packaging for goods. We note that you state that it has been calculated that design improvement could halve the cost of recycling plastic packaging waste. In common with many other products in the construction sector, we strive to reduce our packaging of products. We do, however, have to balance this with the need to protect construction materials both in transport and whilst stored on site or in depots from inclement weather. We also need to be able to identify the materials contained within the packs.
…site or in depots from inclement weather. We also need to be able to identify the materials contained within the packs. But, we do consider whether the thickness of packaging can be reduced or eliminated. In the later case, there is very little alternative apart from plastics. We support the view that it is necessary to strive for full harmonisation of rules on packaging across the internal market to preserve its integrity and allow for a smooth free movement of packaging and packaged goods. Whilst we recognise that there might be a need to have a set of policy options to include measures to amend the essential requirements to improve design for reuse and promote high quality recycling, as well as additional measures to reduce packaging waste generation, including over-packaging, we do need to be mindful of setting realistic targets.
…to reduce packaging waste generation, including over-packaging, we do need to be mindful of setting realistic targets. As we indicated above, packaging is a necessity to protect the materials within. We note that a shift towards certain reusable packaging types may require initial investments to establish reuse systems and therefore industry does need time to amend, invest and adapt. We note that there are other measures that will also be examined in the context of this initiative including requiring all packaging to be reusable or recyclable and providing an enforceable definition of ‘recyclable packaging’ and restricting the use of some packaging materials to certain applications. We do need also to consider the infrastructure for the returning and recycling of packaging materials and to how to prevent cross contamination of other materials in the returns.
…and recycling of packaging materials and to how to prevent cross contamination of other materials in the returns. We have to recognise that in some circumstances there are no alternatives to existing cost efficient packaging materials with the current state of the art knowledge. We thank the Commission in advance for its consideration and efforts and would be glad to further support this process where needed. Ref. Ares(2021)145437 - 07/01/2021