European Safety Federation

 European Safety Federation ivzw - Bavikhoofsestraat 190 - 8531 Harelbeke - Belgium [email protected] - www.eu-esf.org - T+32 56 70 11 03 VAT BE0454.000.382 – RPR Business Court Gent – Division Kortrijk EU Transparency Register number : 91447653655-65 ESF feedback to the PPWD proposal Date : 24/04/2023 The European Safety Federation welcomes the European Commission’s effort to reduce packaging waste and the foreseen requirements for increasing circularity of packaging materials. Packaging has an important role to play to deliver the Green Deal through resource efficiency and waste reduction. Our industry is committed to improve the packaging of our products, while protecting its users.

…and waste reduction. Our industry is committed to improve the packaging of our products, while protecting its users. As representative organization of the Personal Protective Equipment (PPE) sector, we wish to ensure that any further requirements on packaging will meet safety and also in some cases hygiene standards necessary for our products to keep protecting the PPE itself where needed, as well as workers using the PPE in hazardous environments. Our inputs on packaging material requirements • PPE need to fulfil safety criteria to ensure they meet health and safety standards and keep on protecting workers. Therefore, the packaging of products under the PPE Regulation (EU)2016/425 should be considered as contact sensitive plastic packaging.

…of products under the PPE Regulation (EU)2016/425 should be considered as contact sensitive plastic packaging. Below some examples on why packaging is important for the PPE performance: o PPE and hygiene concerns: as for medical devices, some PPE are used in environments where a high level of cleanliness and sterility is required (e.g. food-contact industry, pharma industry, veterinarian products industry). In addition, PPE might come into close contact with the skin, breathing tract (e.g., respirators, earplugs, gloves, etc.) so hygiene measures are important to ensure the safety of the users. o PPE and chemical reaction: the performance of some PPE can be deteriorated by chemical reactions, e.g.

…of the users. o PPE and chemical reaction: the performance of some PPE can be deteriorated by chemical reactions, e.g. filters with chemical activated carbon for respirators can react to humidity or oxygen; Polyvinyl Alcohol (PVA) gloves that dissolve in water and therefore will reduce performance under humid conditions when they are not stored in closed bags. o Some industries require clean room application for particle contamination control in manufacturing of goods (e.g., food production, electronic. manufacturing), this is also applicable to the PPE used in these environments. o PPE used in healthcare settings can be dual function (also medical device).

…to the PPE used in these environments. o PPE used in healthcare settings can be dual function (also medical device). • The definition of non-reusable or recyclability should be clarified: many plastic materials are considered recyclable but consumers might not have access to the right facilities, serious investments need to be in place to develop new recycling facilities. Ref. Ares(2023)2873519 - 24/04/2023  European Safety Federation ivzw - Bavikhoofsestraat 190 - 8531 Harelbeke - Belgium [email protected] - www.eu-esf.org - T+32 56 70 11 03 VAT BE0454.000.382 – RPR Business Court Gent – Division Kortrijk EU Transparency Register number : 91447653655-65 • The scope and definition of transport packaging needs clarification, e.g.

Register number : 91447653655-65 • The scope and definition of transport packaging needs clarification, e.g. if it includes internal packaging only used within the company itself for example, to transport the product to a site, to store it or to protect it temporarily. And if so which ones. Our inputs on packaging size and weight requirements PPE packaging requirements should consider PPE rules on safety and mandatory technical documentation, here below some examples: • In the EU, PPE are currently sold with printed user instructions, which might greatly impact on packaging size and on the weight (especially if we are thinking of smaller products such as ear-plugs). The size of the packaging is not only about the product, but also the compulsory printed user instructions have to be taken into account.

…is not only about the product, but also the compulsory printed user instructions have to be taken into account. • Sterility and safety often mean double packaging, and some PPE need to be packed individually such as for example when being sold in retail to consumers or for protective gloves that are to be used in food-contact environments. • When reducing empty space to a minimum, legislators should count as empty space the void inside products (e.g. safety footwear, helmets) though it could be filled with paper or other material which could be perceived as empty space. • Packaging reduction measures should consider the space for mandatory marking and labels. Our inputs on packaging label requirements We welcome the proposal to harmonize labelling requirements for packaging, essential to minimize internal market fragmentation.

…the proposal to harmonize labelling requirements for packaging, essential to minimize internal market fragmentation. We would also recommend the following measures to further strengthen harmonization: • The EU harmonized label should prevail over any national labelling rules (currently existing, but also future ones); any secondary legislations regulating this aspect should be prioritized to help industry to meet label requirements while maintaining the single market principles. • Secondary legislation should also set up a harmonised EU EPR symbol to avoid the proliferation of local EPR symbols and ultimately help consumers and industries to identify, understand and consistently use it. • Harmonised approach on reporting on recycled content should be in place.

…understand and consistently use it. • Harmonised approach on reporting on recycled content should be in place. • Provide a longer transition period and implementation timelines to avoid the destruction of existing packaging (including packed products in stocks at different stages in the supply chain). • Consider fostering the use of harmonised pictograms and reducing wording on packaging.  European Safety Federation ivzw - Bavikhoofsestraat 190 - 8531 Harelbeke - Belgium [email protected] - www.eu-esf.org - T+32 56 70 11 03 VAT BE0454.000.382 – RPR Business Court Gent – Division Kortrijk EU Transparency Register number : 91447653655-65 More info about ESF: The European Safety Federation (ESF) was founded in 1991.

Register number : 91447653655-65 More info about ESF: The European Safety Federation (ESF) was founded in 1991. National organisations each representing the manufacturers and suppliers of PPE (Personal Protective Equipment) in their country decided to group and unite the European manufacturers, importers, distributors and service providers of Personal Protective Equipment (PPE) and to represent them at government level of the European Union and other European institutions and instances. Today, ESF represents over 600 companies (over 75% are SME), which have over 50.000 employees. The effective and cooperative members of ESF and the enterprises that affiliated to the national federations are dedicated and committed to provide compliant CE certified and high quality PPE.

…to the national federations are dedicated and committed to provide compliant CE certified and high quality PPE. Moreover, they link quality and service by giving expert advice and assistance in the process of risk assessment and analysis as well as training and advice in all aspects related to PPE. Supporting a safety conscious way of life is a common interest to all of us. As each of the 450 million EU citizens (be it as employee, as self-employed or in his/her free time) uses PPE to protect him/her against risks for his/her health or safety, the ESF members have an essential role in the protection of the population.

originalus šaltinis (PDF) ↗

 European Safety Federation ivzw - Bavikhoofsestraat 190 - 8531 Harelbeke - Belgium [email protected] - www.eu-esf.org - T+32 56 70 11 03 VAT BE0454.000.382 – RPR Business Court Gent – Division Kortrijk EU Transparency Register number : 91447653655-65 Contribution to consultation on Revision of the Union Customs Code Date : 19/09/2022 The European Safety Federation (ESF) welcomes the opportunity to share some thoughts on a possible revision of the Union Customs Code. We represent the suppliers of Personal Protective Equipment (PPE), mainly for professional use, on the European level. As such, we experience some issues with the current existing codes : - The codes do not reflect the state-of-the-art products. An example is safety footwear. The codes include safety footwear with steel toecaps.

…the state-of-the-art products. An example is safety footwear. The codes include safety footwear with steel toecaps. However, in reality, steel toecaps are not the only solution anymore to provide protection for the wearer of the footwear. But for safety footwear with toecaps made of other materials, there is no specific code, so they are declared as different types of footwear depending on the style. This way it is impossible to have data on import/export (or even EU production) volumes of these products. - The COVID crisis showed also the limits of the codes. At some point it was the intention of the EU Commission to control the exports of certain types of PPE that were essential in the protection against the virus. The published text did not contain custom codes, but of course, in order to be practical for custom authorities, custom codes were provided in guidance.

…custom codes, but of course, in order to be practical for custom authorities, custom codes were provided in guidance. But as the custom codes are not at all specific enough, PPE suppliers were confronted with additional burdens to be able to export PPE that were not at all relevant for the pandemic. For instance diving suits were blocked, or specific chemical suits that were not at all aimed in the measures. But those products happen to use the same custom code as PPE that were intended to be limited. - Adequate data on imports/exports/production of specific types of PPE are impossible to get as the custom codes are not specific enough. For instance during the COVID crisis it was impossible to have an idea of the volumes of imports of FFP masks or medical masks as the codes are not adequate for that purpose.

…to have an idea of the volumes of imports of FFP masks or medical masks as the codes are not adequate for that purpose. - With the growing importance of sustainability (including information for waste recycling), adequate custom codes should play an essential role in data collection, necessary to organise effective management of material streams. However, the current codes do not allow this, and might even give a completely wrong impression of volumes. - For customs authorities it is not always clear to which legislation they should check products. This is certainly cause of allowing non-compliant products into the EU market as not checked to the correct legislation. But also makes the reporting of non-compliant products ineffective and possibly incorrect. Ref.

…correct legislation. But also makes the reporting of non-compliant products ineffective and possibly incorrect. Ref. Ares(2022)6463253 - 19/09/2022  European Safety Federation ivzw - Bavikhoofsestraat 190 - 8531 Harelbeke - Belgium [email protected] - www.eu-esf.org - T+32 56 70 11 03 VAT BE0454.000.382 – RPR Business Court Gent – Division Kortrijk EU Transparency Register number : 91447653655-65 Therefore, we suggest to revise the custom codes for PPE (and most likely the same is valid for other types of products). Linking custom codes to product legislation (in our case PPE Regulation (EU)2016/425) would be a step forward to improve the system. Careful considerations, in collaboration with the sector, on the specific codes is necessary, also taking into account innovations. At the same time, harmonisation of the codes globally should be the goal.

…also taking into account innovations. At the same time, harmonisation of the codes globally should be the goal. This will certainly help to make market surveillance more effective, and of course, we do not have to remind you that the primary function of PPE is to protect the health and safety of citizens. We are certainly willing and available to further discuss these points. Henk Vanhoutte Secretary General On behalf of the ESF members About ESF: The European Safety Federation (ESF) was founded in 1991. National organisations each representing the manufacturers and suppliers of PPE (Personal Protective Equipment) in their country decided to group and unite the European manufacturers, importers, distributors and service providers of PPE and to represent them at government level of the European Union and other European institutions and instances.

PPE and to represent them at government level of the European Union and other European institutions and instances. Today, ESF represents over 600 companies, of which at least 70% are SMEs. The effective and cooperative members of ESF and the enterprises that affiliated to the national federations are dedicated and committed to provide compliant CE certified and high quality PPE. Moreover, they link quality and service by giving expert advice and assistance in the process of risk assessment and analysis as well as training and advice in all aspects related to PPE. Supporting a safety conscious way of life is a common interest to all of us. As all citizens (be it as employee, as self-employed or in his/her free time) use PPE to protect him/her against risks for his/her health or safety, the ESF members have an essential role in the protection of the population.

originalus šaltinis (PDF) ↗