Interesų grupė
ICPP - Kaiser-Friedrich-Promenade 43 - 61348 Bad Homburg v. d. Höhe - Germany T l h 49 6172 926665 il i f @i i t t i 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 We comment on the European Commission's proposal for an EU Regulation on packaging and packaging waste (COM(2022)677). With our following comments and recommendations, we would like to point out the special aspects of plastic industrial packaging (packaging used between economic operators) which, in our opinion, have not been sufficiently taken into account in some parts of the draft. You may also appreciate that the plastic industrial packaging market contains a large variety of product that may require specific treatment under the Regulation. Since these special…
…to this letter we propose certain changes to the text of the Regulation to address some of the points raised herein. 1. Minimum recycled content quotas (Article 7) It should be noted that there should be an exemption for dangerous goods, food, as well as pharma packaging with direct contact to the filling goods, as for these packaging groups there are stringent quality requirements. If recycled content in this packaging would at all be possible (after required possible further innovation and testing), it cannot be placed on the market without an appropriate approval (e.g., UN approval for Dangerous Goods or EFSA approval for food contact) including the recycled content. Under Article 7 as it now reads, all existing dangerous goods and food approvals for plastic packaging (approx.
Under Article 7 as it now reads, all existing dangerous goods and food approvals for plastic packaging (approx. 4500 dangerous goods approvals in the EU by our members alone) would need to be amended to include the use of recycled material. Only in this way will they be allowed to be placed on the market from 2030 on. A. Restrictions on recycled content: exemption required For food products, the use of recycled content in industrial plastic packaging would pose a risk for contamination. Detailed testing and likely innovation would be required to make these packaging suitable for (all) food products. Similarly, use of recycled content in existing plastic Ref. Ares(2023)2629664 - 13/04/2023 2 packaging would make it unsuitable for use with all dangerous filling goods under existing laws and regulations. B.
…would make it unsuitable for use with all dangerous filling goods under existing laws and regulations. B. Testing and new product approvals: extended time frames required Where the use of plastic packaging would be feasible for certain filling goods, for each renewal of an approval, if at all possible, several tests on different samples are necessary. This would mean a more than significantly increased effort for the testing institutes in the various Member States. Given that resources at the competent authorities as well as in the testing institutes are not sufficient to register the use of recycled plastics in all approvals before 2030, the time frame needed for the conversion of all approvals has to be considered. To harmonize the quotas and make them easier to understand, there should only be 2 different values of recycled content in plastic packaging.
…and make them easier to understand, there should only be 2 different values of recycled content in plastic packaging. Furthermore, the possibility of a compensation should be created by accepting the additional use of recycled content in other products of the same type of plastic, which can be demonstrated through mass balancing and credit methods (Average within an economic operator converting plastics). In addition to the above, it should be noted that it is expected that there will be a shortage of PCR in the market to fulfil the demand for suitable recycled content use in plastic packaging. A solution must be found to create suitable materials, and access to scarce PCR. 2. Reuse packaging (Article 26) The proposed Article 26 contains in (7), (12) and (13) explanations that transport packaging includes pails, drums, intermediate bulk containers and canisters.
(12) and (13) explanations that transport packaging includes pails, drums, intermediate bulk containers and canisters. These examples are sales packages that primarily come into direct contact with the filling goods, most of which are liquids. Although some of the packagings are generally reusable, the reuse of the packaging depends on the product filled first, especially in the case of dangerous goods packaging. For this reason, we recommend that these packaging are not used as examples of transport packaging. The proposed Article 26 also contains requirements that discriminate against plastic packaging compared to packaging made of other materials without justification. Paragraphs 12 to 13 discriminate against certain materials and formats of transport packaging. References to the avoidance of packaging waste alone are insufficient to justify reusability requirements.
…packaging. References to the avoidance of packaging waste alone are insufficient to justify reusability requirements. The ecological benefits and economic feasibility must be examined in their entirety, especially taking into account the impact of transport and cleaning as well as realistic return and circulation figures. Reusable systems should be only promoted in those segments that are expected to be highly advantageous. Based on the filling goods, a significant proportion of industrial packaging is already reconditioned and reused. This is an important part of our activity. However, the possibility of reuse depends on the filling goods, especially in the case of dangerous goods. Reconditioning companies specialized in the collection of industrial packaging are cleaning these packaging for reuse even if they will not be marked with a QR code.
…of industrial packaging are cleaning these packaging for reuse even if they will not be marked with a QR code. Classifying industrial packaging in single use or reusable packaging based on a QR Code will reduce the reuse of these packaging. We also recommend that optimised recyclable single-use packaging that is ecologically better or at least equivalent to reusable packaging can be counted towards the quotas. 3 3. Recyclability (Article 6) To minimise the quantity and quality losses in recycling and to achieve the most cost-efficient and high-quality recycling possible, we propose to tighten the recyclability requirements by raising the recyclability of a packaging from 70% to 80%. From 2035 onwards, the criterion "recycled at scale" according to Article 6(2)(e) becomes a market requirement.
…to 80%. From 2035 onwards, the criterion "recycled at scale" according to Article 6(2)(e) becomes a market requirement. The definition of "recycled at scale" according to Article 3(32), which is based on a coverage of at least 75% of the EU population, is not meaningfully applicable to industrial packaging, as industrial packaging is not accumulated in private households but in industrial and commercial establishments and the extent of its recycling cannot therefore be measured on the basis of a proportion of the population. We recommend that the definition of "at scale" be based on the availability of recycling facilities on an industrial scale instead of on a certain percentage of the population, following the example of the German minimum standard for determining the recyclability of packaging.
…of the population, following the example of the German minimum standard for determining the recyclability of packaging. The special features of industrial packaging must also be taken into account when defining the design-for-recycling criteria. For example, the machine-based, NIR-supported material detection that is used in sorting centres for household-related packaging does not play a role for industrial packaging. Therefore, separate design-for-recycling criteria need to be developed for industrial and consumer packaging. In addition to the development of separate criteria for the assessment of the "at scale" criterion (see last amendment proposal above), commercial and industrial packaging should be added to Table 1 Annex II of the proposal.
…amendment proposal above), commercial and industrial packaging should be added to Table 1 Annex II of the proposal. Especially in the case of industrial packaging, a separate industry sector (reconditioning) has been developing for years, which ensures that the packaging can be reused. However, these existing systems cannot meet the requirements of Annex VI. These existing reuse systems should be taken into account. Therefore, new rules for industrial packaging must be developed. Given the various concerns discussed above and uncertainties on the meaning of certain definitions and their applicability to market and products, we reserve the right to further revisit and add to comments made.
…and their applicability to market and products, we reserve the right to further revisit and add to comments made. Bad Homburg, Germany, April 13th, 2023 About ICPP Founded in 1997, ICPP International Confederation of Plastics Packaging Manufacturers is an international organization of national and regional associations of plastics packaging manufacturers. The association's commitment is to improve the frame conditions for the i i l f d d i l i k i d Annex to Cover Letter dated April 13th, 2023 ICPP – www.icpp.org - e-mail: [email protected] Initial Amendments proposed by ICPP to the draft PPWR Note: Below proposals are preliminary and may change or further comments may be added depending on meaning of definitions used. PPWR Wording suggestion Justification Scope Article 2 Scope
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