Amcor

…1 APRIL 2023 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 Position paper Summary of policy asks Article 5: requirements for substances in packaging • Amend Article 5 to void duplication with existing chemicals and food safety EU legislation by referencing “substances of concern that pose an environmental risk” in Article 5(1) and offering clarity of what the “minimisation” requirement entails. Article 6: packaging recyclability • EU design for recycling criteria developed by the European Commission should cover all technicalities referring to the packaging type assessed. In this respect, there is no need for an additional negative list or description of design for recycling parameters in the Annexes of the PPWR.

…no need for an additional negative list or description of design for recycling parameters in the Annexes of the PPWR. • Annex II Table 2: Grades A – E should be linked to the compatibility of the packaging type with the design- for-recycling EU criteria (e.g. A = highest compatibility, B = high – medium compatibility, C = medium compatibility, D = medium – low compatibility, E = lowest / no compatibility). • EPR fees should be eco-modulated based on recyclability only. Article 7: recycled content targets for plastic packaging • Focus the scope of Article 7(1) on plastic packaging and as an average on the portfolio placed on the market by producers. • Remove the mandate of the 2040 recycled content targets for plastic packaging, instead ensuring they are either set as aspirational or at a later stage based on robust data and a mature EU market for secondary raw materials.

…either set as aspirational or at a later stage based on robust data and a mature EU market for secondary raw materials. Article 8: compostable packaging • Remove the letter (g) from the scope of Article 8(1) and enable the correct labelling of compostable packaging to allow for correct consumer sorting and disposal. Article 10 and 26: reuse and refill targets • Article 26(12) should be amended to include an obligation that the majority of transport packaging used by an economic operator between its sites or between its factories and its customers is reusable. • Industrial reuse obligations should exclude pallet wrappings. • Refill at home should be recognised as reuse. Article 22: restrictions of packaging formats • Remove Article 22 and Annex V from the Packaging and Packaging Waste Regulation.

…restrictions of packaging formats • Remove Article 22 and Annex V from the Packaging and Packaging Waste Regulation. Article 38: prevention of packaging waste • Remove Article 38 (3) on prevention of packaging waste, which allows Member State to achieve the PPWR targets by a variety of measures at their discretion. Avoid imposing additional waste prevention targets without a robust impact assessment. Remove Art 45(2)(b) which allows the charging of single use packaging above alternative options. Missing principle: PPWR measures should lead to the best environmental outcome. Ref.

…above alternative options. Missing principle: PPWR measures should lead to the best environmental outcome. Ref. Ares(2023)2889454 - 24/04/2023 2 Requirements that are missing completely from the PPWR Lifecycle thinking (otherwise mandated via WFD Article 4) Despite attempting to curb packaging waste pollution and increase secondary raw materials on the EU market, the PPWR misses out on the opportunity of grounding its sustainability requirements in measures that truly deliver the best environmental outcome, based on lifecycle of product environmental footprint assessments. Measures based on product environmental footprints or lifecycle assessments are already foreseen in EU proposed legislation on product sustainability or green claims, and should be strengthened in the PPWR text.

…in EU proposed legislation on product sustainability or green claims, and should be strengthened in the PPWR text. Some of the proposed requirements of recycled content, reuse targets, or compostability fail at taking into account the results of increased GHG emissions, therefore directly contradicting the EU’s climate goals. Policy ask: Article 2 should foresee that the PPWR leads to a better environmental outcome. Substances in packaging (Article 5) We welcome the PPWR’s focus to address packaging from all sustainability points of view. We caution however that Article 5 addressing requirements of packaging does not use the correct terminology and may have significant repercussions if not re-assessed in the adoption process.

…does not use the correct terminology and may have significant repercussions if not re-assessed in the adoption process. Only substances of concern that pose environmental risks should be addressed by the PPWR, firstly to ensure consistency with the circularity goals of the regulation (Article 1), and secondly, to avoid regulatory confusion with the EU’s food product safety and chemicals legislation which already regulate the presence of substances in packaging from a chemical safety and human health point of view. The compliance obligations advanced by this article fail to account for the documentation and information needed to be transmitted throughout the supply chain, for example documentation related to raw materials purchased by suppliers. We ask that this is also rectified.

…chain, for example documentation related to raw materials purchased by suppliers. We ask that this is also rectified. It should be clarified what it means to ‘minimise’ the presence and concentration of substances of concern, firstly by clarifying that the substances of concern that pose environmental concerns should be minimised. A workable minimisation requirement should refer to an environmental impact “as low as reasonably achievable”. Policy ask: Amend Article 5 to void duplication with existing chemicals and food safety EU legislation by referencing “substances of concern that pose an environmental risk” in Article 5(1) and offering clarity of what the “minimisation” requirement entails. Recyclable packaging (Article 6) a.

Article 5(1) and offering clarity of what the “minimisation” requirement entails. Recyclable packaging (Article 6) a. 2030 recyclability of packaging (by design): concrete deadlines and use of industry design guidelines Amcor strongly welcomes the focus of the proposal on design for recycling and the approach to develop design for recycling EU criteria which would demonstrate packaging recyclability in 2030 and beyond. We feel however that the lack of concrete deadlines for the European Commission to adopt secondary legislation in this respect continues the legal uncertainty borne by the EU packaging value chain industry and would delay achieving the recycling targets of the PPWD and PPWR. Therefore, we recommend EU policy makers to introduce 1 January 2026 as the deadline for the adoption of EU design for recycling criteria under Article 6 paragraph 4.

January 2026 as the deadline for the adoption of EU design for recycling criteria under Article 6 paragraph 4. Furthermore, we note that industry design-for-recycling guidelines are not represented as a source for the European Commission to proceed with the adoption of the EU design criteria for packaging types. This is a missed opportunity as industry design for recycling guidelines (1) have been widely developed and consolidated, in the case of flexible packaging, by aligning the various stakeholders of the EU flexible packaging value chain (e.g. CEFLEX, 4EG design guidelines) and (2) will support EU policy makers in the swift and timely adoption of delegated acts setting out EU design criteria by the deadline of 2030.

…makers in the swift and timely adoption of delegated acts setting out EU design criteria by the deadline of 2030. EU design-for-recycling criteria should be specific to the packaging category, based on publicly available evidence and testing, and cover specific packaging components and constituents. 3 We encourage the European Commission to revert to a hybrid process, whereby industry guidelines or harmonised EU standards on packaging design are approved via the delegated acts. Where such industry DfR guidelines or CEN/CENELEC standards do not exist, these should be developed by the European Commission, together with the support of industry experts in a transparent manner, for example, a Packaging Forum, ahead of 2030.

…with the support of industry experts in a transparent manner, for example, a Packaging Forum, ahead of 2030. Policy ask: Amend Article 6(4) to include a deadline of December 31, 2025, for the adoption of the delegated acts by the European Commission establishing design for recycling criteria for the packaging types, categories and materials in Annex II. EU design for recycling criteria developed by the European Commission should cover all technicalities referring to the packaging type assessed. In this respect, there is no need for an additional negative list or description of design for recycling parameters in the Annexes of the PPWR. b.

50 → 12

originalus šaltinis (PDF) ↗