FINAT · Trade and business associations · NL
The Hague, 23 April 2023 FINAT Feedback to Public Consultation on review of Packaging and Packaging Waste Directive FINAT is the European association for the self-adhesive label industry. We welcome the opportunity to provide feedback on the European Commission’s proposal to revise the Packaging and Packaging Waste Directive. Self-adhesive labels, also known as pressure-sensitive labels (PSL), play a critical economic and social role in packaging. PSL enable communication of information about packaging and its contents, provide resource-efficient functionality that reduces package complexity and waste, and enable entire supply chains by allowing tracking, tracing and security. Industries such as medical, pharmaceutical, food and beverage, logistics, as well as consumers, rely on self-adhesive labels for a well-functioning supply chain and economy. We would like to provide feedback on…
…well-functioning supply chain and economy. We would like to provide feedback on the following aspects of the proposal: 1. Definition of packaging. Article 3 (1) and subparagraphs provide a definition of packaging material, complemented by specific examples specified in Annex I. We find that these definition and examples do not provide sufficient clarity for some components and applications of self-adhesive labels: a. Release liner. An essential part of pressure-sensitive labels is the release liner, which enables the manufacturing, converting and application of labels onto packaging and products. The definition of “packaging” under Article 3 (1) and the examples in Annex I do not allow the unequivocal assessment of the status of release liner of self-adhesive labels with respect to packaging.
…not allow the unequivocal assessment of the status of release liner of self-adhesive labels with respect to packaging. The release liner turns to waste at the same time that self-adhesive labels become packaging/part of packaging, but this takes place at the manufacturer's facilities and does not reach consumers; we refer to the position papers from CELAB Europe and IRLA for more details on this specific topic. In order to provide legal certainty, and to favour the separate collection of release liner to facilitate its recycling and preserve the efficiency of other packaging recycling streams, we propose to include “release liner from self-adhesive labels” as an example of “Not packaging” under Annex I. b. Labels permanently attached to a product. Pressure-sensitive labels are in some cases attached to products to provide identification details (e.g.
…to a product. Pressure-sensitive labels are in some cases attached to products to provide identification details (e.g. VIN on vehicles, serial number on household appliances), to provide safety or usage information (e.g. recommended tyre pressure on a vehicle) or to provide required legal information (e.g. composition, energy requirements, CE marking, waste sorting information like the crossed-out wheeled bin for WEEE, identification and contact details of manufacturers, importers and other market actors, etc.). These labels are attached to the product for the complete lifetime of the product, in many cases spanning several years. In particular with regard to statutory labelling obligations, such labels have to be affixed to the product in a durable manner, so that the label cannot be removed under normal and reasonably foreseeable conditions of use.
…in a durable manner, so that the label cannot be removed under normal and reasonably foreseeable conditions of use. Thus, such labels are obviously intended to remain affixed to and be disposed together with the product in the specific waste stream. Conversely, they can be Ref. Ares(2023)2864103 - 23/04/2023 considered not to enter packaging waste streams under reasonable foreseeable conditions. In addition, because of the life cycle of these labels which result in specific technical requirements different than for packaging applications, we consider that they should not be considered packaging, but instead an integral part of the product they are attached to. As a result, we believe that the considerations of Article 3 (1) (a) and (c) are not fulfilled in these cases, and therefore these labels are not packaging. To provide explicit clarity, we propose to i.
…in these cases, and therefore these labels are not packaging. To provide explicit clarity, we propose to i. include “Labels hung directly on or attached to products that remain so during the service life of the product” as an example of “Not packaging” under Annex I, and ii. rephrase “Labels hung directly on or attached to a product including sticky labels attached to fruits and vegetables” to “Labels hung directly on or attached to a product that are intended to be removed before using the product, including sticky labels attached to fruits and vegetables”, as an item to be considered as “Packaging” under Annex I.
…including sticky labels attached to fruits and vegetables”, as an item to be considered as “Packaging” under Annex I. 2. Role of adhesives. Adhesives are polymeric materials that are used in very small amounts in final packaging, but that critically enable their function and enable the minimization of packaging. There is currently no feasible process to recycle adhesives (they are not the target of recycling process, due to the small amount they are incorporated in packaging), as there is for many other plastic materials that form the core of the weight of packaging units. The definition of plastic under Article 3 (43) refers to polymers that can function as a main structural component of packaging; this definition could be understood to include adhesives as enablers of necessary function, most likely unintendedly as adhesives are explicitly not considered plastic under the SUPD.…
…adhesives as not contributing to the “plastic part of packaging” for the calculation of recycled content in Article 7. 3. Post-consumer waste recycling. Article 7 of the proposal refers to “recycled content recovered from post-consumer plastic waste”. In this context, it is unclear whether the recovery operations allowed are limited to mechanical recycling only, or if also chemical recycling of post-consumer waste would be considered in scope. Furthermore, we consider that enabling the use of chain-of-custody mass-balance approaches for materials recovered from post-consumer waste have the potential to increase the scope of the recycled content requirements.
…recovered from post-consumer waste have the potential to increase the scope of the recycled content requirements. 4. Design for recycling guidelines. Article 6 states no clear timeline for the implementation of the guidelines but a firm entry into force by 1 January 2030, while “innovative packaging” is granted a 5-year exemption to develop DfR guidelines. Furthermore, there is no clarity in the proposal on the process to develop these guidelines and how the input from suppliers of packaging would be included. We propose to: i. define the entry into force of the Article 8 requirements 5 years after official publication of DfR guidelines; ii. request European standardisation organizations to develop harmonised standards for Design for Recycling criteria, with a clear timeline and process, and involving all relevant stakeholders; and iii. refrain from defining a negative list of packaging…
…characteristics prior to the drafting of DfR criteria taking into account state-of-the art recycling processes 5. Compostable labels for fresh produce. Article 8 mandates that labels attached to fresh produce are to be compostable 24 months after entry into force of the Regulation. While some of the materials required for this application are available, they are not (yet) produced at scale, and there are technical limitations in the development of these materials into compostable labels for application on fresh produce that make the proposed timeline difficult to achieve. Certification of multiple individual components would be necessary, but testing of compostability is extremely time demanding with individual tests requiring several months to complete. As a lack of suitable labels could cause disruptions to food supply and potentially result in food waste, we propose to postpone the…
…in food waste, we propose to postpone the timeline for this measure to at least 48 months after entry into force. 6. Conformity assessment. Article 13 places a requirement on manufacturers to demonstrate conformity of their packaging with the requirements of the Regulation. To this effect, Article 14 burdens any “supplier of packaging or packaging materials” to “provide the manufacturer with all the information and documentation necessary for the manufacturer to demonstrate the conformity of the packaging and the packaging materials”. We consider that the information to be exchanged needs to be limited to the technical requirements to demonstrate compliance with the requirements, explicitly excluding confidential or commercially sensitive information from the scope of Article 14.
…the requirements, explicitly excluding confidential or commercially sensitive information from the scope of Article 14. Furthermore, the proportionality of the requirement on small manufacturers and suppliers of packaging should be assessed: SMEs would be at a resource disadvantage to comply compared with larger economic actors. FINAT represents over 500 member companies established in more than 50 countries, covering the complete value chain of self-adhesive label industry. The label printing industry alone directly employs around 100.000 people in the EU, with a yearly revenue in the order of €14B. FINAT is committed to increasing the sustainability of the value chain and to applying circular economy principles in packaging. FINAT, The Association for the European Labelling Industry P.O.
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The Hague, 06 August 2020 FINAT Feedback on Inception Impact Assessment “Review of the requirements for packaging and other measures to prevent packaging waste” FINAT is the European association for the self-adhesive label industry. We welcome the opportunity to provide feedback on the European Commission’s initiative, “Review of the requirements for packaging and other measures to prevent packaging waste,’’ and in particular regarding updates to the essential requirements for packaging to enable greater circularity. FINAT represents over 500 member companies established in more than 50 countries, covering the complete value chain of self-adhesive label industry. The label printing industry alone directly employs around 100.000 people in the EU, with a yearly revenue in the order of €14B.
…printing industry alone directly employs around 100.000 people in the EU, with a yearly revenue in the order of €14B. FINAT is committed to increasing the sustainability of the value chain and to applying circular economy principles in packaging. Self-adhesive labels, also known as pressure-sensitive labels, play a critical economic and social role in packaging. These labels enable communication of information about packaging and its contents, provide resource-efficient functionality that eliminates package complexity and waste (a label can serve multiple purposes), and enable entire supply chains by allowing tracking, tracing and security. Industries such as medical, pharmaceutical, food and beverage, logistics, and others, as well as consumers, rely on self-adhesive labels for a well-functioning supply chain and economy. The scoping study drafted by Eunomia et al.
…on self-adhesive labels for a well-functioning supply chain and economy. The scoping study drafted by Eunomia et al. for the European Commission refers to self-adhesive labels or its components in some passages. We would like to present some details that are necessary to correctly understand the properties, use and environmental impact of self-adhesive labels. Self-adhesive materials fundamentally consist of the following components: ● Face material is the material such as paper or film (e.g., PET, PE, PP) onto which the printing is applied. The face material adheres to packaging or a product to which it is applied and can be tuned to that substrate and application. The face material is an extremely small fraction of the overall weight of the package (approximately 1% of the weight of the package) as it is typically very thin, and is designed to be removed during recycling (vide infra).
…the weight of the package) as it is typically very thin, and is designed to be removed during recycling (vide infra). ● Adhesive is part of the label construction itself and serves to bond the face material to the packaging or product. The adhesive formulation can be specifically tailored to the application, taking into account the complete life cycle of the label with the packaging or product. The industry uses adhesives with special consideration of recycling, so that adhesives are being used and continue to Ref. Ares(2020)4145279 - 06/08/2020 be developed for all relevant combinations of face and container materials. These adhesives either allow for readily detaching of the label from glass and/or plastic containers, or are repulpable in the paper and cardboard recycling process, thus facilitating the recycling of the packaging and increasing the quality of the recyclate.
…recycling process, thus facilitating the recycling of the packaging and increasing the quality of the recyclate. Formation of “stickies” of adhesives in paper recycling (as mentioned on p. 28 of the scoping study) is an issue that can be avoided by appropriate pulping conditions and choice of self-adhesive. ● Release liner is a carrier of the label face material and facilitates applying the face material to the package or product. It is typically a paper or a film (PET and PP) and coated with silicone to allow release of the face material for application to the package or product. During automated application of labels from a roll, the liner is rewound in the applicator onto a spindle, which enables its separate collection for recovery operations. Contrary to what is stated in the Eunomia scoping study (p.
…enables its separate collection for recovery operations. Contrary to what is stated in the Eunomia scoping study (p. 28), paper and polymer-based liners are recyclable and can be recycled economically. In summary, self-adhesive labels are key components that enable the circular economy of packaging materials. Applied self-adhesive labels can be readily detached from plastic and glass containers by tuning the formulation of the adhesive used. Separation of labels from the containers during the recycling process results in a higher quality recyclate than in the case of direct printing or colouring of containers. Paper labels applied onto paper/cardboard packaging are repulpable in the paper recycling process.
…of containers. Paper labels applied onto paper/cardboard packaging are repulpable in the paper recycling process. FINAT is working actively with other packaging and recycling industry associations on consistent Design for Recycling guidelines (for instance CEPI, PRE RecyClass) to ensure that these industries take full advantage of the self-adhesive label technologies that allow for, and enhance, recycling and the circular economy. We therefore request that the European Commission continues to enable the circular economy of self- adhesive labels and avoids inaccurately classifying them or their components as non-recyclable.
The Hague, 06 January 2021 FINAT Feedback on Public Consultation to inform the review of the requirements for packaging and other measures to prevent packaging waste FINAT is the European association for the self-adhesive label industry. We welcome the opportunity to provide feedback on the European Commission’s initiative to review of the requirements for packaging and other measures to prevent packaging waste, and in particular regarding updates to the essential requirements for packaging to enable greater circularity. FINAT represents over 500 member companies established in more than 50 countries, covering the complete value chain of self-adhesive label industry. The label printing industry alone directly employs around 100.000 people in the EU, with a yearly revenue in the order of €14B.
…printing industry alone directly employs around 100.000 people in the EU, with a yearly revenue in the order of €14B. FINAT is committed to increasing the sustainability of the value chain and to applying circular economy principles in packaging. Self-adhesive labels, also known as pressure-sensitive labels, play a critical economic and social role in packaging. These labels enable communication of information about packaging and its contents, provide resource-efficient functionality that eliminates package complexity and waste (a label can serve multiple purposes), and enable entire supply chains by allowing tracking, tracing and security. Industries such as medical, pharmaceutical, food and beverage, logistics, and others, as well as consumers, rely on self-adhesive labels for a well-functioning supply chain and economy. The scoping study drafted by Eunomia et al.
…on self-adhesive labels for a well-functioning supply chain and economy. The scoping study drafted by Eunomia et al. for the European Commission refers to self-adhesive labels or its components in some passages. We would like to present some details that are necessary to correctly understand the properties, use and environmental impact of self-adhesive labels. Self-adhesive materials fundamentally consist of the following components: ● Face material is the material such as paper or film (e.g., PET, PE, PP) onto which the printing is applied. The face material adheres to packaging or a product to which it is applied and can be tuned to that substrate and application. The face material is an extremely small fraction of the overall weight of the package (approximately 1% of the weight of the package) as it is typically very thin, and is designed to be removed during recycling (vide infra).
…the weight of the package) as it is typically very thin, and is designed to be removed during recycling (vide infra). ● Adhesive is part of the label construction itself and serves to bond the face material to the packaging or product. The adhesive formulation can be specifically tailored to the application, taking into account the complete life cycle of the label with the packaging or product. The industry uses adhesives with special consideration of recycling, so that adhesives are being used and continue to Ref. Ares(2021)151965 - 08/01/2021 be developed for all relevant combinations of face and container materials. These adhesives either allow for readily detaching of the label from glass and/or plastic containers, or are repulpable in the paper and cardboard recycling process, thus facilitating the recycling of the packaging and increasing the quality of the recyclate.
…recycling process, thus facilitating the recycling of the packaging and increasing the quality of the recyclate. Formation of “stickies” of adhesives in paper recycling (as mentioned on p. 28 of the scoping study) is an issue that can be avoided by appropriate pulping conditions and choice of self-adhesive. ● Release liner is a carrier of the label face material and facilitates applying the face material to the package or product. It is typically a paper or a film (PET and PP) and coated with silicone to allow release of the face material for application to the package or product. During automated application of labels from a roll, the liner is rewound in the applicator onto a spindle, which enables its separate collection for recovery operations. Contrary to what is stated in the Eunomia scoping study (p.
…enables its separate collection for recovery operations. Contrary to what is stated in the Eunomia scoping study (p. 28), paper and polymer-based liners are recyclable and can be recycled economically. CELAB (Circular Economy for Labels), a global initiative (including a European branch) to promote the economical recycling of label release liner involving the complete label value chain has been launched in October 2020. In summary, self-adhesive labels are key components that enable the circular economy of packaging materials. Applied self-adhesive labels can be readily detached from plastic and glass containers by tuning the formulation of the adhesive used. Separation of labels from the containers during the recycling process results in a higher quality recyclate than in the case of direct printing or colouring of containers.
…recycling process results in a higher quality recyclate than in the case of direct printing or colouring of containers. Paper labels applied onto paper/cardboard packaging are repulpable in the paper recycling process. FINAT is working actively with other packaging and recycling industry associations on consistent Design for Recycling guidelines (for instance EPRC, CEPI, Plastics Recyclers Europe) to ensure that these industries take full advantage of the self-adhesive label technologies that allow for, and enhance, recycling and the circular economy. We therefore request that the European Commission continues to enable the circular economy of self- adhesive labels and avoids inaccurately classifying them or their components as non-recyclable.