European Carton Makers Association

…14 April 2023 ECMA feedback on the Packaging & Packaging Waste Regulation proposal The European Carton Makers Association (ECMA) welcome the Commission’s ambition to contribute to a climate neutral circular economy through the proposal for a Packaging and Packaging Waste Regulation (PPWR). The new legislation should also ensure that proposed measures meet the primary objective “to reduce the negative environmental impacts of packaging and packaging waste, while improving the functioning of the internal market”. There are several overarching issues with the proposal. Firstly, the harmonization achieved by switching from a Directive to a Regulation may be jeopardized by allowing Member States to go beyond the requirements.

…from a Directive to a Regulation may be jeopardized by allowing Member States to go beyond the requirements. This measure undermines the internal market legal basis, significantly complicates implementation, and challenges the basic principle of a regulation set by Article 288 of the Treaty for the Functioning of the European Union (TFEU)1. Secondly, the huge number of delegated acts expected should be reconsidered as they will create regulatory uncertainty and risk not taking stakeholder expertise in account. Finally, ECMA supports the introduction of harmonised labelling requirements but suggests that these be aligned with existing product legislation; for example, the rules for tobacco packaging and medicine packaging are defined in specific laws for those products2.

…for example, the rules for tobacco packaging and medicine packaging are defined in specific laws for those products2. ECMA would also like to emphasize specific key aspects in the proposal that require further discussion and elaboration and recommends the following: Recyclability requirements should be aligned with the Design for Recycling criteria and set recycling rates The PPWR proposal sets clear recyclability requirements and suggests that Design for Recycling criteria are established for specific types of packaging, as listed in Annex II, Table 1. In the case of paper and board, two different types of paper & board packaging are identified: Paper/Cardboard packaging and composite packaging of which the majority is paper/cardboard. However, the recycling rates in Article 46 of the proposal for specific materials are set for paper & cardboard only.

However, the recycling rates in Article 46 of the proposal for specific materials are set for paper & cardboard only. ECMA recommends using the approach provided by Article 46 also for the assessment of the recyclability requirements (Annex II, Table 1) and for data collection (Annex XII, Table 4), including recycling at a scale where the evaluation is made for all paper & board packaging being 1 Art. 288 TFEU - A regulation shall have general application. It shall be binding in its entirety and directly applicable in all Member States. 2 The Tobacco Products Directive 2014/40/EU concerns the manufacture, presentation and sale of tobacco and related products. Directive 2001/83/EC and Regulation (EC) No 726/2004 include harmonised provisions for the manufacture, wholesale or advertising of medicinal products for human use, among other legislation.

…provisions for the manufacture, wholesale or advertising of medicinal products for human use, among other legislation. • Recyclability requirements should be aligned with the Design for Recycling criteria and set recycling rates. • Market restrictions should be evaluated to ensure they do not increase negative environmental impact and food waste. • Reuse targets should be realistic and positive for the environment, society, and economy following science-based policy making. • Mandatory recycled content should be set only for plastic packaging, according to the Circular Economy Action Plan. Ref. Ares(2023)2751559 - 18/04/2023 recycled at Union level. This will allow for harmonized implementation and assessment across industry sectors and Member States and is also in line with the definition on “recycled at scale” according to Article 3(32).

…and Member States and is also in line with the definition on “recycled at scale” according to Article 3(32). While the proposal addresses key issues related to recyclability, it does not regulate an essential step to increase recycling: collection. In order for recycling rates to improve, separate and effective collection of packaging is a logical prerequisite. The regulation should address the need for efficient collection systems in Member States to facilitate the achievement of the established recycling targets. Market restrictions should be evaluated to ensure they do not increase negative environmental impact and food waste Measures on packaging prevention, including market restrictions, should be meaningful, achievable, and support the overall objectives of the EU Green Deal and Circular Economy.

…should be meaningful, achievable, and support the overall objectives of the EU Green Deal and Circular Economy. Banning single use packaging for fruits and vegetables (containing less than 1,5kg) and single-use packaging in the HORECA sector, as suggested in points 2, 3 and 4 of Annex V, could be counterproductive for the economy and the environment. All packaging is created with a purpose to protect, preserve, and promote a product. The loss or damage of a product has a higher environmental impact compared to the savings achieved by reducing the packaging itself, in terms of resources used and emissions created. For packed food products, packaging only makes up 3-3.5% of the carbon footprint3.

…used and emissions created. For packed food products, packaging only makes up 3-3.5% of the carbon footprint3. Therefore, if the market restrictions result in packaging removal or minimisation, leading to increased bulk packaging, the resulting damaged food will increase food waste and worsen environmental impacts. If reusable systems are implemented instead, then the environmental impact of the water usage required for cleaning processes must also be taken into consideration. Additionally, single-use packaging helps ensure that hygiene and food safety standards are met by food packaging. Reusable packaging for fruits and vegetables, on the other hand, brings increasingly complex logistic challenges related to transport, sanitation, and storage. If not effectively implemented, these systems can spread contamination, leading to increased food waste and food safety issues.

…these systems can spread contamination, leading to increased food waste and food safety issues. Reuse targets should be realistic and positive for the environment, society, and economy following science-based policy making According to the Impact Assessment, “The general objective of the legislative proposal is to reduce negative environmental impacts of packaging and packaging waste and improve the functioning of the internal market, thus boosting efficiency gains in the sector”. The reuse targets in the PPWR proposal risk compromising this objective and undermining the Circular Economy Action Plan’s intention to make packaging recyclable or reusable by 2030. The suggested high reuse targets will result in the substitution of paper & board with plastic packaging, for which recycling is already challenging.

…will result in the substitution of paper & board with plastic packaging, for which recycling is already challenging. This risks flooding the market with millions of tons of plastic packaging, giving plastic a disproportionate advantage, and increasing the EU’s dependency on imported fossil resources. This ultimately fails to fulfil the main objective of the PPWR proposal and harms the competitiveness of the internal market. 3 guideline_stopwastesavefood_en_220520.pdf (denkstatt.eu) In addition, effective reuse systems can only be achieved with high level of standardization of packaging formats, which ignores innovation and limits competition. Standardized packaging also risks increasing overpackaging, directly contradicting the Commission’s ambition to limit excessive packaging.

…also risks increasing overpackaging, directly contradicting the Commission’s ambition to limit excessive packaging. Reuse systems also require more logistics, transport, washing, etc., which will significantly increase emissions, water and chemical usage and overall environmental impact. Existing studies indicate that reuse has higher environmental impact compared to recyclable packaging for certain studied applications4. Therefore, reuse systems can only be part of the circular solution5. While other studies deny this, the reality shows that reuse systems have not worked in practice6 and do not always provide the expected environmental benefits. Reuse targets that do not take into account existing scientific evidence will fail to support the EU’s green ambitions.

Reuse targets that do not take into account existing scientific evidence will fail to support the EU’s green ambitions. ECMA therefore recommends that recycling and reuse act as complementary measures following science-based policy making and life cycle thinking. Mandatory recycled content should be set only for plastic packaging, according to the Circular Economy Action Plan The Circular Economy Action Plan states that “to increase uptake of recycled plastics and contribute to the more sustainable use of plastics, the Commission will propose mandatory requirements for recycled content and waste reduction measures for key products such as packaging, construction materials and vehicles”. Based on this call to increase the amount of recycled plastic, Article 7 of the PPWR should only establish recycling content requirements for plastic packaging, not the ‘plastic part in packaging’.

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Feedback to the EU Roadmap on the initiative “Review of the requirements for packaging and other measures to prevent packaging waste” ECMA supports the Commission’s ambition to contribute to the circular economy through the review of the requirements for packaging and packaging waste. The review should also ensure that the proposed preventive measures will support the functioning of the internal market for packaging and packaged goods while preventing the possible negative impact on the environment. • Measures on packaging prevention should be meaningful, achievable, and support the overall objectives of the EU Green Deal and Circular Economy. • EU legislation should be focused on supporting paperboard packaging to become the primary functional pack format.

• EU legislation should be focused on supporting paperboard packaging to become the primary functional pack format. The material is already circular and through targeted investment and further development, its use could be extended to other market and product applications that are currently reliant on materials that are not renewable or widely recycled • Paper & board packaging is the most recycled packaging in Europe with an 85% recycling rate (according to Eurostat). There is real economic demand for recycled paper as a secondary raw material, allowing the fibres to remain in the economy as a valuable resource and be used for new packaging, but further support for improved waste separation and collection systems is needed. The separated waste stream would provide a new high-grade recycled material with wider applications.

…systems is needed. The separated waste stream would provide a new high-grade recycled material with wider applications. • We support setting a practical and enforceable definition of “recyclable” packaging. Such definition should focus on Design for high quality recycling. The paper & board sector already incorporates eco-design to ensure that packaging is recyclable and recycled in practice. In addition, we also support an eco-modulated harmonized EPR system to incentivize more easily recycled packaging. • We support the reduction of “overpackaging” and “underpackaging”. Packaging “fit for purpose” can lead to packaging waste prevention and should be introduced as a new measure for all packaging.

“fit for purpose” can lead to packaging waste prevention and should be introduced as a new measure for all packaging. This will ensure that every packaging item is designed to fit the product exactly with minimum void space and a specification linked to the product shelf-life, for example, a paper overwrap for short shelf-life products such as fresh fruit and vegetables rather than a non-recyclable film with a life expectancy of many years. This would help prevent overpackaging and underpackaging and the related unnecessary waste and losses. • Setting an “overall packaging waste reduction target or waste generation limit” with the aim of reducing the volume or weight of packaging waste will be counterproductive to the economy as a whole and have a higher impact on the environment.

…of packaging waste will be counterproductive to the economy as a whole and have a higher impact on the environment. o An unintended consequence of a weight reduction target will be to favour the use of other non-renewable materials, that are not circular, over paperboard. o Well designed, efficiently produced, appropriately used and responsibly recycled packaging provides multiple benefits – it minimises damage to products, extends their useful life, facilitates efficient distribution, gives safe and convenient access to goods and communicates vital information to the consumer. Ref. Ares(2020)3978055 - 28/07/2020 • Single use packaging as a format includes packaging made from different materials, which do not pose the same threat to the environment and the oceans and should not be regulated as one single category.

…do not pose the same threat to the environment and the oceans and should not be regulated as one single category. Recyclable, single use packaging made from renewable materials, such as paperboard, should be excluded from such restrictions. Paper-based single use packaging has clear hygienic advantages when it comes to food and consumer safety and is essential for the overall sustainability of the food system, as it was also recently proved by the COVID-19 crisis. • Future measures on reuse should consider all environmental, health and economic impacts of reuse systems throughout the life cycle of the product and packaging. Setting reuse targets for “transport packaging” as a format risks including packaging which is already being recycled at a very high rate and thus jeopardizing a well- functioning and circular system.

…is already being recycled at a very high rate and thus jeopardizing a well- functioning and circular system. • Measures to promote recycled content should target sectors where the market’s for secondary raw materials are not developed yet. The market for recycled paper is already well-developed – as shown by the high recycling rate. Support for the further development of high-quality fibre separation to produce high-grade recycled fibre materials suitable for food applications would be welcome– measures on recycled content are unnecessary and may have unintended impact disturbing the functioning recycling system. • Consumer surveys consistently show consumers prefer fibre packaging with regards to its sustainability, usability and practicality – 81% would choose cartonboard packaging.

…packaging with regards to its sustainability, usability and practicality – 81% would choose cartonboard packaging. Support to further develop the functional properties of paperboard to provide an effective barrier for gases, moisture, aromas etc would extend its use to other applications. The Hague, 28 July 2020.

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Pro Carton ECMA T: +43 664 852 74 58 T: +44 7789 397615 [email protected] [email protected] Brussels, Jan 2026 ECMA and PRO CARTON Position on the draft Delegated Act establishing exemptions from the PPWR’s reuse obligations for wrappings and straps We propose the following amendment to Article 1 of the draft Delegated Act: “Exemption concerning pallet wrappings and straps Economic operators that use pallet wrappings or straps for stabilisation and protection of products put on pallets during transport are exempted from the 100% reuse requirements of these packaging formats established in Article 29(1), Article 29(2) and (3) of Regulation (EU) 2025/40.” Detailed explanation: A comprehensive exemption for pallet wrappings and straps represents the most effective and pragmatic policy choice.

…comprehensive exemption for pallet wrappings and straps represents the most effective and pragmatic policy choice. It safeguards product integrity, hygiene, and worker safety while maintaining cost-competitive supply chains across Europe. This approach aligns with the overarching goals of the PPWR without disproportionate burdens on economic operators. Our sector has already undertaken significant investments to ensure timely compliance with PPWR obligations, reflecting our strong support for the legislation’s objective. While we welcome the aim of the draft Delegated Act, which seeks to establish partial exemptions from the PPWR’s reuse obligations for wrappings and straps, the current proposal does not fully account for the operational impracticality of reuse for straps and wrappings.

…the current proposal does not fully account for the operational impracticality of reuse for straps and wrappings. Reuse targets on wrappings and straps – economically and technically unfeasible In our understanding, Article 1 of the draft Delegated Act introduces exemptions from the obligations set out in Article 29, paragraphs 2 and 3 of the PPWR, while leaving unchanged the requirements under Article 29, paragraph 1, which establishes a 40% reuse target by 2030 for pallet wrappings and straps for stabilisation and protection of products put on pallets during transport. In our view, applying a 40% reuse target to pallet stabilisation wrappings, films, and straps is disproportionate and fails to reflect the essential role these components play in ensuring product integrity and transport safety.

…fails to reflect the essential role these components play in ensuring product integrity and transport safety. As recognised in the draft Delegated Act, automated solutions for reusable packaging are not sufficiently developed yet. Imposing reuse targets on pallet wrappings and straps would disproportionately disadvantage operators and in particular SMEs and operators with limited capacity to redesign packaging lines, implement pooling systems and deploy tracking infrastructure. Furthermore, for companies importing goods from non-EU countries or geographically remote locations, reuse obligations would impose substantial costs and operational challenges (e.g., in view of the need to send back the pallet wrappings and straps). The feasibility of returning packaging is Ref.

…in view of the need to send back the pallet wrappings and straps). The feasibility of returning packaging is Ref. Ares(2026)233098 - 09/01/2026 Pro Carton ECMA T: +43 664 852 74 58 T: +44 7789 397615 [email protected] [email protected] extremely limited, and implementing such changes would require a complete overhaul of logistics systems, including reverse flows and servicing for new stabilisation components. Furthermore, while Article 1 of the draft Delegated Act introduces flexibility, it does not address the reuse targets set out in Article 29, paragraph 1 of the PPWR. This provision fails to reflect real-world operational conditions. Indeed, in proportion, straps and wrappings represent a very high share of the packaging units operators must use during their daily operations, making compliance with a 40% reuse ratio for these formats virtually impossible in practice.

…their daily operations, making compliance with a 40% reuse ratio for these formats virtually impossible in practice. Exemption applicable to all materials ECMA and Pro Carton support an exemption for all materials as proposed in this draft. The selection of pallet wrapping solutions exempt from reuse targets must remain dependent on logistical, environmental, and transport conditions. A professional responsible for product safety and hygiene is best placed to determine the most appropriate materials. An approach applicable to all materials ensures EU reuse objectives are balanced with operational realities while supporting ongoing efforts to improve recyclability and reduce plastic consumption.

…with operational realities while supporting ongoing efforts to improve recyclability and reduce plastic consumption. Pro Carton, the European Association of Carton and Cartonboard manufacturers, is a non-profit organisation representing over 42 cartonboard mills in 14 different European countries and North America, supplying more than 90% of Europe’s demand, as well as the carton converting industry across Europe. ECMA, The European Carton Makers Association is the international network of folding carton organisations; carton businesses, national carton associations and suppliers to the carton industry.

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…1 Feedback to the European Commission public consultation “Review of the requirements for packaging and other measures to prevent packaging waste” The undersigned associations support the Commission’s ambition to contribute to the circular economy through the review of the requirements for packaging and packaging waste. A future-proof Packaging and Packaging Waste Directive (PPWD) should take an outcome-based approach to enable that all packaging is recyclable or reusable and low-carbon. This should be done by setting ambitious and clear goals, while safeguarding the well-functioning of the Internal Market and enabling industry to innovate.

…and clear goals, while safeguarding the well-functioning of the Internal Market and enabling industry to innovate. The revised PPWD should be based on a set of principles and objectives which achieve the following: • Set goals to support separate collection, sorting and recycling and waste reduction with a focus on reducing residual waste that is not recycled or reused. • Provide clear definitions for the concepts and terms referred to (e.g. recyclable packaging, reusable packaging); • Support the EU’s transition towards a strategic resource autonomy, which reduces our dependency on imported materials; • Ensure a level-playing field for the packaging sector through a technology/material neutral approach and non-discrimination. Life Cycle Assessment (LCA) studies can be useful in this respect to measure environmental performance while taking into account the end of life of packaging.

…be useful in this respect to measure environmental performance while taking into account the end of life of packaging. For accurate results, LCAs should look at packaging formats in the same packaging category. • Ensure a level playing field for European producers with respect to imported packaging materials. • Ensure a stable regulatory framework for industry to invest in sustainable innovations of packaging solutions, which otherwise would not be achieved through restrictions on materials or packaging options; • Ensure the integrity and well-functioning of the EU Internal Market through clear and realistic EU requirements and legislation that foster competition. Paper and paperboard packaging is designed with a plurality of purposes, benefits and functions.

…foster competition. Paper and paperboard packaging is designed with a plurality of purposes, benefits and functions. To this extent, the revised Essential Requirements for packaging in the upcoming PPWD legislation must strike the right balance between the functionality of packaging and the objectives of packaging circularity and waste reduction, and therefore, achieve the following: Ensure a level-playing field for all materials and packaging. The revised PPWD should provide objectives and targets which improve the circularity and climate impact of packaging lagging in performance in its product category, while supporting innovation in sustainable and already circular materials, such as paper packaging, and enabling the well-functioning of the EU’s Internal Market.

…and already circular materials, such as paper packaging, and enabling the well-functioning of the EU’s Internal Market. Ensure a clear, practical and enforceable definition of “recyclable” packaging, which focuses on design for high-quality recycling. High quality recycling is understood as using paper for recycling for the production of new paper-based products. The paper and board sector already incorporates eco-design to ensure that packaging is recyclable and recycled at scale. Measures to promote recycled content should be applied for target sectors where the markets for secondary raw materials are not developed yet, and be underpinned by existing market and product realities.

…markets for secondary raw materials are not developed yet, and be underpinned by existing market and product realities. Measures on recycled content should not disturb well-functioning recycling loops, such as paper and board recycling, and should be assessed based on a robust impact assessment that accounts for market conditions and existing authorisations, particularly with regard to food contact applications as food safety and hygiene should not be compromised. The market for paper for recycling is already well-developed, as shown by the high recycling rate of 84.6%1. There is a ‘real’ economic demand for recycled paper as a secondary raw material allowing the fibres to remain in the economy as a valuable resource and be used for new paper – based packaging. 1 According to Eurostat figures, https://ec.europa.eu/eurostat/databrowser/view/ten00063/default/table?lang=en Ref.

…1 According to Eurostat figures, https://ec.europa.eu/eurostat/databrowser/view/ten00063/default/table?lang=en Ref. Ares(2021)78445 - 05/01/2021 2 Furthermore, a future-proof PPWD should strike the right balance between waste prevention, reusability or recyclability of packaging, and thus: Ensure that waste prevention targets for packaging focus on the stream of residual packaging waste, i.e. waste that cannot be reused or recycled. An “overall packaging waste reduction target or waste generation limit” with the aim of reducing the volume or weight of packaging waste is counterproductive to the economy as a whole and has higher impact on the environment. A qualitative approach targeted on packaging efficiency should prevail on a purely quantitative one.

…the environment. A qualitative approach targeted on packaging efficiency should prevail on a purely quantitative one. Well designed, responsibly sourced, efficiently produced, low-carbon packaging that is appropriately used and effectively recycled provides multiple benefits – it minimises damage to products and food waste, extends their useful life, facilitates efficient distribution, gives safe and convenient access to goods and communicates vital information to the consumer. Ensure that future measures on packaging reuse take into account all environmental, health and economic impact of reuse systems throughout the life cycle of the product and packaging, assessing the different options through LCA and compared performances. End of life should be taken into account in both cases.

…the different options through LCA and compared performances. End of life should be taken into account in both cases. EU regulators should avoid setting reuse targets for “transport packaging”, as this approach would jeopardise already well-functioning recycling and circular systems by including packaging already recycled at very high rate. Address packaging waste prevention through measures underpinned by their impact on climate change, biodiversity and in light of the essential function of packaging to ensure and support resilient and sustainable supply chains. Reduce “overpackaging” by enabling packaging which is “fit for purpose”: circular packaging designed according to its functionality, which prevents product and food losses as well as packaging waste.

…packaging designed according to its functionality, which prevents product and food losses as well as packaging waste. Equally, restricting the use of specific packaging formats, like single use packaging items is an approach which does not deliver long-term benefits, nor a forward-looking solution to sustainability. Single use packaging as a format includes packaging made from different materials, with different threats to the environment and the oceans and should not be regulated as one single category. Recyclable, low-carbon single use packaging made from sustainably sourced renewable materials should be incentivised, not restricted. Single use packaging including for food contact materials has clear hygienic advantages when it comes to food and consumer safety and is essential for the overall resilience and sustainability of the food system. Brussels, 17 December 2020

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