Packaging and packaging waste

NOVAMONT FEEDBACK ON THE CONSULTATION ON THE REVISION ON ESSENTIAL REQUIREMENTES: FOCUS ON BIODEGRADABLE & COMPOSTABLE PLASTICS PACKAGING The review of the Packaging and Packaging Waste Directive (PPWD) in 2018 required the European Commission to examine the feasibility of reinforcing the Essential Requirements (ERs) for packaging with a view to “improving design for reuse and promoting high quality recycling, as…

In ANEC’s view, the "essential requirements" of the Packaging Directive are vague, do not give clear instructions to business and cannot be enforced. The associated CEN standards were intended to provide more detailed provisions and clarity, but the influence exerted by the European packaging industry in their drafting meant they do not contain the substantive requirements needed.

EFBW would like to share its views on the roadmap of the upcoming review of Packaging & Packaging Waste Directive (PPWD). All drink containers used by natural mineral and spring water producers, be it PET, glass or aluminium, are fully recyclable while overpackaging is absent from this sector. Our members are committed to further improving the sustainability of their packaging, by making it fully circular.

AIM, the European Brands Association, fully supports the objective of the Green Deal towards a clean, circular and climate neutral economy. Focusing on eco-design for packaging from a holistic point of view has long been a priority for branded goods manufacturers, and at the forefront of many innovative measures and R&D investments in recent years.

PepsiCo strongly supports the strengthening of the Essential Requirements and the work being done to identify measures for waste prevention as part of the revision of the Packaging and Packaging Waste Directive (PPWD). The attached note includes several elements we hope will be considered as the Commission develops a proposal for the revision of the PPWD.

Improving the essential requirements of packaging placed on the EU market to ensure that plastic packaging is reusable or recyclable is crucial to reduce the packaging waste created in the EU. We therefore warmly welcome the Commission’s initiative to assess the expected impacts of the adapted essential requirements for packaging.

BDSI welcomes the opportunity to contribute to the consultation on the Review of the requirements for packaging and other measures to prevent packaging waste. The BDSI represents the economic interests of over 200 mostly medium-sized German confectionery companies. The German confectionery industry is the fourth-largest sector of the German food industry, accounting for around 10% of overall sales.

PARC-000183-2020 Assunto: Review of the requirements for packaging and other measures to prevent packaging waste Requerente: Comissão Europeia I – GENERALIDADE É com agrado que a DECO analisou esta proposta para revisão da Diretiva 94/62/CE do Parlamento Europeu e do Conselho, de 20 de dezembro de 1994, que visa a prevenção e redução dos resíduos de embalagens.

Filed in Portuguese · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ö 1. The administrations responsible for waste management in the Länder of Berlin and Brandenburg welcome the initiative to review the requirements for packaging and packaging waste in the EU. The above objectives of promoting re-use and recycling, increasing the use of recyclates and reducing packaging waste are fully supported. Ö 2.

Filed in German · English published by the European Commission

EUROPEN - The European Organization for Packaging and the Environment - supports the general objective for the revision of the Packaging and Packaging Waste Directive, which is a well-functioning Internal Market through fully harmonised rules on packaging while tackling the environmental impact of packaging and packaging waste.

We support the initiative to review the essential requirements of Directive 94/62/EC on packaging and packaging waste. We support measures to prevent and reduce overpackaging and the objective that in 2030 all packaging on the EU market must be reusable or recyclable.

Filed in Estonian · English published by the European Commission

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.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SUEZ is committed to help reducing packaging wherever this is reducing the environmental footprint of the packaged product from cradle to cradle. SUEZ therefore welcomes the actions the EU Commission wishes to take and fully supports the measures listed in the roadmap, notably the following: recycled content targets for packaging and design for reuse and recycling.

Cefic welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to review the rules regulating the placing on the market of packaging with a view to make packaging increasingly sustainable and circular and minimize waste to preserve planet’s resources (materials, food, water, energy, etc.).

Date: 15 July 2020. REPLY TO THE CONSULTATION ON THE INCEPTION STUDY ON REVIEW OF THE REQUIREMENTS FOR PACKAGING AND OTHER MEASURES TO PREVENT PACKAGING WASTE ACE supports an ambitious implementation of the Packaging and Packaging Waste Directive, as well as the new Circular Economy Action Plan.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

“APEAL, the Association of European Producers of Steel for Packaging, welcomes packaging waste prevention measures that take into account the wider scope of a circular and resource efficient economy, ensuring a net decrease in carbon emissions. One needs to look at design for high-quality recycling, guaranteeing high-quality input in the recycling operations.

Herbalife Nutrition is a global nutrition company providing science-based nutrition solutions and a supportive community approach that inspires people to embrace a healthier, more active lifestyle. We offer weight-management, nutrition, and personal care products that can be personalised with the help of an educated and trained distributor.

The European Recycling Industries’ Confederation (EuRIC) strongly welcomes the Inception Impact Assessment on the review of the requirements for packaging and other measures to prevent packaging waste and fully supports the initiative’s aim to tackle the limited competitiveness of secondary materials from recycled packaging relative to virgin feedstock.

Syctom, the public waste management service for 85 municipalities in Ile de France, including Paris (6 million inhabitants), fully supports the proposed measures. The costs of processing non-recyclable waste cannot increase indefinitely without affecting the finances of the communities that are responsible for it, and thus ultimately to the public.

Filed in French · English published by the European Commission

WPV e.V. - Hilpertstraße 22 - 64295 Darmstadt WIRTSCHAFTSVERBAND PAPIERVERARBEITUNG (WPV) e. V. [address removed] Telefon [phone removed] Telefax 06151/87032-29 E-Mail: [email removed] Internet: www.papierverarbeitung.de Position Paper INCEPTION IMPACT ASSESSMENT: Review of the requirements for packaging and other measures to prevent packaging waste The German Branch Association of Paper Converting Industries…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

- The fact that the monitoring of waste packaging production is based on weight makes it complicated to monitor progress on reuse and prevention, and encourages the trend toward light-weighting initiatives, sometimes at the expense of recyclability.

This is a joint feedback from several associations in the paper & board value chain: CITPA, CEPI, ACE, ECMA, EMPHA, FEFCO, PRO CARTON. The paper & board value chain supports the Commission's ambition to contribute to the circular economy through the review of the requirements for packaging and packaging waste.

Planet (Planet) can — and will — be able to solve the problems caused by people! (the PUMA manifest) Packaging is the activity of temporarily integrating an external function and a product to enable the product to be used. The world ‘does it’ 320.000 times per second, which results in the same number of packages emptied per second, later in time and at a location other than where they are filled.

Filed in Dutch · English published by the European Commission

Environmental (planetary) problems caused by People can – and will - also be solved by us, People! (The PUMA MANIFESTO) Packaging is the activity of temporarily integrating an external function and a product to enable the use of the product.

Swedish Forest Industries welcome the new Circular Economy Action Plan, as we believe it will be beneficial in achieving the overall targets for the European Green Deal. Reduce waste and create better conditions to improve reuse and recycling of goods are necessary to achieve the transition to (more) circularity of resources.

Aarhus University Hospital Ref. Ares(2020)3659115 - 10/07/2020 Technical Department Palle Juul Jensens Boulevard 50 DK-8200 Århus N Tel. [phone removed] www.auh.dk Review of the requirements for packaging and other measures to prevent packaging waste At Aarhus University Hospital (AUH) we have conducted a circular economy (CE) project focusing on plastic packaging between 2016 and 2020.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Amcor is a global leader in developing and producing high-quality, responsible packaging for a variety of food, beverage, pharmaceutical, medical-device, home- and personal-care and other products. We work with leading companies around the world to protect their products and the people who rely on them through a broad range of flexible packaging, containers, cartons, closures and services.

In Green Transition Denmark, we clearly support circular economy and the thought that waste is reduced and goods are re-used and recycled as much as possible. However, it is very important to be aware of the limitations – hazardous chemicals. This can in many cases be a big problem, e.g.

NEW DIGITAL TECHNOLOGIES AS AN ENABLER OF AN EFFECTIVE PACKAGING WASTE MANAGEMENT The inclusion of new digital technologies should be considered in the directive - new technologies are important enablers of transparency, can help ensure compliance to both social and climate responsible business conduct and – at the end – help create a more effective and responsible packaging waste management system.

Packaging waste from food is directly linked to our "modern" way of living: with long value chains, convenience food, food on the go, fast food etc. It is necessary to introduce legal rules to reduce packaging waste to force the industry to innovate and not just take the cheapest solution.