Intergraf

Intergraf, the European federation for the printing industry, welcomes the European Commission’s review of the essential requirements of packaging. A key part of the value chain and the circular economy, the printing industry brings together the materials, ink, and packaging design which make the final packaging product.

Intergraf represents the European printing industry. Intergraf contribution addresses the provision on package leaflets (article 63.3). The proposal presents a revolutionary approach in granting the flexibility to Member States to remove paper leaflets from the packaging to rely only on the information made available online through the electronic product information.

Intergraf provides feedback to the Revision of EU rules on food contact materials on behalf of the European printing industry. Please find our comments in the attached document. We remain at your disposal for further information and look forward to working with the European Commission on this crucial area of legislation.

Representing over 100.000 companies, the European printing industry is actively preparing for the compliance of its companies, who are generally considered as downstream operators under the European Deforestation Regulation (EUDR). Printing companies manufacture printed products classified under HS 49.

Intergraf warns against setting a digital only approach in EU product legislation. The practice applied to professional equipment under the Machinery Regulation should not be extended to consumer goods. At present, EU consumers receive printed instructions with their products, containing essential information on use, assembly, and repair. They are vital for product safety and consumer protection.

Intergraf warns against setting a digital only approach in EU product legislation. The practice applied to professional equipment under the Machinery Regulation should not be extended to consumer goods. At present, EU consumers receive printed instructions with their products, containing essential information on use, assembly, and repair. They are vital for product safety and consumer protection.

Intergraf represents 21 national printing federations in 19 countries in Europe. The printing industry provides jobs to 640,000 Europeans active in over 110,000 companies and generates a turnover of approximately € 82 billion. The industry throughout Europe consists mainly of small enterprises, as 90% of them employ fewer than 20 persons.

In line with Article 20.4 and subsequent Commission's Report (COM(2016)74), Intergraf calls for the extension of the scope of the EU Timber Regulation to printed products. The trade and economic situation as well as competition and environmental aspects in support of the extension are detailed in the attached position.