EGMF position paper on the proposal for a Packaging Regulation

In the new Packaging and Packaging Waste legislative proposal, we observe some positive aspects, like the change from a Directive to a Regulation. However, we have a number of concerns, which we believe will lead to additional burden on the manufacturers of goods.

Therefore, we request that EU legislators consider our proposals for their further evaluation:

1. Harmonize requirements for all Member States, which means having the same labels for the disposal and alphanumeric code use (for example according to Decision 129/97/EC1) for which the industry has already invested a lot of financial resources. This also includes permitting each Member State to request additional national information only on a voluntary basis and not as a mandatory requirement.

2. Permit the use of digital support, like a QR-code or other digital marking technology connected to the internet. The use of digital support should be a voluntary option to provide information to the end user 2 as an alternative to the packaging label, simplifying the industrial process.

3. Have clear and harmonised requirements when it is not possible to know in which EU Member State products will be placed.

4. Permit companies to be registered to a collective EPR system only in one PRO (and not in each Member State where the packaging will be put on the market), for example, by registering only in the main country of reference or having an “European collective EPR system”.

5. To achieve the proposed minimum recycled content in plastic packaging, we need higher production of secondary raw materials both in terms of quantity and purity. We also need standardisation activities to ensure the quality of the secondary plastic materials.

6. Manufacturers of finished products cannot bear the full responsibility and burden of ensuring the traceability of the feedstock in these materials. EU suppliers of packaging materials should hold the responsibility for conformity for their products.

7. To avoid double regulation, all packaging feedstock comprising recycled and virgin materials should only be required to be in conformity with the REACH Regulation and no other piece of legislation in order to generate a higher demand and supply of recycled plastics without legacy substances.