GROW responds to the EU’s public consultation on the revision of the packaging Directive

On January 6th 2021,  the European Federation of Wood Packaging Manufacturers participated in the public consultation launched by the European Commission on the revision of the essential requirements of the Packaging and Packaging Waste Directive.

The aim of the consultation was to gather stakeholder input and improve packaging design to promote reuse and recycling, address over-packaging and reduce packaging waste. According to the initial impact study carried out by the European Commission, the overall increase in packaging waste generated, and how the essential requirements also leave too much room for interpretation, in particular on what qualifies as recyclable. The European Commission has therefore decided that it was necessary to review the Directive which is due to be published by the end of 2021. GROW Int.’s position on the revision of the directive is as follows: Whereas sustainably managed and renewable materials should always be preferred to non-sustainable materials (which include those of fossil origin), Whereas the essential requirements for packaging should be different for sustainable and non-sustainable materials, Firstly, it is crucial to adopt a life cycle approach and promote the use of Life Cycle Assessment (LCA) and/or Product Environmental Footprint (PEF) to understand the full environmental impact of packaging materials and to adopt the most appropriate legislation. The graph shows the LCA carried out by ADEME[1] with the results when comparing wooden packaging with plastic or cardboard: therefore, a renewable material, if sustainably managed, is always better for the environment than a material of fossil origin.

Secondly, the essential requirements for packaging should be different for sustainable/renewable materials such as wood than for non-sustainable ones.

Third, developing a harmonised, clear and realistic definition of recyclability as well as compostability and biodegradability with the aim of having legal certainty by updating current definitions.

Fourth, the imposition of reuse targets and the promotion of reusable packaging may not be the most appropriate solution for all materials.

Fifth, some harmonisation of national fees for integrated waste management systems linked to extended producer responsibility (Green Dot) is needed for each type of packaging material. Eco-design should be encouraged by increasing or reducing the fees depending on the environmental impact of packaging.

Finally, wood packaging companies are all SMEs and it is important not to impose a disproportionate administrative burden on them. These companies are often located in rural areas with limited economic opportunities and should be supported to combat the exodus to urban areas.

By actively promoting tree planting, the wood-based sector contributes to the fight against climate change (trees sequester CO₂ and wood retains it), promotes biodiversity conservation and helps in the fight against poverty.

In 2018, about 397 000 enterprises were active in wood-based industries across the EU, representing 20% of EU manufacturing enterprises. It is estimated that there are at least 16 million forest owners in the EU who take care of approximately 60% of the European forest area [2]

[1] The French Agency for Ecological Transition (ADEME), Life Cycle Assessment Study of wooden, corrugated cardboard and plastic apple crates, L045-R5 2000. The conclusions of the LCA carried out by ADEME comparing cardboard, plastic and wooden packaging showed that (as shown above) single-use wooden packaging is the best solution for fruit and vegetables. When comparing a plastic multi-rotational packaging with two single-use packaging made of renewable materials, it cannot be said that reuse is better than single use in terms of environmental impact. It will depend on the material.

[2] Confederation of European Forest owners CEPF_BROCHURE.pdf (cepf-eu.org)

More information on the EU consultation

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