We fully agree that packagings are widespread, that it would be appropriate to minimise their usage where not necessary and their dispersion into the environment should be avoided. Under this assumptions, the EU Commission\u2019s proposal of a Regulation on Packaging and Packaging Waste (PPWR) constitutes a suitable and desirable effort; also, the choice of a Regulation as legislative tool will concur in defining a harmonized legislative framework across the EU providing clarity and certainty to companies operating in this sector which needs it to define long term investments.<\/p>\n\n\n\n
The primary objective of this Regulation should be the reduction of environmental pollution and its impact on climate change.<\/p>\n\n\n\n
This objective, though, should be pursuit on the basis of clear and unmistaken scientific evidence and looking at sustainability in a holistic way by taking into consideration social and economic aspects as well as the environmental ones. <\/p>\n\n\n\n
This should be even more valid when specific product categories are targeted. <\/p>\n\n\n\n
Unfortunately, this is not happening with the PPWR: specific product categories are demonized and ruthlessly targeted by some of the proposed provisions. The role and function these products have as well as the environmental impacts of proposed alternative solutions are completely disregarded both in the Impact Assessment and in the legislative proposal. <\/p>\n\n\n\n
This is well the case of plastic packaging for fresh fruit and vegetables like trays and punnets; yes, those containing the strawberries, grapes, and cherry tomatoes you find at your local supermarket. The EU Commission proposal sets an outright ban for this product at article 22 and Annex V, point 2. <\/p>\n\n\n\n
Packaging plays a fundamental role in the supply chain of fruit and vegetables, protecting them during transport, preserving their organoleptic features, avoiding contamination from external agents, and prolonging the shelf life of the goods contained within. They therefore allow all European consumers to enjoy these products especially when local production is not possible. They also provide sufficient space to host labels which carry relevant information for consumers, some of which are mandatory by law. Eliminating these packaging would significantly increase the amount of food waste which not only has negative ethical implications but generates more CO2<\/sub> emissions than the packaging itself.\u00a0<\/p>\n\n\n\n Beyond these features, plastic packaging, at least those manufactured by ProFood member companies, are 100% single material, are 100% recyclable and, absurd enough, already contain, where allowed an average of 70% of recycled plastic content: these products already meet the criteria set by the Regulation itself for 2040 of what is considered a virtuous food packaging. Contrarily to other materials, to produce plastic packaging for food purposes, recycled raw materials (or secondary raw materials) can be used, making this industry a truly circular one. <\/p>\n\n\n\n Similar considerations can be made for the proposed outright ban of single-use foodservice packaging such as cups, plates, salad bowls, containers, etc. widely used in the Horeca sector as stipulated in article 22, Annex V, point 3. <\/p>\n\n\n\n While the intention is to avoid littering, which in any case does not constitute an issue in \u2018closed\u2019 and controlled environments like Horeca, the proposal intends banning, in a discriminatory way, entire product categories without addressing, instead, the negative behaviors of consumers. The proposed measures overlap with the recently adopted SUP Directive by amending some of its fundamental aspects which would nullify strategic choices and investments made by companies operating in this sector. <\/p>\n\n\n\n For this product category, the draft Regulation proposes re-use practices: while these could have a role to play, they should not prevail in the case of already established and well-functioning waste management systems.<\/p>\n\n\n\n The overall impression is that the rationale underpinning the proposal to ban specific product categories, is more ideological than based on clear and unquestionable scientific evidences: the JRC study referenced several times both in the Impact Assessment as well as during the discussions taking place in the EU Parliament draws conclusions based on partial and incomplete analysis; proof of this, is the need to develop a follow-up study requested in May by the Commission to the JRC on the environmental performances of re- usable tableware and packaging in the Horeca sector. <\/p>\n\n\n\n We believe that these types of studies, in particular LCAs, are a useful, indeed indispensable tool on which to base legislative proposals: however, they must be carried out properly, in accordance with the ISO standards that regulate their use.<\/p>\n\n\n\n It is on the basis of this compliance that the usefulness and reliability of these studies should be assessed, and not on the basis of preconceptions, purely ideological positions or simply the need to bring in arguments a posteriori<\/em>.<\/p>\n\n\n\n It should also not be forgotten that these studies only deal with the environmental impact, and therefore provide a partial assessment of the topic: they must be supplemented with considerations related to relevant factors such as the socio-economic impact, food waste, food safety, consumers\u2019 health, implementation costs and consequences for the industrial sector.<\/p>\n\n\n\n The draft PPWR is now undergoing discussions in the ENVI Committee of the EU Parliament leading to a possible vote in October or November; most of the argumentations illustrated above and the legitimate questions we raised don\u2019t seem to find space in political debate within ENVI. However, the very same doubts and objections seemed to have pushed both the ITRE and AGRI Committees of the EU Parliament to include a straight deletion of article 22 and Annex V (points 2 and 3) and a deep review of article 26 paragraph 2 to 6 in their respective Opinions. These proposed compromises have been voted on by 80% of the MEPs sitting in those Committees and the Rapporteur in ENVI Frederique Ries should take this into account.<\/p>\n\n\n\n The fact that we are heading towards the end of the legislature does not imply that discussions and negotiations on this file should be rushed.<\/p>\n\n\n\n