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What about
Packaging in the EU?
Directive 94/62/EC amended by 2004/12/EC - Packaging
Decision 97/129/EC - Marking
SI 2003 No 1941 - UK
On December
20, 1994 the European Parliament issued Directive 94/62/EC "on
packaging and packaging waste," which went into effect on June
30, 1996.
The
definition of packaging was intended to be comprehensive. It includes
primary packaging for an individual
sales unit, secondary packaging for a
case of the product, and tertiary
packaging
for shipping and handling during transport. It includes packaging
used at any stage of production or manufacturing: from raw material to
finished product. Packaging includes items filled at point of sale, such as
plates, cups and bags used in food service. Packaging does not include items
that are integral to a product and are intended to be used, consumed and
disposed of together, such as a teabag or permanent flower pot.
Packaging
must meet the essential requirements:
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Packaging volume and weight must
be the minimum amount necessary to maintain safety, hygiene
and acceptance of the packaged product |
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Packaging must be manufactured to permit reuse or recovery when packaging waste is disposed of.
Recovery includes the recycling of packaging materials, separate
composting of biodegradable packaging, and energy recovery through
incineration. |
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Noxious & hazardous substances
must be minimized when packaging is incinerated or landfilled |
In addition,
lead, cadmium, mercury and hexavalent chromium
are prohibited in packaging. Maximum concentration levels of 100 ppm were
effective June 30, 2001. Concentration levels are calculated for each
packaging component, such as a bottle top (not at the homogeneous material
level required by RoHS). Lead crystal glass is exempt from this requirement.
The marking and identification system
established by the directive remains voluntary at this time. Each material
is assigned a number and a letter abbreviation. Marking should be permanent
to facilitate recycling and recovery. It may be placed on the packaging
itself or on the label.
What about Packaging Waste?
SI 2005 No 3468 - UK
Green Dot national programs
Green Dot
participation costs
Directive
94/62/EC establishes aggressive recovery and
recycling targets for packaging waste. By December 31, 2008, 55%
by weight of all packaging waste must be recycled, and 60% must either be
recycled or incinerated with energy recovery. In addition, material-specific
recycling targets must also be met: 60% by weight for glass, 60% for paper
and cardboard, 50% for metal, 22.5% for plastics and 15% for wood (such as
crates and pallets).
The directive
establishes the polluter pays principle
with respect to financing the recovery and recycling of packaging waste. The
polluter is understood to be the producer of packaging and packaged
products, not the consumer.
All EU
directives are transposed by each member state into national law. Each
nation determines the mechanism for collection of waste packaging and the
method of financing its recycling and/or recovery. To date, there is
no standardization between member states
in financing methods, logistical models, or even the sources of packaging
waste that must be collected and treated.
In the UK,
each producer is allocated a recovery obligation
based upon variables such as the weight of packaging that the
producer places on the market in the UK, the type of material used in the
packaging, and the class of producer (making raw materials, making
packaging, putting products into packaging, seller of packaged products, or
importer of packaged products).
The
obligation is met by acquiring PRNs (packaging waste recovery notes) issued when packaging waste is received by
an accredited reprocessor. These obligations can be met directly or through
membership in a registered compliance scheme
operated on behalf of its members. Approximately 90% of companies in
the UK meet their obligations through membership in a scheme.
The
Green Dot (Der Grune Punkt) system is
used in Germany and 21 other European countries. Under this system,
non-profit organizations in each nation assume the take-back and recovery
obligations for producers placing products on the market in that nation.
Collectively the national Green Dot systems operate under the umbrella
organization PRO EUROPE (Packaging Recovery Organization Europe).
Recovery is
financed by licensing the Green Dot trademark
to participating producers. The appearance of the Green Dot on a packaged
product means that the producer has pre-paid the collection, sorting,
recovery or recycling of the packaging.
Producer
fees, regardless of country or financing method, vary according to the
packaging material that is used. Plastic
and composite packaging almost always have the highest fees by weight.
Paper, cardboard and glass packaging usually have the lowest fees by weight.
Aluminum and steel typically fall somewhere between.
Manufacturers
located outside of Europe who wish to place products on the EU market
typically work with an importer or distributor.
Under the laws of most member states, the importer is defined as person
obligated for packaging waste. Typically the importer has standing
arrangements for meeting the packaging waste obligations for the products he
imports. Your responsibility as an offshore manufacturer is to keep records
concerning the composition and quantity by weight of packaging materials
placed on the market in any given nation -- and to pay any fees your
importer passes along to you.
This summary is intended to give you an easy-to-understand overview and does
not constitute legal advice. The actual standard in the original language
should be reviewed and used for all business, legal, and product compliance
purposes.
If you would
like more information about EU packaging and packaging waste requirements, we stand ready
to help you. Just
email
us or give us a call at 972-679-8996 for a more detailed presentation.
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RSJ
Technical Consulting
PO Box 867705, Plano, Texas 75086
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