73 packaging value chain organisations call on EU to safeguard the Single Market in Single-Use Plastics negotiations

Brussels, 16 November 2018 – EUROPEN and 72 other associations representing a wide range of packaging materials and sectors across the packaging value chain call on the European Institutions to ensure that the free movement of packaging and packaged goods across the EU’s Single Market is not undermined by the Single-Use Plastics Directive (SUP), currently being negotiated in trilogues.

In a joint statement published today, the 73 organisations make a set of recommendations to EU negotiators aimed at ensuring that the proposed Directive provides legal certainty and does not lead to a patchwork of national measures that would fragment the Internal Market, thereby undermining the free movement of goods and the transition to a Circular Economy.

The signatories to the statement acknowledge the problem of plastic pollution and are committed to finding and contributing to solutions, but emphasise that an EU legal framework that undermines the Single Market will fail to achieve the intended objectives. An EU Directive that enables individual Member States to impose a wide range of disparate restrictions on packaging risks a chilling effect on the very investment at scale in innovation, including eco-innovation for circularity, that the transition to a Circular Economy demands.

Unlike national restrictions on carrier bags, allowed through a derogation from the EU Directive on Packaging and Packaging Waste (PPWD), derogations for a range of packaging applications will impact not only the free movement of packaging, but the free movement of packaged goods.

In order to avoid this damaging scenario, the 73 signatories to the joint statement call on the EU institutions to:

Secure the primacy of the PPWD for all packaging and packaged items in case of conflict between different EU legal instruments;
Ensure that any national measures that may be adopted as a result of the SUP directive are duly pre-notified to the European Commission and without prejudice to the Singla Market clause of the PPWD;
Measures to achieve consumption reduction targets envisaged in the SUP directive cannot include unilateral national restrictions on the placing on the market of specific packaging applications.

“We fully acknowledge the need to address the plastic pollution issue and more broadly we support the objective of the EU’s Circular Economy strategy,” said Hans van Bochove of Coca-Cola European Partners and EUROPEN Chairman. “But we will only succeed with a clear, evidence-based, harmonised and predictable legal framework that is able to guide and secure sustainable investments. Fragmentation of the Single Market would seriously impede investments in innovation and the transition to a Circular Economy ” underlined Van Bochove.

“We should be mindful that in the rush to reach an agreement on the SUP directive we don’t let policy coherence go by the wayside,” said Virginia Janssens, EUROPEN Managing Director. “We want the measures to be effective, so we must avoid an overlapping, contradictory legislative patchwork. Any further measures relating to the regulation of packaging materials should be addressed in a harmonised way in the context of the forthcoming review of the PPWD, which sets EU-wide standards, including the Essential Requirements that packaging placed on the EU market must meet,” she concluded.

List of co-signatories in alphabetical order:

ACE - The Alliance for Beverage Cartons and the Environment, AGVU - Arbeitsgemeinschaft Verpackung und Umwelt e.V., Germany, AIM - European Brands Association, A.I.S.E. - The International Association for Soaps, Detergents and Maintenance Products, Alliance Carton Nature, France, Aluminium Denmark, Denmark, AmCham EU - American Chamber of Commerce to the European Union, ANIA - Association Nationale des Industries Alimentaires, France, APEAL - The Association of European Producers of Steel for Packaging, ARAM - Association for Packaging and the Environment, Romania, Bryggeriforeningen- The Danish Brewers’ Association, Denmark, BSDA- Bulgarian Soft Drink Association, Bulgaria, BVE - Bundesvereinigung der Deutschen Ernährungsindustrie e.V, Germany, CEPI - Confederation of European Paper Industries, Cicloplast -Spanish association of plastic transformers and raw materials producer for promoting plastics packaging recycling, Spain, CICPEN - Industrial Coalition on Packaging and the Environment, Czech Republic, Citpa- The International Confederation of Paper and Board Converters in Europe, CNE - Conseil National de l’Emballage, France, COFEPAC- Comité Français de l’Emballage Papier Carton, France, COPACEL, France, Cosmetics Europe - The Personal Care Association, CPME aisbl (Committee PET Manufacturers Europe), EKO-PAK- Packaging Industry Union of Employers, Poland, ELIPSO - Les entreprises de l'emballage plastique et souple, France, EFBW - European Federation of Bottled Waters, Emballasjeforeningen- The Norwegian Packaging Association, Norway, EPRO - European Association of Plastics Recycling & Recovery Organisations, European Retail Round Table, EuPC - European Plastics Converters, EuPIA- European Printing Ink Association, EUROCOMMERCE - The voice of retail and wholesale in Europe, European Aluminium, European Aluminium Foil Association e.V, European Bioplastics, European Dairy Association, European Vending & Coffee Service Association, EUROPEN - The European Organization for Packaging and the Environment, EXPRA - Extended Producer Responsibility Alliance, FCD- Fédération du Commerce et de la Distribution, France, FDF - Food and Drink Federation, UK, FCIO- Association of the Austrian Chemical Industry, Austria, FEA - European Aerosol Federation, FEBEA - Fédération des Entreprises de la Beauté, France, Federalimentare – Federazione Italiana dell’Industria Alimentare, Italy, FEFCO - European Corrugated Packaging Association, FEVIA - The Belgian Food and Drink Industry, Belgium, Flexible Packaging Europe, FNIL- Fédération Nationale des Industries Laitières, France, FNLI - Federatie Nederlandse Levenmiddelen Industrie, The Netherlands, FoodDrinkEurope - The organisation of Europe's food & drink industry, Foodservice Packaging Association, UK, IK Industrievereinigung Kunststoffverpackungen e.V, Germany, ILEC - Institut de liaisons et d’études des industries de consommation, France, INCPEN - The Industry Council For Research On Packaging And The Environment, UK, Independent Retail Europe, INTERGRAF - European Federation for Print and Digital Communication, Miljöpack – The Trade & Industry Group, Sweden, Metal Packaging Europe, Pack2Go Europe - Europe’s Convenience Food Packaging Association, The Packaging Federation, UK, Pakkaus - Packaging Association, Finland, PCEP -Polyolefin Circular Economy Platform, Petcore Europe, PlasticsEurope - Association of Plastics Manufacturers, PFPŻ ZP - Polish Federation of Food Industry, Poland, Potravinářská komora České republiky- Federation of the Food and Drink Industries of the Czech Republic, Czech Republic, SEPEN- Association for Packaging and Environmental Protection, Serbia, Serving Europe - Branded Food and Beverage Service Chains Association, SLICPEN - Industrial Coalition on Packaging and the Environment, Slovakia, Sociedade Ponto Verde, S.A. - Packaging Recovery Organisation, Portugal, Styrenics Circular Solutions (SCS), UNESDA - Union of European Soft Drinks Associations