Page 27 - FINAT Yearbook 2011

• Product Safety and Good Manufacturing Practice
• The European Chemicals Legislation: REACH & CLP
• The Integrated Pollution Prevention and Control directive:
IPPC
packaging and packaging waste directive
The EU Directive 94/62/EC on Packaging and Packaging Waste was first adopted on 20 December 1994. The latest amendment of the Directive dates back to 2004 and states that the so-called Packaging Committee should decide with priority upon the classification of a number of ‘borderline’ cases as illustrative examples of packaging and non packaging in the Directive’s Annex I. In the 2004 edition, ‘release paper for self-adhesive labels’ was listed as one of the items to be classified. After several years of radio silence, it came to FINAT’s attention at the end of 2010 that the EU Commission’s DG Environment was preparing a draft amendment of Annex I to be proposed to the Packaging Committee (composed of Member State represent- atives) for adoption in which release papers would be classified as packaging material. Currently, the classification of liners differs from country to country with the UK and Netherlands as examples of countries that have explicitly included liners under the packaging waste regime. The proposed classification of liners would imply that this status in future would also apply in all other EU Member States.
It is FINAT’s position that Release Liners should not be classified as packaging since they are an integral part of the self-adhesive labelling process, during the manufacture of the self-adhesive labelstock, during the conversion of labelstock at the label printing plant, as well as during the ultimate applicat- ion of the label onto the product. Supported by international lobbying consultants Hill & Knowlton and legal counsel Brabers and Partners, FINAT got in contact with officials from DG Environment and DG Enterprise and submitted detailed position papers listing our legal argumentation against the interpretation of liners as packaging material. With the
support of the national associations and stakeholder compa- nies, national Member State representatives on the Packaging Committee were addressed with our argumentation. At the Packaging Committee meeting in March the Commission proposal was kept on hold and at the moment of writing, it remained unclear whether and to which extent a revised amendment proposal was forthcoming before the summer. FINAT’s lobby therefore continues on this subject.
sustainable packaging
FINAT is concerned about the prolifera-
tion of ‘green labels’ and environmental
sustainability scorecards driven by both
legislators and global end-users and has
therefore welcomed the initiative by the
Consumer Goods Forum (CGF), the
consortium of the world’s largest brand
owners and retailers, to launch the Global
Packaging Project (GPP). Aim of the project is to provide a common framework and measurement system for business partners and key stakeholders to have meaningful discussions about packaging and sustainability that can influence business decisions. The intent is to standardize a global language for packaging and sustainability.
After the presentation of the GPP at the FINAT Congress in Valencia last year, FINAT took part in the GPP meeting in Paris in October 2010 where the various pilots that had been set up to test the sustainability metrics and definitions. From the pilots it became clear that there is much focus on the envir- onmental indicators, and that social and
economic indicators are often already
part of normal business decisions.
Nevertheless, it was concluded that
the definition of sustainability
encomp-asses three pillars and
any framework on packaging
sustainability needs to reflect
these three pillars. The final
version release is
expected in the first half
of 2011.
food contact
Like all types of food
packaging, food labels have to
comply with strict food safety
requirements as set out in
Regulation (EC) No
1935/2004, and Directive 2002/72/EC related to “plastic materials and articles to come into contact with foodstuffs”, as well as Commission Regulation (EC) No 2023/2006 on Good manufacturing practice (GMP) for materials and articles
Food Labels: Highly commende winner Vrijdag
Premium Printing, Netherlands in the 2005 FINAT Label Competition
Food Labels: Highly commended winner Greco Label, Greece, in the 2006 FINAT Label Competition
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FinAt YeARbooK 2011 |