EU Red Tape Comes in Plastic
Under the PPWR, putting plastic packaging on the EU market increasingly means proving far more than whether the package simply works. Manufacturers must demonstrate compliance with rules covering materials, recyclability, recycled plastic content, substances of concern and packaging minimisation, supported by technical documentation and an EU declaration of conformity. Suppliers must provide the information needed to build that file. For smaller businesses using or commissioning plastic packaging, what used to be a basic packaging decision can therefore become a surprisingly technical compliance exercise.
In practice, plastic packaging can raise questions such as:
- What plastic is the packaging made from?
- Which polymer or polymers does it contain?
- What does each plastic component weigh?
- Does it contain substances of concern?
- Does it comply with applicable restrictions?
- Is the packaging designed to be recyclable?
- How will its recyclability be assessed?
- Can it be collected, sorted and recycled at scale?
- How much post-consumer recycled plastic does it contain?
- How was that percentage calculated?
- Can the recycled content be traced and documented?
- Does it meet the applicable minimum recycled-content target?
- Is it contact-sensitive packaging?
- Which recycled-content target applies to that particular type of plastic packaging?
- If an exemption is claimed, which polymer is involved?
- Is there a suitable recycling technology for that polymer?
- Is that recycling technology available at industrial scale?
- Has the packaging’s weight and volume been reduced as required?
- Can suppliers provide the specifications and supporting evidence?
- Has the conformity assessment been completed?
- Is the technical documentation ready?
- Has the EU declaration of conformity been drawn up?
Personal Remarks
Industry fed Brussels the nonsense. Brussels turned it into regulation. Now small businesses get the paperwork. Welcome to Europe’s red-tape chain.
Source
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040