8 April 2020

Submission from 'European Carton Makers Association': Guidance on identifying and describing the products covered by the SUP Directive

Dear Sir / Madam,

I am writing on behalf of the ‘European Carton Makers Association’ (ECMA) who represent 500 folding carton manufacturers, paper mills and other suppliers to our industry, with 50,000 staff in almost every European country.

I represented ECMA at the ‘Single Use Plastics Directive’ webinar on 3 April 2020 and I am responding to your request for comments regarding your recently announced definition of plastic. Along with the entire forestry and paper industry, I am concerned that the draft guidance on ‘main structural component’ would mean that all polymers used in paper and fibre-based packaging would be defined as ‘plastic’ for the purposes of the ‘Single Use Plastics Directive’.

Folding Cartons are one of the best examples of a sustainable and circular economic model: using primarily renewable resources, they are made of sustainably managed virgin and recycled fibres primarily from European forests, and the used raw materials are widely recovered and reused, thus leading to limited waste. According to EUROSTAT, the 2017 recycling rate for paper-based packaging was 84.8%. In absolute volumes, more paper-based packaging was recycled than all other packaging materials together. In addition, folding cartons are the most hygienic packaging format for consuming food ‘on the go’ and their value in this area has been demonstrated and reinforced throughout the Covid-19 crisis.

In the absence of any ‘polymer-free’ alternatives, the draft guidance that has been presented would have significant environmental effect and likely lead to a range of unintended consequences which are not aligned to the Commission’s desire to achieve a true Circular Economy coupled with long-term carbon reduction. 

  • Under the new definitions, there could be a move to heavier, 100% plastic and less recyclable packaging formats. 
  • The European fibre packaging sector is investing heavily in developing new and innovative barrier coatings to facilitate even more recycling of our products in the full breadth of waste streams; the draft guidance that has been presented would be a disincentive to continued innovation. 
  • Wood fibre, which is the core raw material used in folding cartons, has a lower climate impact than plastic hence to define folding cartons as plastic, would create significant confusion to consumers, as to which packaging format to use.

I also wish to question the draft guidance definition of a main structural component. Folding cartons, whilst primarily consisting of wood fibre (the main structural component), also have other materials (minor structural components), in the draft guidance (3.2.2. SUPD WPI Guidelines), both main and minor structural components are given equal weighting regarding whether an items falls within scope of the SUPD; I would respectfully suggest that the priority order of the components should be used in the final definition of the product.

Finally, I was delighted to hear Mr Rana Pant of the European Commission recognise during the webinar, that hygiene of packaging is an over-arching priority for the SUPD. Interestingly, it has been reported by the media during the Covid-19 crisis how some re-useable 100% plastic packaging items have been banned by many outlets due to the reduced hygiene protection that they offer.

I am available to discuss any area of this email; my organisation will continue to be fully engaged in ensuring the SUPD fulfils all expectations for all stakeholders.

Best regards,

Mike Turner

Managing Director

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ECMA - the European Carton Makers Association
P.O. Box 85612
NL-2508 CH The Hague
The Netherlands
T: +(31) 70 312 39 11
M: +(44) 7789 397615
E: mturner@ecma.org
I: www.ecma.org

Published on 8 April 2020