Europe toughens packaging stance
Rather out-dated, but still an interesting read: First published 03/99, PACKAGING WORLD® Magazine
by Victor Bell, Environmental
New 'essential requirements'
will necessitate alterations to many types of packaging to avoid European
Many products as they're currently packaged could be
banned in Europe due to new European Union (EU) regulations. The EU is
finalizing so-called "essential requirements" that will establish
standards for how packaging must meet environmental demands such as source
reduction, reuse, recycling and the use of heavy metals. These standards
are expected to be finalized sometime during the year 2000. (Separately,
the U.K. and France have already passed their own standards. These are
not expected to be enforced strongly until the EU requirements have been
Under the new requirements, packaged products could
be banned if: (a) they interfere with the recycling program of the country
in which the product is sold, (b) their packaging is not easily recovered,
or (c) they could be packaged with less material, without interfering
Examples of packaging that could be banned include blue
glass, polyvinyl chloride shrink sleeves, pigmented high-density polyethylene
milk containers, excessively large boxes (of any material) for software
or CDs, multilayer laminated paperboard materials and many more. Manufacturers
that sell packaged products in Europe will be required to maintain documentation
showing that the products meet these "essential requirements."
Hundreds of existing packages currently in the European
marketplace may require modification in order to comply.
The envelope, please
The essential requirements include six individual standards
for packaging and one standard that links all the elements together:
heavy metals and other hazardous substances
recovery (through incineration)
recovery (composting and biodegradation)
The standard linking these elements together is titled
"Packaging and the environment," and it specifies how to comply
with the six individual standards as a whole.
The specific details for these standards are contained
in seven separate publications, each roughly 20 pages, that include checklists,
forms and guidelines. They can be purchased in the U.S. from Custom Standards
Services (Ann Arbor, MI) at 800/699-9277. More information can also be
obtained directly from the European Committee for Standardization (or
CEN, as it's known by the French acronym) at www.cenorm.be.
All packages will be required to meet the source reduction
and heavy metals standards. Packagers who claim their packaging is reusable
must then meet the reusability standard. Finally, packagers will be required
to meet at least one (and sometimes all) of the recovery standards (material,
energy and/or organic). That is, manufacturers will be required to demonstrate
that their packaging is recoverable in a given country's material recycling
system, produces energy if incinerated, or is compostable or biodegradable.
Manufacturers will also be required to demonstrate that
their packaging does not interfere with existing recovery programs. For
example, blue glass could contaminate a specific country's glass recycling
program or a PVC shrink label could contaminate a country's polyethylene
terephthalate recovery program. These materials can be used only if the
packager can justify (to government officials upon demand) that their
use is critical to the function of the package.
Under the proposed draft, product manufacturers must
assess their own packaging for compliance and maintain in-house records
that document compliance with the standards. Such assessment documentation
must be available for government review upon demand.
Each assessment that a manufacturer prepares must address
all packaging components for each packaging "system." A system
is defined as all primary, secondary and transport packaging associated
with a given product. For example, for source reduction, the company must
determine which functions of the package (protection, safety, storage,
application and marketing) are critical and how the packaging can be further
reduced without negative impact.
For recyclability, a manufacturer would be required
to determine which facilities are needed to recycle each packaging component
and if those recycling facilities exist in the country in which the package
is sold. For example, if Spain lacks the paper recycling facilities to
handle laminated paperboard, a packager cannot select recycling as its
The assessments must be retained for at least two years
(four in the U.K.) after a package is removed from the market. Upon request,
the responsible party (in most cases, the manufacturer) will have to produce
documentation showing that the packaging met the requirements.
U.K., France go it alone
France passed its own "essential requirements"
that went into effect on October 20, 1998, and are similar to, but not
as detailed as, the European standards. The French standard requires that
the supplier of the packaging (if from the EU) or the manufacturer (if
not from the EU) have a written declaration on file stating that all packaging
related to a product conforms to the requirements. Upon request by enforcement
authorities, the responsible party will have 15 days to produce the documentation,
which must show that the packaging meets the French requirements.
Companies that meet the European standards, once they
are passed in 2000, will be automatically in compliance with the French
requirements. Products that were packaged or filled before 1995 are exempt
from the French requirements. Packaging materials that were manufactured
in accordance with the rules in force before January 1, 1995, shall be
permitted until January 1, 2000. After that date, such packs will have
to comply with the new standards.
Last August, the U.K. published guidance notes on implementing
its regulations. Enforcement of the U.K. regulations were scheduled to
begin January 1, 1999. Compliance can be demonstrated by supplying sufficient
technical documentation to an enforcement officer, for a period of up
to four years from the date the packaging is removed from the market.
The U.K. regulations suggest the use of the draft European standards at
this time. As in France, products that meet the CEN standards will also
meet the U.K. standards.
Modifying the design process
U.S. packagers and packaging suppliers should incorporate
this self-assessment into the packaging design process itself. For example,
an assessment should show that the packaging designer reviewed the environmental
impact of the materials selected during the design process. Package designers
who are not familiar with these requirements will need to become familiar
with them. Sometimes, simplified checklists can be prepared to help guide
material selection decisions to prevent the wrong materials from being
selected for a given country.
Regardless, product manufacturers and packaging suppliers
must establish a paper trail showing how each standard was incorporated
into their packaging design protocol. Both should establish a packaging
database that should include all the data necessary to prepare country
eco-fee reports (material types and weights), plus sufficient information
regarding material types to determine how the material can be recovered.
Of critical importance, a producer must establish a certification system
to determine and track (from materials and/or packaging suppliers) the
recyclability, energy value, biodegradability, recycled content and heavy
metals concentrations of the packaging materials used.
The good news is that elements of this process could
already be part of a company's ISO 9000 or 14000 program. (These are standards,
promulgated by the Intl. Standards Organization, that manufacturers follow
in order to be certified as operating at a certain, documented level of
A six-month comment period began November 19, 1998,
to review the European essential requirements. Companies selling products
in Europe should take advantage of this opportunity to comment. Comments
can be submitted to any of the CEN National Standards Bodies such as British
Standards Institution (BSI), but not, ironically, to CEN itself. (Editor's
note: In a special arrangement for Packaging World's readers, Brian Such,
Project Manager, Packaging and the Environment at BSI, has indicated he
will forward comments he receives via e-mail at Brian_Such@bsi.org.uk
to the CEN Technical Committee.)
The present draft is generally favored by industry,
but there is a strong movement by government officials in some member
states (mainly Germany) to make these requirements more demanding by removing
the self-assessment process and by establishing stricter guidelines. (Victor
Bell will be speaking on this topic at Southpack in Atlanta, May 18, 1999.)
Victor Bell, CPP, is president of Environmental Packaging
Intl., which specializes in global environmental packaging and product
published 03.99, PACKAGING WORLD® Magazine page 59
Europe toughens packaging
Original standards never
by Victor Bell, Environmental
The EU Directive on Packaging and Packaging Waste (originally
passed in 1994) calls for the establishment of European standards to be
used to implement "essential requirements" for packaging of
products that are sold in the EU. Packaging that does not comply with
these "essential requirements" was supposed to have been banned
from EU markets as of January 1, 1998. Those requirements, however, have
never been enforced because the standards on how to comply were never
adopted. This new draft of the European standards has just been published
and probably will become final in 2000.
The European Committee for Standardization (CEN) has
developed draft standards (see main story) that address the "essential
requirements." While these standards are not final, they indicate
the direction the European Community will pursue in order to establish
minimum criteria for packaging sold in the European market. It's important
to note that these criteria will affect primary, secondary and transport
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