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APPLiA recommendations on the Packaging and Packaging Waste Regulation proposal

Policy papers 02 Mar 2023

The proposal marks a landmark step to combat the over-packaging of products and growing amounts of waste. This calls for requirements with an empirical basis and right timing for implementation.

Packaging is necessary to protect home appliances in the factory warehouses and during shipping, ensuring that the product is in good working order when it arrives at consumers homes, and consumer safety is ensured while using the equipment. The EU’s proposed Packaging and Packaging Waste Regulation (PPWR) marks a landmark step to combat the over-packaging of products and growing amounts of waste.

APPLiA has finalised a set of key recommendations to ensure a smooth and effective implementation of the proposal:

1. A harmonised approach to support the Single Market: It is critical to implement the PPWR in a harmonised way that focuses on keeping markets open and cross-border trade for products flowing.

2. A competent assessment on the reasonable implementation of reusable transport packaging: We recommend applying such reusable targets only where it would make sense from the technical and environmental perspective, by means of thorough analyses based on feasibility studies, real-world circumstances, logistical considerations, potential effects on consumer health and safety, as well as goals for reducing food waste and safety standards.

3. All requirements must be implemented with sufficient transition times: A five-year implementation time as from the adoption of the implementing acts would be needed for our industry to cope with such new requirements.

4. The administrative effort for compliance must be appropriate: As Original Equipment Manufacturers, the PPWR has to provide clear responsibilities for the economic operators.

5. Preference for digital solutions going forward: We foresee a key opportunity to allow producers to provide relevant product information via digitally generated information/labels instead of paper versions.

6. A consistent approach with other EU legislation & policies: The PPWR should be the only legislation regulating packaging to avoid confusion and double regulation.

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