Ecosurety’s Post

⏰ FRESH PRODUCE INDUSTRY ALERT ⏰ You have until 5pm (AEDT) Monday, 28 October 2024 (TODAY!!) to submit your feedback on the Department of Climate Change, Energy, the Environment and Water proposed reforms for packaging. ⏰ https://lnkd.in/g9qF88z2 WHAT ARE THE REFORMS? The short version is that the Commonwealth Government are potentially implementing phased or complete bans on problematic plastics in packaging and/or a fee based system to penalise brand owners for using packaging that does not use recycled content, is not recyclable and/or does not have proper labelling. WHO DOES THIS IMPACT? While many of the main industries concerned are large plastics packaging users like pharma and FMCG - essentially - any industry with consumer products that are packaged should pay attention. This means anyone in fresh produce with plastic packaging on consumer products and/or used during transport should pay attention to the reforms. WHAT COULD BE PROGRESSIVELY BANNED, RESTRICTED OR 'DISINCENTIVISED'? • Use of mixed or multiple polymers. • Inclusion of colours in plastic packaging. • Suitability of PVC/PDVC, EPS/PS, PETG, non-polyolefin bioplastics (PLA, PHA), PA, nylon, EVOH, AIOx, SiOX, rigid steel, and oxo-degradable polymers in packaging. • Overwraps, empty space (excess headspace, double walls, and false bottoms). • Additives that prevent or impede recycling. • Additives that reduce the value of recyclate. • Chemicals of concern regulated through other frameworks to protect human health and the environment. • Use of carbon black. • Use of silicone, metal parts, wadding, padding, ties, cables, metals, thermosets, pump systems, swing tops with ceramic, and sealing foils not able to be completely removed in container closures. • Use of labels and sleeves where they impede recycling. • Use of inks that are toxic, bleed, or are metallic or mineral based. • Use of adhesives that are not water soluble or cannot be easily removed in the recycling process. • Packaging that cannot be easily emptied by the consumer where the remaining product impedes recycling. WHERE DO WE STAND? We are taking an active stance on the proposed changes and are submitting a detailed response to the changes being proposed. We are committing to: 🍎 Advocate for growers and bring to light the nuances of the fresh produce industry that MUST be considered during their review 🍑 Participate as an industry liaison with the Department of Climate Change, Australian Packaging Covenant Organisation (APCO) and any other governing body involved in the review and decision. 🥑 Work with major retailers Coles Group, Woolworths Group and ALDI Stores Australia to get the best outcomes for growers, producers, pack houses and the entire produce supply chain. We are busy finalising our submission today - but soon we will release an overview of our responses and potential impacts of the changes with more specifics. #PackagingReforms2025

Shared my opinion in Packaging Digest on the evolving Extended Producer Responsibility (EPR) Regulations. Check it out! At Acquis Compliance, we partner with complex product manufacturers, particularly in the electrical, electronics, electro-mechanical, and semiconductor sectors. These companies rely on batteries and also diverse packaging materials to ship their products safely around the world. Our expertise helps them meet the evolving landscape of packaging and battery compliance, focusing on Extended Producer Responsibility (EPR) regulations globally.   From a compliance standpoint, the EU's upcoming Packaging and Packaging Waste Regulation and the EU Battery Regulation are particularly impactful. The ambitious recycling targets, stringent material limitations, and new requirements for battery design and labelling pose significant challenges for brands with global distribution. Additionally, the overlapping and sometimes conflicting regulations between the EU and US states, such as California (with its California SB 54 regulations) and Washington (with its HB 1131 and SB 5154), as well as other regions with PFAS restrictions in packaging, create a complex regulatory environment. States like New York, Colorado, Maryland, and Vermont are also introducing packaging regulations, further adding to the complexity.   Then there's the mountain of paperwork for WEEE (Waste Electrical and Electronic Equipment) compliance. Each country has its own reporting requirements, formats, and deadlines – a logistical nightmare for any captain. Setting up collection centers for used electronics and batteries in each territory adds another layer of complexity.   However, amidst these challenges, there are also positive trends. As regulations tighten, we are witnessing a significant shift towards eco-friendly packaging solutions. This trend is driving a surge in demand for sustainable packaging materials. However, this shift also necessitates increased testing to identify potential hazardous substances in packaging materials, both to comply with regulations and meet customer demands. This, in turn, is leading to a rise in demand for testing lab services. To ensure efficiency and cost-effectiveness, collaboration between brands, packaging suppliers, consultants, and testing labs is crucial

♻ Mandated Packaging Laws. 💸 Official betting is now open!!! Attended Australian Packaging Covenant Organisation (APCO)'s 2024 Roadshow, shaping their 2030 Packaging Strategy yesterday. Phew!!! heaps of work to be done!!!! Their proposed Eco-Modulation EPR scheme, whilst probably the most equitable scheme if applied to ALL brands owners above relatively low threshold, is hugely ambitious. ▶ Will it be accepted by Govt? ▶Will it be accepted by Brands? ▶Will consumers & households buy in? ▶What will the cost of implementation/management be? ▶Who'll pay for it? ▶Will brands be prepared to appoint APCO as their de facto proxy to efficiently & economically drive the critical waste management part of the equation? ❓ These are all big questions to which there are no answers as yet. Not knocking APCO, but to me it looks like they've put up their hand to try & eat a whole elephant in one sitting. Perhaps the proposed PRO's that will come into being as a result of the EPR schemes can shoulder some of the burden? Remains to be seen. The biggest ❓ 's for me are: ❓ When & how recovery/recycling infrastructure will be able to match pace with packaging design targets/mandates? Without that the scheme fails. ❓ How waste collection & materials recovery, at the local level, can be harmonised NATIONALLY? Chris Foley rightly spoke about a level playing field (the whole point of eco-modulation) but, if different states, councils, commercial operators don't offer consistent services/pricing nationally, that level playing field doesn't exist. ❓ How to simplify waste separation/collection at source, making it easier for consumers to at least give the system a chance to work? On this point I'm in favour of the OPRL Limited simple, binary labelling system of Recycle/Don't Recycle - leaving substate separation to the experts at MRF's. Any bets on when these mandates will become binding & the EPR scheme will be fully functional? - I'm offering an ⬆ over/under ⬇ of July 2029!!!! 💰 place your bets please! I'm not being cynical either, I am in favour of an EPR scheme & I believe the Eco-Modulation proposal makes the most sense, but I'm realistic & have lived through an EPR scheme implementation which took 4 years of discussion, debate, structuring and then another 2 years to be enacted. So, most definitely start planning for dramatic change, get your ducks in a row, but certainly don't hold your breath, we're in this for the long haul. On the point of collection/recycling infrastructure, let's fantasize on what it could look like come July 2029. Check out the Netherlands kerbside collection system. 👇 Thats gold! 🥇

EU Packaging and Packaging Waste Regulations. Clearly unclear The European automotive industry has always made significant efforts to move to more sustainable packaging solutions but with even more stringent requirements on materials and recyclability soon to be introduced by #PPWR, the Odette #Packaging Experts Group has brought together actors from all parts of the packaging supply chain to collaborate at European level to face up to the challenge. 📌Current focus is on the development of an Odette Sustainable Packaging Guideline which will serve as a guide to develop environmentally friendly packaging solutions and help the industry prepare for the forthcoming legal requirements. Taking a lead from national automotive sustainable packaging guidelines, views from the entire supply chain, from packaging manufacturers to part suppliers and vehicle manufacturers to recyclers are being examined to create a common understanding of the requirements. The guideline will describe ways to use materials more efficiently, reduce waste and promote recycling to minimize the environmental impact of packaging to further establish and promote the circular economy. 📚The Odette Sustainable Packaging Guideline will be available in the early part of 2025. In the meantime, work continues to decipher the latest draft legislation in order to identify the materials to be used, the partners involved, the data required, the targets to be achieved and any new marking and/or labelling requirements. ✅The objective is to produce a digest of the regulations to assist the entire industry. This work also assists in the preparation for lobbying at an EU Stakeholder Meeting, which we hope will take place before the end of this year. We continue to gather questions and comments from automotive packaging experts for discussion with the EU representatives. Facing up to the Packaging Sustainability and Regulatory Challenge will be on the agenda at #odette2025 Conference in May in Bratislava. #ppwr #odetteinternational #packaging

Brands at GreenBlue Org and Sustainable Packaging Coalition (SPC) #SPCAdvance have generally been supportive of Extended Producer Responsibility (#EPR) legislation, even if they're likely to foot the bill on fees. There's a sense of resolve, acceptance of responsibility, even an eager willingness to comply. But they also urge better alignment among disparate laws in disparate states. A federal law would seem to be a silver bullet, but it also seems unlikely in the near term. In a panel moderated by The Recycling Partnership that included panelists from Sealed Air Corporation, Ball Corporation, and PepsiCo, Jeff Bezzo of SC Johnson explained the benefits of EPR harmonization. “What we'd like to see is some foundational principles. What are the covered materials, for example? We don't want to dictate what's right in each state, as far as the infrastructure that's needed and things like that, but it would be helpful to have a common set of language. For example, what is a "responsible producer?" What's the definition of that? If we could get to common principles, even labeling, it would really help avoid what's becoming a patchwork of legislation. We are for EPR, but what we'd like to see is a much more harmonized approach, because it truly is getting very difficult to navigate,” he said. He also thinks common incentives and fee structures will have a harmonizing effect. "Some of the eco-modulation schemes will help, from the standpoint of result reviews for example, and driving those sorts of systems. PCR content, I expect, will be one of the other key elements of eco-modulation. From the incorporation of PCR all the way through packaging design, we're going to see more innovation. Of course, the fee structures themselves will help drive towards more common materials. That will be helpful, just from the standpoint of the recyclers and all the way through the supply chain.”

An update of our international Guide on plastics and packaging laws has been launched. You can find more information on the topic here: https://lnkd.in/gWDA__wa #cmslaw #esg #plastics #packaging

Controversy surrounds PPWR agreement by EU legislators “Plastics Recycling World” reported that the European Parliament and Council reached agreement in March on an amended Packaging and Packaging Waste Regulation (PPWR). But the regulation has left many stakeholders dissatisfied, with some criticising the unequal treatment of plastics, and some raising trade concerns.  Germany’s IK association of plastics packaging producers said PPWR had been “transformed into an anti-plastics regulation” favouring other materials which could lead to worse environmental outcomes. “Food packaging made of paper and cardboard usually cannot do without a plastic coating, as uncoated fibres cannot retain moisture or grease. Compared to pure plastic packaging, however they are significantly less recyclable and are also 40% cent heavier on average, which has a negative impact on energy consumption.”  European plastics converters, released a legal assessment in February suggesting that PPWR’s special rules for plastic packaging and exemptions for other materials “are very likely not compatible with EU law”. It said this could lead to an “avalanche of European or national legal disputes and, as a result, to instability of the framework and the undermining of the circular economy for packaging that it aims to establish”. Legal challenges from outside the EU may also arise from the “mirroring” clause, which was reported to have alarmed European Commission trade officials about its potential for causing trade disputes with non-EU countries . A study in February’24 had shown that without the necessary investment, the PET recycling rate in Europe could fall 38% by 2040. 

📣 EU co-legislators reached a deal on the Packaging and Packaging Waste Regulation (#PPWR) yesterday evening. With the election fast approaching, time was running out to finalise this highly anticipated agreement. The provisional political agreement now needs to be green-lighted by the European Commission (which has expressed some trade-related concerns over a specific measure), the Council of the EU and the European Parliament (at the latest in its Plenary on the week of 15 April). The coming days will still be crucial as technical details will continue to be ironed out. What are some of the changes to expect?  📦 The new Regulation established safety and sustainability requirements (e.g. on recyclability, substance of concerns like PFAS, minimum recycled content...); 📦 It lays down harmonised labelling requirements for several aspects of packaging;  📦 It also mandates waste prevention measures, including binding re-use targets (with several exemptions specified in the text), setting up of deposit-return systems, restricting certain types of single-use packaging or requiring economic operators to minimise the packaging used (including a maximum of 50% void-space limit for transport, grouped and e-commerce packaging); 📦 It creates an obligation for producers to comply with Extended Producer Responsibility and mandates the setting up of national EPR registries. You can find more information in the Council and European Parliament's press releases: 👉 https://lnkd.in/eqTm7iU5 👉 https://lnkd.in/ekvGSngB cc Ecommerce Europe

Is the deal done? How do you feel about the #lastminute changes to the #EU #PPWR? There are new rules for #packaging #reuse, #singleuseplastics #bans but not the same for #singleuse paper packaging, and an unnecessary space maximum for transport and #ecommercepackaging that is quite generous indeed. The latest compromise is expected to face a plenary vote in April. Is this an example of the leadership that we need to advance plastics circularity? https://lnkd.in/e7biAhax

📢 REGULATORY UPDATE: Proposal for a revision of EU legislation on Packaging and Packaging Waste.   📅 The new Packaging Regulation is expected to be published by the end of 2024. The new framework will repeal the Packaging Directive 18 months after its entry into force. 📦 As a Regulation, the new legislation will be applicable directly in all EU Member States, harmonizing the packaging requirements across the European Union. 📜 The provisions will affect the whole lifecycle of the packaging from its design to its end-of-life treatment. New requirements will include but will not be limited to: ◾ The Digital Product Passport (DPP) - The DPP will provide information on the packaging properties through a digital carrier (QR code) for both end-users and competent authorities. ◾ Labelling ◾ The packaging will carry instructions regarding its manufacturer and importer, reusability, and environmental sound disposal. ◾ Packaging recyclability ◾ The packaging recyclability will be measured in Recyclability Grades. Non-recyclable packaging will be banned from the market. ◾ Minimum recycled content ◾ Plastic packaging will be required to have a minimum recycled content. ◾ Measures better waste collection and recycling will be introduced.   👤 Our Team: Meet our team specialist, responsible for tracking updates on the New EU Packaging Legislation:   🔹 Filomila Koutsogianni, Environmental Compliance Manager (The Netherlands)   ℹ Please get in touch with us if you require further information ([email protected]).    #EU #packaging #packagingwaste #packagingdesign #environmental #environmentalcompliance #EPR #extendedproducerresponsibility