Reply to the Feedback Procedure on the Commission's Proposal for a Regulation on Packaging and Packaging Waste

Brussels, 24 April 2023 – AESGP welcomes the opportunity to provide feedback on the Commission Proposal for a Regulation on Packaging and Packaging Waste (PPWR). Given its transversal application to all packaging, AESGP recognizes the clear implications it will have on the self-care sector and looks forward to having an open and transparent dialogue with all relevant stakeholders to achieve a framework that proactively addresses the adverse impact of packaging and packaging waste on the environment and human health.

General considerations

As general considerations, AESGP welcomes the choice of a Regulation as a legal instrument and an internal legal market basis to encourage effective harmonisation between Member States, preventing market fragmentation and the establishment of barriers hindering the free movement of packaged goods.

To ensure legal certainty and promote transparency for economic operators, AESGP calls for the inclusion of clear timelines on the adoption of secondary legislation, where not specified, and for additional transitional periods for economic operators if secondary legislation is delayed.

EU’s horizontal regulatory framework for packaging and packaging waste must be coherent with existing requirements detailed in sectorial legislation, without creating any conflicts.

Specific considerations

AESGP has some specific comments on the draft provisions, notably:

  • Recyclable packaging timelines should be specified with industry partners due to sectorial legislation compliance. Exemptions applying to Medical Devices should cover all packaging materials, not just plastics, to ensure timely adaptation. Small-size packaging that is not detected in sorting facilities should not cause an unduly burden to producers.
  • Recycled plastics with adequate quality, meeting high health and safety standards, must be made available before any mandatory targets on recycled content for the healthcare products sector are set. Currently, recycled plastic suitable for contact-sensitive packaging (other than PET) is still very limited in the EU. Targets for minimum recycled content in plastic packaging should be aligned and consistent.
  • Additional labelling and marking requirements should be relevant and helpful for consumers while being proportionate and feasible considering already extensive labelling requirements applicable under other legal frameworks. Consider digital labelling. Timelines should consider compliance changes and take provisions that avoid wasting resources of products already placed on the market.
  • Empty space ratio (minimum 40 %) is too simplistic and overlooks design requirements that packaging must provide to meet its main functionalities, particularly guaranteeing the safety and efficacy of the products, as is the case for consumer healthcare products.
  • The obligation for producers to provide proof of conformity for each individual package is excessive. The effort to prove and document, with legal certainty, that packaging cannot be smaller or lighter is disproportionate to what is intended to be achieved. Competent authorities should be empowered to request justification from companies on a packaging solution, based on a risk-based control approach.


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