Miljøprojekt, 1091 – Emballagedirektivet

The EU Packaging Directive was adopted in 1994 and implemented in Denmark in 1997. Therefore, one might assume that Danish companies are familiar with the Directive. However, the situation is quite different, and nobody is presently able to guide the companies on how to meet the requirements laid down in the Directive. Therefore, together with a number of participating companies, the Danish Technological Institute offers a guide to other companies through this project, which is carried out by the Confederation of Danish Industries and financed by the Danish Environmental Protection Agency (Danish Ministry of the Environment).

In this guide the Danish Technological Institute interprets a number of rules which are not yet final. The guide focuses on a number of texts that companies have found difficult to understand, and translates them into practical, understandable methods. On top of that, a large number of companies have gained financial benefits as well from using the guide.

Background and purpose

Background

In 1994 the EU adopted the Directive on packaging and packaging waste. This Directive was implemented in Danish legislation in 1997. Even though a number of years have passed since the Directive was adopted, many companies are still not meeting the obligations set out in the Packaging Directive. This is among other things due to the fact that instructions are only described in broad terms in Encl. II, and, moreover, to the fact that European standards giving the companies better guidelines should have been worked out. These standards were finally approved by the EU in February 2005. Even these standards are very general, thus still leaving the companies with no precise guidance on how to observe to the rules.

Anyone introducing a packaging or a packaged product on an EU market, must observe the following:

The company responsible for meeting these requirements must be able to document in writing that these demands are met, when requested by an EU authority. Unfortunately, the Directive contains no accordance procedures, leaving the individual countries room for individual interpretation. Export companies should be aware of this fact.

Purpose

The purpose of this project is to provide the companies practical methods enabling them to meet especially the packaging minimization demands (Annex II of the Packaging Directive).

The Investigation

This project was initiated before the relevant standards were agreed upon. Therefore, the project partners have worked on the basis of the Directive as it was and the standard proposals known at that time. Work was initiated in four companies, working together two by two: a packaging producer and one of their customers were co-operating on how to meet the directions in the Packaging Directive. Later on, another pair started work at a time where the standards were close to being adopted. This pair was also a packaging producer and one of their customers.

From this practical experience, the partners have prepared a guide, presenting the methods which we assumed could be accepted by a national authority. It should be noted that this guide is an interpretation made by the Danish Technological Institute and the participating companies. It will take some time before all EU countries have adopted final legislation on this subject. Only then administrative and legal practice will decide what is sufficient and what is not.

Towards the end of the project, a third group was included, so a total of eight companies have participated in preparing this guide, although this final pair had not concluded their work by the end of the project period.

The participating companies are: Glud & Marstrand, Tulip, Færch Plast, Danish Crown, SCA Packaging, TRIAX, SCA Flamingo and Grundfos.

The project has been closely linked to a Nordic development project, OPTI-PACK, where packaging specialists from 40 companies and institutes in Denmark, Finland, Iceland, Norway and Sweden have co-operated on related subjects.

Main conclusions

Project results

The most challenging part of drawing up an understandable business guide has been to sort out the relatively unknown basis for the project. On numerous occasions, the partners have asked themselves whether they were interpreting the rules correctly. They have experienced that the task became easier when it came to solving an actual task. A simple question of whether a representative of the authorities would accept this or not often gave the answer. The difficult part has been to accept that documentation should be in writing.

The essential chapter 6 contains lists of methods which the companies can use for such documentation. These methods are merely suggestions made by the Danish Technological Institute and the case companies. Only future will show, whether the authorities will be demanding more or less.

Therefore this interpretation is solely the Danish Technological Institute’s responsibility.

The guide starts with a short review of the current directives, statutory orders and standards.

Any company introducing a packaging or a packaged product to an EU market is responsible for observing these rules. Typically, it will be a producer buying packaging for a product (packer/filler). It could also be the packaging producer, an import/export business or a retail chain with its own brand.

The responsible company must do the following in order to meet the directive’s requirements:

The above mentioned demands are described in six European standards and two reports. Two of the six European standards give a precise guideline for the companies on how to determine whether the packaging meets the demands or not. The other four standards are system standards securing that the companies have been through a process. These four system standards have been very difficult for the companies to implement, since there is not precise guidelines on how to proceed.

A long list of documentation methods is included in chapter 6. This list can be found neither in the Packaging Directive nor in any of the standards. The intention is not for the companies to use all methods. The intention is that this guide can be used as a dictionary or/manual, where the company can pick and choose the method which fits each individual situation most efficiently - irrespectively of whether you use annex II or the standards.

All kinds of documentation method are described. Some are practical observations or tests. Other methods are more complicated, and, finally, the scientific methods are mentioned as well in this guide. The methods are described very briefly - somewhat like a check list. The experience from practical use in the participating companies shows that everybody consider these check lists a great help to get started with practical work, as they are handy and self-explanatory.

The guide works with the company’s own documentation as well as the documentation which can only be provided by the subcontractors. However, it is not always possible to obtain the correct documentation from subcontractors. In such cases, accordance declarations are a possibility. The guide presents an example of this. It is important that the subcontractor assumes authority control, if an official authority expresses doubt whether the rules have been met.

By and large, all the participating companies have been through the same process. Initially, they become very frustrated with the demands, but quickly the majority realises that the task is manageable and actually brings about financial savings for the company.

The guide also includes the participating case companies’ experience with this project. It is very interesting to observe that several of them have obtained actual savings, even on packaging for which they thought optimum requirements had already been met.

The project has achieved as much as a 25% material reduction and, at the same time, a 15% transport volume reduction for the same product. The product value has even increased, because it was possible to prove accordance with the Packaging Directive.