Summary

En fælles forståelse af emballagedirektivets krav til emballageminimering

The general purpose of the project has been to provide for the authorities (The Danish Environmental Protection Agency) and the producers, packers and fillers of packaging a common understanding of the requirements in the EU Packaging Directive regarding the minimisation of packaging, including what level of documentation detail the companies may be requested to present.

As a flexible and operational approach it is suggested that companies establish and maintain a documentation system, which collects knowledge about the good and bad properties of a given packaging and which describes the consequences this knowledge has for its final design. The system outlined in the project includes a number of elements which are judged to be generally important, but there are no formal requirements to the system an individual company chooses to establish. The “important” elements are described in brief at the end of this summary.

The report contains checklists which can be used to focus on packaging minimisation in the development process. Some of the checklists are derived from the standard DS/EN 13428, while others have been compiled from English and French tools for packaging development. An overview of the ten performance criteria in DS/EN 13428 is also provided, listing for each criteria a number of properties relevant under the given heading.

An Annex to the report gives an overview of how the Packaging Directive has been implemented in practice in the United Kingdom and in France. The basic approach differs between the two countries, mainly because of difference in the distribution of responsibility in the value chain. In the United Kingdom, as in Denmark, the packer/filler is responsible for establishing the necessary information upon request from the authorities, whereas in France that responsibility lies with the “packaging designer.” For both countries, however, it is judged that the controlling authorities would largely accept a system approach like the one suggested in this report.

The background for the project

The EU Directive on Packaging and Packaging Waste (94/62/EC) and the Danish notification define three equal requirements to packaging, regarding its reduction at the source, its re-usability and its content of dangerous substances, respectively. In order to help companies fulfil the requirements of the Directive a number of European standards have been established, including DS/EN 13428 which specifies a procedure for assessing packaging to ensure that the weight and/or volume is at a minimum. The standard appears, however, to be used only to a very moderate extent by Danish companies, a probable reason being its rigid requirements with respect to documentation.

In general, in Denmark the responsibility for having the necessary documentation lies with the packer/filler. However, a packaging producer who markets empty packaging (off-the-shelf packaging) is responsible for ensuring that a packaging has been quantitatively minimised before it is handed over to a packer/filler. Companies marketing own-brand products have the responsibility for documentation, irrespective of whether or not a standard solution is chosen.

The DS/EN 13428 approach to packaging minimisation

The structure of the method in DS/EN 13428 is to establish an overview of the requirements to the packaging in relation to each of ten performance criteria, within these criteria select one (and only one!) critical area for source reduction , and then, through different forms of tests, document that the weight and/or volume of the packaging cannot be reduced further without endangering functional performance, safety and user/consumer acceptability. In principle this documentation must be prepared for each component of the full packaging solution, including primary, secondary and tertiary packaging components.

The Directive and the Standard contains formal requirements that test results exist which render it probable that the packing cannot be further reduced. Such relevant tests can be very different in nature, such as for instance mechanical tests (fall, vibration), test shipments via the most demanding routes, or consumer panels in which invited consumers give their personal opinion on whether the packaging fulfil their needs and demands. It is an implicit assumption that the test performed includes a solution which is not satisfying with respect to all performance criteria, and which therefore must be altered in the final solution. An unsatisfactory solution can be that an unacceptable amount of products or packaging is damaged in a test or that users/consumers reject it because of difficulties in handling.

Everyday life of companies

A majority of companies is judged to be motivated to use as little packaging as possible – if not because of environmental concerns then for economical reasons. Many companies handle hundreds of thousands of products daily, and each gram saved in packaging is potentially significant savings, both environmentally and economically.

Many companies are therefore devoting resources to the design and development of packaging solutions which fulfil the requirements of all actors in the value chain and use a minimum of packaging materials. The companies may test their own solutions – or have relevant tests made externally – and when a satisfactory solution is found it will be implemented as soon as possible.

The companies are therefore fulfilling the intention of the Packaging Directive, i.e. to work actively with the development of optimised packaging solutions, but the documentation rarely fulfils the requirements in their strict sense. The approach suggested in DS/EN 13428 is not used to a significant extent because the focus of the companies is to develop solutions that are technologically functional and accepted by all stakeholders in the value chain. At the end of a development process there can thus exist a solution which has been tested in all relevant ways, but for which it has not been documented – as required by the standard - that a critical area (and only one) has been identified or that a lighter/smaller packaging solution will not have the desired properties.

An alternative approach to documentation of packaging reduction

A company working actively in the optimisation of packaging can document this in other ways than by demonstrating that it uses the DS/EN 13428 standard.

The report presents an outline of a system which a company can establish with the aim of being able to provide documentation upon request. The system can function on its own but many companies will probably find it suitable to integrate relevant elements into an existing quality or environmental management system such as EMAS, ISO 14001 or ISO 9001. In essence, the basic function of the system is to pick up information about good and “not-so-good” properties of a given packaging and to store this knowledge together with information on the corrective actions taken.

The following elements are seen as important in a documentation system:

Knowledge obtained in the primary development process. During the process a number of tests are often conducted, and the results of these are often suited as documentation. However, many companies do not store this information in a structured way, e.g. as an integral part of a design review or design brief together with drawings and other technical specifications.
Experience from packaging production. As an example, the failure rate may become unacceptable when large-scale production is commenced, e.g. because a different machinery is used. In such cases the packaging will often need to be re-designed, addressing the critical element in a development process.
Experience from filling processes. When production (the filling process) is started up at the packer/filler, unexpected problems may occur, e.g. in the form of torn or toppled packaging. The cause of such problems can often be characterised as a packaging’s critical parameter, and the documentation of problems and the corrective actions taken are important elements in the dialogue with customers and authorities.
Experience from distribution. If a product is damaged when it arrives at the customer this is a clear indication that the full packaging solution does not give the desired protection. A description of the problem and a statement that it has been corrected is an important element in the documentation of a packaging solution.
Dialogue with sales points. Many packaging solutions are developed in dialogue with future points of sales, and the wishes of customers cannot be neglected if a company wants to remain in the market. It is generally accepted that wishes from retail stores may lead to larger packaging solutions, e.g. providing pilfer resistance, but a formal documentation of this requires a written request from the customer.
Dialogue with end-users and consumers. Only one in fifty consumers reports if the packaging does not function properly from his or her point of view, that is, if the packaging is difficult to open, if the product is damaged, etc. Such complaints must be taken seriously, of course, and corrective actions must be taken if possible. In order to ensure good documentation, the complaints should be stored with the possibility of re-finding it when necessary.

Not all of the elements detailed above will be relevant for a given company, and other elements may be equally important. The report contains a simple checklist which describes central issues and elements of the documentation system, relevant actors and possible types of documentation. With this list, most companies should be able to describe the basic elements in its documentation system.

It is outside the scope of the current project to give more precise directions on how to establish and maintain the system, but a company which has established the basic procedures should be able, as a general rule, to present to customers and authorities information that demonstrates that it works seriously with packaging development and optimisation.