The EU Packaging Directive requires the following of a company:
- Minimize the packaging system so that the packaging just fulfils its purpose - protection, display, information, distribution adaptation etc.
- Make sure that each packaging component contains no more than 100 ppm. heavy metal.
- Minimize the use of environmentally hazardous components according to EU Directive 67/548.
- Meet special demands if the packaging is to be re-used for the same purpose.
- Make sure that the packaging meets at least one of the following demands:
- Recoverable to other materials
- Combustible with energy recovery
- Compostible or biodegradable
Ad) 1. The logical approach would be for the company who brings a packaging or a packaged product to the market to deal with these requirements. This means that all sorts of companies will be performing this task - big or small. It is possible to use the Annex II of the Packaging Directive as well as EN13428. The contents are identical. Our experience during this project has been that the companies need more concrete suggestions for the practical work. Therefore this guide in Chapter 6 has been a good tool for the companies.
Ad) 2. For most companies it will be impossible to obtain the information needed. The necessary data will typically be with the subcontractor or maybe even sub subcontractors and they will normally be very unwilling to provide other than an accordance declaration. See Encl. C. It is recommended, that it is the packaging supplier who uses CR 13695-1.
Ad) 3. The same applies here. For most companies it will be impossible to obtain the necessary information from the subcontractors, so an accordance declaration is in practice the only way. See Encl. C. It is recommended, that it is the packaging supplier who uses CR 13695-2.
Ad) 4. Most companies do not use re-usable packaging, so they don’t have to meet this requirement. In this case EN 13429 should be used.
Ad) 5. The three ways to recycle the packaging requires use of the standards EN 13430-13432. Like mentioned previously it is not realistic to expect the company buying packaging for their products to take on the responsibility. These companies should be able to obtain an accordance declaration from their packaging suppliers. The packaging suppliers should work out these declarations according to the standards. One should be aware that all three recycling methods are not available in all markets.