Update on Regulatory Affairs

Pro Carton focuses on two Regulatory Affairs topics: the Circular Economy legislative package and LCA environmental policy. Circular Economy Pro Carton is following the progress of the European Commission’s Circular Economy package of proposed legislation, in order to assess its potential impact on the carton industry. Pro Carton acts together with other paper based packaging associations in Brussels, in order to minimise any negative impact wherever possible. The Circular Economy legislative process affecting cartons is nearing its conclusion. The original proposals from the European Commission, presented in December 2015 were discussed in length by MEPs. The European Parliament finally adopted its position on the Circular Economy on 14^th March. The Council of Ministers also debated the proposals and agreed their position on 19^th May. This paved the way to open negotiations between the European Commission, the Council of Ministers and the European Parliament to find an agreement. These Trilogue negotiations are currently taking place behind closed doors and are scheduled to continue until the end of October 2017. The negotiations promise to be tough as several of the positions adopted by the different Institutions on key topics are quite wide apart. For example, the packaging targets for paper and board proposed by the European Commission suggest a minimum recycling target of 75% by 2025, whereas the European Parliament calls for a minimum target of 90% and the Council of Ministers proposes 70%. A crucial question that affects the achievement of any recycling target, that must also be agreed, is where to fix and measure the point at which recycling actually takes place. The paper based associations promote the view that “real recycling” takes place only at the input to the final recycling process. Together with other paper based packaging associations in Brussels, Pro Carton developed a Position Paper on the key topics of legislation affecting paper based packaging. This Position Paper was presented and discussed with Commission officials and MEPs during the course of the process. Pro Carton also worked with the Packaging Chain Forum which represents the whole packaging value chain. A key objective of this Forum is to defend the free movement of packaged goods in the European Union, which is currently threatened by a change in the legal basis of the Packaging and Packaging Waste Directive, proposed by the Council of Ministers. Together with sixty six packaging related associations, Pro Carton signed an industry statement in order to bring the dangers of changing the legal basis to the attention of the Trilogue negotiators. LCA and Carbon Footprinting Pro Carton is currently working together with CITPA, the European association for converters of paper and board products, to prepare a methodology which is up to date with the latest ISO and European standards, and will deliver a scientifically credible way for the paper packaging industry to present its environmental credentials. Pro Carton prepares an Environmental Data Report of the major environmental impacts of producing printed cartons, every three years which is available on request to LCA experts. The CITPA methodology is scheduled to be complete before the summer break, and then Pro Carton will apply it to data from cartonboard producers and carton converters in order to compile a picture of the industry’s current environmental performance. With this data, Pro Carton can also calculate an up to date Carbon Footprint figure, which is the European Industry average for production of printed cartons.