Packaging standards discussion raises questions over “new approach”

DG Environment has in a recent working document outlined possible options concerning the future use of CEN standardisation for packaging waste. Stakeholders and Member States are being consulted on the document.

The sustainable resources unit of DG Environment has in a
working document identified complications with the standardisation
of packaging. It has raised issues that are now being discussed
internally, as well as with the Member States and other

DG Environment suggests that there is an inherit
problem with the “new approach” in that the CEN is actually asked
to go beyond technical decisions, and include political
considerations. In the directive, the essential requirements lack
specific limit values, which is the main reason why the CEN
standardisations could not set pass/fail standards. Limit values
would however need to be set on political level. DG Environment
proposes the following limits:

  • minimum trip or rotation rate for plastic/glass bottles:
  • minimum recyclable content: 80-100%
  • minimum calorific value: 8-15 MJ/kg

The sustainable resources unit of DG Environment
is however not convinced that this is the way forward since the
basis for choosing one minimum standard over the other would be
arbitrary, the life-cycle approach would be ignored, and it would
take years to get the proposal through the legal procedure. In
addition, experience shows that minimum standards are not efficient
for packaging, since there are so many types, materials and
functions of packaging.


Industry is in general positive to the new "approach" to let
CEN develop standardisations instead of setting politically decided
limits. The European organisation for packaging and the
EUROPEN, states that the working document from DG
Environment contains inaccurate descriptions and perceptions of how
the directive works.

The European Environmental Bureau (EEB) has
repeatedly criticised the CEN standardisations, as well as the "new
approach". It stated that "The EEB is convinced that politics
should have the last word even if tasks are assigned to private
bodies". The EEB also finds it problematic that the CEN's working
groups are dominated by industry, with little representation by
environmental groups or governments.


The Packaging and Packaging Waste Directive (EC 94/62)
imposes "essential requirements" for what kind of packaging should
be allowed on the EU market. To operationalise these requirements,
the CEN (the European standardisation body) was asked to produce
harmonised packaging standards. The delegation of the task to the
CEN was done in accordance to the "new approach", to avoid that the
EU legislative procedure deals with details, and to ensure a fast
decision that later on can be revised quickly.

In September 2000, the CEN issued five standards, of which only
two were accepted by the Commission. There has been serious
criticism of the CEN and the work it has done (see also

5 October
10 October
). in December 2001, the CEN received a
new mandate until 2003 to revise the standards so that they comply
fully with the essential requirements in the directive.


The sustainable resources unit of DG Environment has given
stakeholders and Member States until 20 March to give comments and
suggestions to the working document.


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