Cetie and the draft SUP directive

Par Nicholas Harris
Le 11/11/2018

The European Commission proposal for single-use-plastic

On 28 May 2018, the European Commission published a proposal for a directive "on the reduction of the impact of certain plastic products on the environment," referred to more simply as the "SUP" directive, for "single-use plastics." 
The introduction to the proposal indicates that it is more specifically aimed at preventing marine pollution, of which 80% to 85% is indicated to consist of plastic, based on the standardised count of waste on European beaches used as the indicator. The ten types of single-use plastic products found most frequently, which are listed in an appendix to the proposal, would be subject to different legislative provisions.
It is no surprise that plastic bottles for beverages and their caps figure in the list of specifically designated products and would be subject to four of these provisions: measures to raise consumer awareness, selective collection targets, extended producer responsibility and product design requirements. 
It is with regard to this last provision that the subject was discussed at Cetie because, in this respect, the project is a 
"New Approach" directive (see this section in L & C 396), and conformity with the regulatory design requirement would be considered in reference to conformity with a "harmonised" CEN standard to be developed under a European Commission mandate. 

EU legislative procedure

We must of course wait for the proposed directive to go through the EU legislative procedure, which involves its adoption by the European Parliament and Council with any amendments agreed by these institutions, to know the precise content of such a requirement and therefore the exact scope of the standard to develop. 
The Commission is nevertheless pushing for the directive to be published before the European elections of May 2019 and the standardisation work should commence rapidly thereafter, in principle within the CEN TC 261 "Packaging" Technical Committee in which Cetie participates via Afnor. 
The proposal includes a time frame of three years after the publication of the directive for the design requirement to enter into force, which would imply an equivalent time frame for drafting the standard, which is relatively short given the incompressible duration of certain phases of the procedure. 
It is therefore proposed that Cetie follow closely the development of the directive to anticipate and actively support CEN's action and work on draft pre-standards from the earliest stages in order to contribute effectively to the process. This subject naturally raised considerable interest within the Cetie "PET finishes" working group because the design requirement, according to the Commission's proposal, would be that plastic bottles "will only be allowed on the market if their caps and lids remain attached to the bottle during the intended use of the product. " 

Significant impact on the industry

If this requirement is maintained in the published Directive, it will clearly have a significant impact on the industry. 
Beyond the support to the CEN in the development of a harmonised standard corresponding to this requirement, it would open a new chapter in Cetie's work on standardisation and good practices for PET bottle closures. 
It was therefore decided to create a specific "SUP" sub-group, whose first discussions effectively confirm the usefulness for the entire value chain to be able to exchange on such subjects in the technical forum provided by Cetie. It has already enabled the participants to access updated information on the progress of the European legislative process and an overview of the action of the national and international industrial federations involved. 

Drafting project deadline

Though the role of Cetie is clearly separate from the "political" process, the group members were able to usefully exchange points of view on the possible technical and industrial impacts of the legislative proposal. 
The industry is clearly committed to fully support the objective of taking action to prevent marine pollution. 
There are however naturally concerns regarding certain aspects of the proposal, in particular concerning the priorities between the various preventive measures and the initially proposed three-year conformity deadline for the requirement that the cap remains attached to the bottle for all products. 
These preliminary discussions with contributions from the entire value chain have enabled Cetie to initiate a dynamic action to support CEN standardisation on this legislative project of major importance for the industry.

N. Harris - Cetie General Secretary for french Magazine Liquides & Conditionnement N°397
PDF (FR) :
- Liquides & Conditionnement N°397 (FR)
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