spiritsNEWS March 2021

Revision ahead: the EU’s Packaging & Packaging Waste Directive

Packaging – such as glass bottles, in which more than 90% of spirits are sold in the EU – has received increasing attention in the last months, both on Member State and EU level. Many times, glass is the packaging of choice for our spirit producers. It reliably protects our valuable product during transport and storage, it is safe, responds to consumer demands and encourages the responsible consumption of spirit drinks.

In the EU, legislation on packaging is among others, delivered via Directive (EU) 2018/852 on Packaging and Packaging Waste. As is the case with Directives, significant room to maneuver is left to the Member States who are responsible to deliver on the results to be achieved. Whilst accounting for the many different ways in which Member States organise their packaging and packaging waste dealings, this can create challenges for the users of packaging: they are faced with diverging rules and requirements packaging needs to fulfill in order to be lawfully placed on the market. The reality is that some Member States require recycling information, which is banned by others! And there are a good number of examples we are confronted with today.


In France, for instance, the application of the Triman logo on packaging is a requirement to place a product lawfully on the market. Such additional marking requirements infringe the EU’s internal market – just as the ban of products featuring the ‘Green Dot logo’, which France intended to apply as of 1 April 2021 (ban currently under suspension). Importantly, the application of the ‘Green Dot logo’ is mandatory in neighbouring countries, e.g. Spain.

Producers of spirit drinks selling their products in The Netherlands are facing challenges in the form of new requirements regarding bottles’ weight, which are specific to the Dutch market and – again – would infringe and endanger the internal market. The Packaging and Packaging Waste Directive’s double legal basis – the protection of the environment as well the internal market – gives way to such requirements.

We have always been active and vocal in favour of the Internal Market in order to ensure the free movement of goods between Member States.

The European Commission has announced the revision of the Packaging and Packaging Waste Directive under the leadership of DG Environment and in the wider context of the European Green Deal. The first legislative proposal for a revised Directive is expected towards the end of 2021 or early 2022. Rumor has it that the review will focus on packaging design, re-use, and recycled content. A workshop will be organised in June by EUNOMIA - the consultant to the European Commission – with all the relevant stakeholders, including spiritsEUROPE. We expect the discussions on packaging to be very rich and interesting given that packaging fulfills various functions touching political cornerstones such as the internal market, consumer and environmental protection as well as product safety, to name the most obvious ones.

We will represent and defend the interest of our producers within the frame of our ongoing work on sustainability covering environmental considerations, social responsibilities as well as economic imperatives.

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