Our sector is consistently working to reduce its already limited environmental impact, using state-of-the-art research and innovation to cut down on packaging volume and weight, increase recycled content and eliminate waste.
We welcome the choice of the Commission to opt for a Regulation rather than a Directive. It is of vital importance to us, our suppliers and the many other sectors we work with that there is consistency and a level-playing field in the application of these proposals across the EU, in particular since we have recently seen the threat of a fragmentation of the Single Market by the implementation of some country-specific measures on packaging.
We also welcome and encourage the proposed use of QR codes and other digital innovations as an effective and user-friendly means of providing information to the consumer on recycled content, reuse information, etc. via digital means. The spirits sector, working together with wine, already has its U-Label digital platform which offers a means, via QR codes, of providing this information to the consumer. In addition, a partnership was signed recently between U-Label and the Italian-based Giunko company to ensure consumers can access digital information about product packaging and recycling in Italy as of 1 January 2023. As a result, a single QR code will serve as digital one-stop shop for nutrition & recycling information!
We welcome the recognition that mandatory re-use targets for spirits are not the most suitable way forward. Our sector already implements and tests new waste management models, including packaging reuse models, to deliver the best environmental outcomes. With many of our sector’s companies producing to export, with long supply chains and GI regulations and rules governing bottling in third countries, there is no “one size fits all” model from a carbon footprint /consumer safety perspective for spirits. Freedom to innovate must be given to industry to continue to invest in breakthrough packaging innovation and R&D.
We are concerned about the Commission’s plans to remove “marketing” and “consumer acceptance” from the performance criteria for packaging. A result of this could be restrictions on brand differentiation and product presentation which is key for our sector, a sector that does not produce ‘fast consumed’ products. As we strive to make our packaging more sustainable, the diversity of different and unique packaging designs should not be undermined by the new rules.
We look forward to engaging with the European Commission, the European Parliament, Member States and relevant stakeholders as the debate on this proposal moves on to its next stage.
