The Federation of German Food and Drink Industries (BVE) is demanding amendments to the planned implementing act for the EU Packaging Regulation (PPWR) producer register. The focus is on a uniform EU-wide data set for packaging as well as the avoidance of duplicate reporting and divergent national requirements.
The European Commission's draft specifies the requirements for producer registers pursuant to Article 44 of the PPWR. In the view of the BVE, the implementing act should keep the bureaucratic burden for companies and authorities to a minimum. To achieve this, uniform specifications for reporting, data collection and reporting obligations are particularly necessary.
Standardised packaging data
The BVE is proposing a binding European core dataset for packaging. Among other things, this should include packaging components, types of packaging, material categories and subcategories, as well as the weight of the individual components and the total weight. Additional technical details should only be required if they are expressly mandated under EU law.
At the same time, the association is calling for EU-wide binding definitions and classification rules. This concerns, for example, composite and multilayer materials, coatings, labels and closures. The aim is to prevent the same packaging from being classified differently in various member states.
National EPR requirements should also be based on the European core dataset. For additional national reporting categories, the BVE proposes a binding mapping. This would mean companies would not have to maintain different data structures for the same packaging.
Criticism of duplicate reporting
The BVE also critically assesses the administrative burden for companies operating across Europe. Despite harmonisation, manufacturers still have to register in every member state in which they make packaging available on the market. The individual registers have to be maintained and updated separately. The BVE therefore advocates for the central management of master data with a single point of entry.
According to the association, duplicate reporting of packaging data should also be avoided. Quantities and material compositions are in many cases already collected by extended producer responsibility organisations. Additional reporting of the same data in the producer register increases the administrative burden. The BVE suggests obtaining this information from the EPR organisations instead.
Source: Federal Association of the German Food Industry
