European Plastics Converters (EuPC) recommends a thorough revision of the proposed technical regulation.
While EuPC welcomes the initiative to provide clarity in distinguishing between single-use and reusable plastic food-contact products, where an EU-wide harmonized definition is currently lacking, the proposed technical specifications raise significant concerns regarding practical implementation, compatibility with the principles of free competition, and potential adverse environmental impacts.
Limiting the assessment of reusability for plastic food-contact articles solely to parameters such as weight and shape is insufficient and fails to reflect existing technical standards and specifications necessary to ensure the quality, safety, and durability of genuinely reusable products. To ensure alignment with the objectives of Directive (EU) 2019/904, additional and alternative criteria should be incorporated into the proposed regulation, including:
- Reference to UNI EN 12875-1:2005 to ensure resistance to high-temperature washing cycles,
- Proven durability over multiple uses complying with the migration testing of Regulation (EU) 10/2011,
- Product design principles that emphasize robustness without encouraging excessive material use.
Please find attached our detailed contribution.
