Our associations, representing the spirits, wine and container glass sectors support the objectives of the Packaging & Packaging Waste Regulation (PPWR). Our members are fully committed to improving product sustainability and to reducing the weight of their packaging. Light-weighting and innovation help us cut costs and carbon footprints.
While we support the overall objective of packaging minimization, we fear that as it stands the PPWR proposal will severely restrict packaging design, with serious side-effects on far-reaching negative consequences on consumer-choice, product value, brand identity and the competitiveness of the European industry.
Design is key to brand building, elevation, premiumisation, differentiation and recognition by consumers. Packaging represents the product it contains and its brand. No longer including ‘consumer acceptance’ and ‘marketing and product presentation’ in the performance criteria (Annex IV) related to packaging minimisation (article 9) carries the risk of having detrimental effects on the design of packaging, leading to standardization.
Many packaging designs are integral to the EU’s tradition, cultural heritage and know-how. Intellectual Property rights (including Geographical Indications and trademarks) play a vital role for sectors whose businesses rely directly on the added value of their innovations and on the tangible and intangible values of their products. IP rights are key to brands’ competitiveness on EU and global markets, while guarding against counterfeiting off and online.
On top of its health and environmental credentials, the unique characteristics of glass in terms of design, transparency, shapes, colours and versatility make glass an integral part of the product, helping brand recognition and appealing to consumers.
Glass-packed products promote the reputation, image, competitiveness and profitability of Europe’s industry worldwide, boosting exports and helping the EU’s trade balance. Products contained in glass make up €250 billion of EU external trade.
Our sectors consider that it is critical to understand and acknowledge the value added of packaging in the product and the diversity of packaging functionalities to contribute to innovation, competitiveness & sustainable growth.
We believe that packaging should be designed so as to optimise its volume and weight while maintaining its ability to perform the packaging functions and allowing for reasonable and proportionate design differentiation.
23.05.2023, FEVE
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