Sean Milmo, European Editor05.11.18
Action on plastic packaging waste is gathering pace across Europe at European Union (EU), national and local levels. The impetus is coming from a growing desire among European consumers for something to be done about the increasing danger of plastic waste to the environment.
Another driver are moves to set up circular economies across Europe in which as much as possible of plastics and other materials are recycled or reused to achieve a drastic reduction in waste. This is especially the case with packaging waste.
To encourage high levels of reuse, plastics and other materials for recycling will have be clean and safe. Ink producers can expect new restrictions on packaging ink chemicals that are regarded as being harmful to health or a long-term threat to the environment.
Currently the main curb on ink chemicals in packaging relate to those in food packs whose chemicals could migrate into the packaged food products.
Restrictions on ink chemicals in recycled plastic packaging could be much more radical and wider in scope. They are likely to be a mix of regulatory and voluntary limits, which could result in ink makers and packaging converters having to deal with fragmented and inconsistent sets of rules.
Brand Owners and Retailers
Many of the initiatives on plastic packaging have been made by individual brand owners or retail chains that have set themselves targets for reductions in their own plastic packaging waste.
In late April 2018, a UK Plastics Pact was set up comprising 42 businesses, including most of the country’s leading supermarket chains and owners and manufacturers of major food, drink and non-food brands together with plastic reprocessors and packaging suppliers.
The pact’s objectives are that by 2025 it will eliminate “problematic and unnecessary” single-use plastic packaging, achieve 100% reusable, recyclable or compostable plastic packaging and 70% of plastic packaging being recycled or composted. In all plastic packaging, there will be an average 30% of recycled material.
Some members of the pact acknowledge that one result will be a decrease in the use of plastics, whether made of virgin or recycled material. “For our part we accept our responsibilities and are working hard to reduce the use of plastics across our business,” said Mike Coupe, chief executive of Sainsbury, a leading UK supermarket.
The members of the pact include the UK arm of Nestle, the Swiss-based food and beverages giant, which in April 2018 announced a plastics waste action program with the main objective of achieving 100% recyclable or reusable packaging by 2025.
The company issued a Guidance Note on Packaging Inks in August, 2016, with a negative list of components to be excluded from inks, primers and overprint lacquers, coatings and varnishes. The main purpose of the note, which has become a standard in the food packaging sector, has been to deal with the issue of migration of chemicals in food packaging. It is likely to be updated to be made more directly relevant to the recyclability of materials and chemicals.
Government Action
At the EU level, a number of regulatory measures are already being introduced. The European Parliament has been amending an existing piece of legislation – the EU waste framework directive – to restrict use of potentially harmful substances in recycled materials. Packaging suppliers will have to notify the European Chemicals Agency (ECHA) of the presence of substances of very high concern (SVHC) in materials in waste streams.
The amendment has been introduced within the context of the EU’s plans to develop a Union-wide circular economy based on, as far as is possible, only non-toxic materials being recycled or reused. Earlier this year, the Parliament approved a circular economy legislative package that sets an EU target of 65% of packaging materials being recycled by 2025.
The European Commission, the EU Brussels-based executive which is responsible for drawing up proposals for EU legislation, has been working on regulatory initiatives specifically targeted at the recycling of plastic materials. These are outlined by the Commission in a Strategy for Plastics issued earlier this year.
“It is stressed (in the Strategy) that the reuse and recycling of end-of-life plastics is very low (in the EU), particularly in comparison with other materials such as paper, glass or metals, and that less that 30% of the annual EU plastics waste is collected for recycling,” per Ales Bartl and Preslava Dilkova, associates at the Brussels office of the law firm Jones Day.
In preparation for the issuing of this guidance, the Commission published a discussion document in January, outlining what it regarded as key issues in dealing with chemicals in waste, including packaging.
The Commission has suggested there should be a mandatory system under which waste management and recovery operators have to be informed about the presence of substances of concern. These substances may not be limited to toxic or potentially harmful chemicals, the Commission has indicated. They may include chemicals, for example, which emit unpleasant odors.
Representatives of small and medium sized companies (SMEs) have been protesting about some of the Commission’s suggestions.
A proposed mandatory information system may work for large homogenous substance families, said the European Association of Craft and Small and Medium-sized Enterprises (UEAPME), whose members include ink suppliers and other companies in the packaging value chain. “A general information system for all substances would be over-proportionately burdensome for SMEs,” it added in a position paper. “A crucial aspect is also the protection of confidential business information.”
A big challenge for producers of inks and their distributors is keeping up to date with what are substances of concern and those which are categorized by ECHA as being substances of very high concern (SVHC), normally toxic chemicals which are carcinogenic or persistent or bioaccumulative. Once listed by the agency as an SVHC, a chemical is destined to be phased out of the market under the EU’s REACH legislation on safety of chemicals.
ECHA, which is responsible for administering REACH, regularly updates its SVHC list. It is also constantly extending the list of chemicals which need to be labeled as being hazardous under the EU’s Classification, Labelling and Packaging (CLP) regulation.
A large proportion of the materials which members of the European Printing Ink Association (EuPIA) are committed to exclude from their inks are based on CLP classifications and/or toxicological evidence “available at the time” of the publication of the association’s latest exclusion list in November, 2016. EuPIA concedes that the hazard-based voluntary approach behind the list is “being increasingly superceded by the management of risks of chemicals under REACH.”
In its voluntary global code on inks, last updated in August 2016, Nestle states that a priority for ink suppliers must be compliance with local legislation on food packaging.
In the absence of local legislation, Nestle requires inks to be formulated with chemicals on the positive list of the seven-year-old Swiss Ordinance for food contact materials. A revision of this law came into force last year but in a version so prone to misinterpretation that EuPIA issued its own guidance on the new legislation.
In addition, Nestle added its own negative list to the code. This included phthalate plasticizers, bisphenol-A, vegetable oils and fatty acid esters with strong odors and solvents and other chemicals in press washes and fountain solutions that emit odor or taint food.
In dealing with chemicals in items like plastic packaging, voluntary codes are likely to become more specific to the needs of particular waste streams.
“Recycling requirements are becoming increasingly complicated because they have to be adjusted to the various stages of recycling processes,” explained Paul East, packaging technologist RECycling Of Used Plastics (RECOUP), a UK not-for-profit organization.
“Often toxicity is not the issue,” he continued. “With pigments, for example, carbon black is a problem because when included in or on food packaging it interferes with the infrared sensors identifying materials during the sorting stage.”
A number of European ink producers have already been preparing themselves for the stricter standards of plastic packaging recycling. Some are involved in development projects aimed at solving technological difficulties like those with carbon black.
Others are going further by creating inks that can be certified as being suitable for full loop cradle-to-cradle (C2C) recycling schemes from the production of raw materials to their use in the next cycle. Hubergroup and Siegwerk have had inks certified by the German-based C2C accreditation body Environmental Protection Encouragement Agency (EPEA).
In the longer term, a major incentive for companies to make plastics packaging inks fit for the circular economy is that inks that do not cause recycling problems will command a higher price on the market, which may help offset any possible decline in plastic packaging demand. n
European Editor Sean Milmo is an Essex, UK-based writer specializing in coverage of the chemical industry.
Another driver are moves to set up circular economies across Europe in which as much as possible of plastics and other materials are recycled or reused to achieve a drastic reduction in waste. This is especially the case with packaging waste.
To encourage high levels of reuse, plastics and other materials for recycling will have be clean and safe. Ink producers can expect new restrictions on packaging ink chemicals that are regarded as being harmful to health or a long-term threat to the environment.
Currently the main curb on ink chemicals in packaging relate to those in food packs whose chemicals could migrate into the packaged food products.
Restrictions on ink chemicals in recycled plastic packaging could be much more radical and wider in scope. They are likely to be a mix of regulatory and voluntary limits, which could result in ink makers and packaging converters having to deal with fragmented and inconsistent sets of rules.
Brand Owners and Retailers
Many of the initiatives on plastic packaging have been made by individual brand owners or retail chains that have set themselves targets for reductions in their own plastic packaging waste.
In late April 2018, a UK Plastics Pact was set up comprising 42 businesses, including most of the country’s leading supermarket chains and owners and manufacturers of major food, drink and non-food brands together with plastic reprocessors and packaging suppliers.
The pact’s objectives are that by 2025 it will eliminate “problematic and unnecessary” single-use plastic packaging, achieve 100% reusable, recyclable or compostable plastic packaging and 70% of plastic packaging being recycled or composted. In all plastic packaging, there will be an average 30% of recycled material.
Some members of the pact acknowledge that one result will be a decrease in the use of plastics, whether made of virgin or recycled material. “For our part we accept our responsibilities and are working hard to reduce the use of plastics across our business,” said Mike Coupe, chief executive of Sainsbury, a leading UK supermarket.
The members of the pact include the UK arm of Nestle, the Swiss-based food and beverages giant, which in April 2018 announced a plastics waste action program with the main objective of achieving 100% recyclable or reusable packaging by 2025.
The company issued a Guidance Note on Packaging Inks in August, 2016, with a negative list of components to be excluded from inks, primers and overprint lacquers, coatings and varnishes. The main purpose of the note, which has become a standard in the food packaging sector, has been to deal with the issue of migration of chemicals in food packaging. It is likely to be updated to be made more directly relevant to the recyclability of materials and chemicals.
Government Action
At the EU level, a number of regulatory measures are already being introduced. The European Parliament has been amending an existing piece of legislation – the EU waste framework directive – to restrict use of potentially harmful substances in recycled materials. Packaging suppliers will have to notify the European Chemicals Agency (ECHA) of the presence of substances of very high concern (SVHC) in materials in waste streams.
The amendment has been introduced within the context of the EU’s plans to develop a Union-wide circular economy based on, as far as is possible, only non-toxic materials being recycled or reused. Earlier this year, the Parliament approved a circular economy legislative package that sets an EU target of 65% of packaging materials being recycled by 2025.
The European Commission, the EU Brussels-based executive which is responsible for drawing up proposals for EU legislation, has been working on regulatory initiatives specifically targeted at the recycling of plastic materials. These are outlined by the Commission in a Strategy for Plastics issued earlier this year.
“It is stressed (in the Strategy) that the reuse and recycling of end-of-life plastics is very low (in the EU), particularly in comparison with other materials such as paper, glass or metals, and that less that 30% of the annual EU plastics waste is collected for recycling,” per Ales Bartl and Preslava Dilkova, associates at the Brussels office of the law firm Jones Day.
In preparation for the issuing of this guidance, the Commission published a discussion document in January, outlining what it regarded as key issues in dealing with chemicals in waste, including packaging.
The Commission has suggested there should be a mandatory system under which waste management and recovery operators have to be informed about the presence of substances of concern. These substances may not be limited to toxic or potentially harmful chemicals, the Commission has indicated. They may include chemicals, for example, which emit unpleasant odors.
Representatives of small and medium sized companies (SMEs) have been protesting about some of the Commission’s suggestions.
A proposed mandatory information system may work for large homogenous substance families, said the European Association of Craft and Small and Medium-sized Enterprises (UEAPME), whose members include ink suppliers and other companies in the packaging value chain. “A general information system for all substances would be over-proportionately burdensome for SMEs,” it added in a position paper. “A crucial aspect is also the protection of confidential business information.”
A big challenge for producers of inks and their distributors is keeping up to date with what are substances of concern and those which are categorized by ECHA as being substances of very high concern (SVHC), normally toxic chemicals which are carcinogenic or persistent or bioaccumulative. Once listed by the agency as an SVHC, a chemical is destined to be phased out of the market under the EU’s REACH legislation on safety of chemicals.
ECHA, which is responsible for administering REACH, regularly updates its SVHC list. It is also constantly extending the list of chemicals which need to be labeled as being hazardous under the EU’s Classification, Labelling and Packaging (CLP) regulation.
A large proportion of the materials which members of the European Printing Ink Association (EuPIA) are committed to exclude from their inks are based on CLP classifications and/or toxicological evidence “available at the time” of the publication of the association’s latest exclusion list in November, 2016. EuPIA concedes that the hazard-based voluntary approach behind the list is “being increasingly superceded by the management of risks of chemicals under REACH.”
In its voluntary global code on inks, last updated in August 2016, Nestle states that a priority for ink suppliers must be compliance with local legislation on food packaging.
In the absence of local legislation, Nestle requires inks to be formulated with chemicals on the positive list of the seven-year-old Swiss Ordinance for food contact materials. A revision of this law came into force last year but in a version so prone to misinterpretation that EuPIA issued its own guidance on the new legislation.
In addition, Nestle added its own negative list to the code. This included phthalate plasticizers, bisphenol-A, vegetable oils and fatty acid esters with strong odors and solvents and other chemicals in press washes and fountain solutions that emit odor or taint food.
In dealing with chemicals in items like plastic packaging, voluntary codes are likely to become more specific to the needs of particular waste streams.
“Recycling requirements are becoming increasingly complicated because they have to be adjusted to the various stages of recycling processes,” explained Paul East, packaging technologist RECycling Of Used Plastics (RECOUP), a UK not-for-profit organization.
“Often toxicity is not the issue,” he continued. “With pigments, for example, carbon black is a problem because when included in or on food packaging it interferes with the infrared sensors identifying materials during the sorting stage.”
A number of European ink producers have already been preparing themselves for the stricter standards of plastic packaging recycling. Some are involved in development projects aimed at solving technological difficulties like those with carbon black.
Others are going further by creating inks that can be certified as being suitable for full loop cradle-to-cradle (C2C) recycling schemes from the production of raw materials to their use in the next cycle. Hubergroup and Siegwerk have had inks certified by the German-based C2C accreditation body Environmental Protection Encouragement Agency (EPEA).
In the longer term, a major incentive for companies to make plastics packaging inks fit for the circular economy is that inks that do not cause recycling problems will command a higher price on the market, which may help offset any possible decline in plastic packaging demand. n
European Editor Sean Milmo is an Essex, UK-based writer specializing in coverage of the chemical industry.