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Constantia Flexibles GmbH

CFlex

Constantia Flexibles is one of the world's leading manufacturers of flexible packaging.

Lobbying Activity

Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

15 Apr 2024

The proposed change to Article 14, paragraph 4 expands the specific and overall migration requirements to the group of multi-material multi-layer materials with a plastic food contact layer (MMMLs). However, for many MMML packaging materials this will pose a severe problem. The proposed change to Article 17(2), point (a) removes the application of the Euro-cube for containers and other articles, containing or intended to contain less than 500 millilitres or grams. This represents a considerable change to the legislation which would then also affect MMMLs with a food contact layer made of plastic. The attached document explains why we reject those proposed changes. Apart from this, we support the feedback given by Flexible Packaging Europe and by Industrievereinigung Kunststoffverpackungen.
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Response to Restrictions on bisphenol A (BPA) and other bisphenols in food contact materials

8 Mar 2024

As a producer of flexible packaging materials we fully support the feedback of Flexible Packaging Europe which was filed under F3457275 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13832-Food-safety-restrictions-on-bisphenol-A-BPA-and-other-bisphenols-in-food-contact-materials/F3457275_en. Additionally, we thank for the opportunity to give further comments: Article 7, pt. 1 implies that a written declaration might be required for all food contact materials and articles, also if they do not contain BPA or other Bisphenols. However, our interpretation is, that a written declaration is only required for food contact materials and articles, for which BPA or other bisphenols have been used or for materials and articles which fall under the monitoring requirements. If this is the case, this would require further clarification to avoid misunderstandings. Article 10, pt. 3 of the draft text refers to the requirement to issue a declaration of compliance for intermediate food contact materials and articles not complying with the regulation, 9 months before the end of the applicable transition period. Earlier in the introduction, paragraph (18) explains, that it is necessary to consider the "various steps in the supply chain which requires to consider the time needed to manufacture the final food contact article from intermediate materials. Although a definition for intermediate food contact material and article and final food contact article is given in Article 2, pt. 2(a) and 2(b), in some cases it is not so easy to determine if a material or article is an intermediate material or article, or a final article. The definition for intermediate material and article can be applicable for materials like substances and mixtures as defined under REACH Regulation as well as for articles as defined under REACH regulation. To which actor in the supply applies the requirement to issue a DoC 9 months prior to the end of the applicable transition period? Lets give an example: A coating producer delivers a BADGE-containing coating to a converter, who applies the coating to the external surface of a metal substrate. The coated metal is delivered to a further converter who is manufacturing a metal container made from the coated metal. The metal container is sold to a food producer. According to our interpretation, the coating producer and the converter who is applying the coating on the metal surface would have to issue a DoC as manufacturer of intermediate materials and articles. However, until now, there was no legal obligation for the coating producer to forward information on the presence of BPA to his customer, as it is applied on the non-food contact side. If the coating producer informs the converter that is applying the coating exactly 9 months before the end of the applicable transition period, how can this converter issue such a declaration to all its customers (the manufacturers of the final article/container) in time and approve suitable alternatives within 9 months? We suggest differentiating the timeframe for the obligation to inform the downstream users via DoC on the presence of BPA and other Bisphenols, depending on the nature of the supplied intermediate material and article. The information obligation for manufacturers of mixtures (varnishes, coatings, inks, etc) as defined under REACH Regulation which are intended to be used for the production of food contact articles should start much earlier, e.g. 3 months after publication of the regulation.
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Meeting with Angelika Winzig (Member of the European Parliament)

14 Sept 2023 · Verpackungs- und Verpackungsabfall Verordnung

Meeting with Alexander Bernhuber (Member of the European Parliament)

27 Jun 2023 · Packaging and packaging waste

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and EuroCommerce and

28 Mar 2023 · Packaging Waste

Meeting with Claudia Gamon (Member of the European Parliament)

22 Mar 2023 · Perspectives on packaging and circular economy

Meeting with Karen Melchior (Member of the European Parliament, Shadow rapporteur for opinion)

28 Feb 2023 · Discussion of reusable packaging, in depth discussion of compostation practices, chemistry and physics with stakeholder expert, including request to request necessary update of standards.

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

28 Oct 2022 · Implementation of circular economy and the revision of EU packaging rules