European Association of Steel Drum Manufacturers

SEFA

Scope: To represent the steel industry in the European and Worldwide environment Promote the image of new steel drums Industry voice in Regulatory and government authorities (Eu – National and European level and world wide regulations – UN – RID – ADR – ICAO – IMDG … Main areas of involvement: Transport Regulations, Environment, Safety, National & International Standards: EN – ISO … Collect and communicate steel industry data Cooperation with other industrial Associations in Europe – Metal Packaging Europe (MPE), SERRED, SEFFI and others … Steel industry communication and cooperation on new developments Work with customers and suppliers Leverage on the introduction of new products and technology Work on Industry and product Standards Close cooperation with customers and their associations Supply information to our customers about the industry, products and related regulations

Lobbying Activity

Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

18 Apr 2023

SEFA is the Association representing the steel drum industry in Europe. Our members produce steel drums and other types of industrial sales packaging for various industries such as the lubricant and chemical industry, or the agrochemical and food sectors. Steel is a permanent material which means it has the potential to be recovered and recycled endlessly, without losing its essential properties. Currently, 85 % of steel packaging is recycled. Steels unique magnetic properties also make it easy to recover from the waste stream to be recycled. There is moreover a healthy market for scrap steel, which greatly facilitates its circularity. These unique characteristics have enabled our industry to take major steps to reduce the use of materials needed to produce new steel drums in line with the Commissions objective to minimise packaging. As a result, we are achieving high recycling rates of steel packaging and decreasing the use of virgin materials, minimising the environmental impact of our industry. Steel drums are mainly produced according to the international ISO Standard 15750, and are the most widely used packaging for the delivery of dangerous goods across the world. Close to 50 million tons of goods are packaged worldwide each year in steel drums. Our drums offer the most adequate and robust protection for many filling goods and meet the strictest test requirements in the Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) for safe handling of Dangerous Goods. It is key to understand that the steel drum sector is a global one, with drums often being used for shipments across the world. In this context, SEFA strongly supports the European Commissions Green Deal ambitions to promote a circular economy for packaging by creating a level European playing field that will facilitate compliance and enforcement. We welcome the Commissions draft proposal and would like to offer the following observations: 1) The draft overlooks the specific circumstances of the market for industrial (B to B) packaging, which as outlined above are very different in comparison to the market for consumer packaging, and thus requires some adjustments throughout. 2) Drums and other similar types of industrial packaging such as pails, canisters and Intermediate bulk containers or IBC, are wrongfully categorised as transport packaging in Article 26 paras 7, 12, 13 and recital 69. We therefore request the Commission to consider using the wording in recital 10, which correctly distinguishes between sales packaging, grouped packaging and transport packaging: sales packaging corresponds to primary packaging, grouped packaging to secondary packaging and transport packaging to tertiary packaging.
Read full response