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European Carton Makers Association

ECMA

The European Carton Makers Association is the official organisation for Folding Carton Producing Companies, National Carton Associations and Suppliers for the folding carton industry throughout Europe.

Lobbying Activity

Meeting with Adam Jarubas (Member of the European Parliament, Committee chair)

13 Nov 2025 · Opakowania produktów tytoniowych i leków

Response to Omnibus Regulation Aligning product legislation with the digital age

8 Aug 2025

The European Carton Makers Association (ECMA) welcomes the Commissions approach to simplify EU legislation with the objective of reducing administrative burdens, particularly for SMEs. However, with the proposed Omnibus IV on aligning product legislation in the digital age, we are extremely concerned if a digital only approach was considered with product information for medicines and medical devices Currently, patients always receive printed paper instructions for use with their medicines and medical devices, providing essential consumption and safety information. Patients require clear information on their medicines and medical devices at the point of use and without the requirement to own a smartphone, be in an area where the internet can be accessed whilst also having the digital literacy skills to access the information (in 2023, only 55.6% of people in the EU aged 16 to 74 had at least basic digital skills, and by 2030 the estimation is of 59.8%)recent events, such as the April 2025 power cuts across Spain and Portugal, have proven that a paper information leaflet is the ONLY fail-safe method for a patient to obtain information on their medicines and medical devices without delay.
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Response to Single Market Strategy 2025

21 Jan 2025

Preserving the functioning of the Single Market is key to ensuring that packaging materials, including secondary raw materials, and packaged goods can move freely across the EU to reach European consumers and businesses. From an environmental standpoint, harmonised rules are essential to improve the sustainability of packaging and its value chain, ensuring that an EU-wide approach to packaging waste prevention, management and recycling is not defeated by unilateral initiatives. In recent years, the Single Market principles have been put into question by the resurfacing of technical barriers to trade and the free movement of packaging and packaged goods due to the adoption of unilateral and national measures to the detriment of the principles of competition, proportionality and mutual recognition. In the case of packaging and packaged goods, divergent national provisions are impacting virtually every economic sector and products value chains. Disparate national packaging requirements, such as unilateral labelling requirements, impede the use of a single packaging execution and require the redesign of all packaging across the internal market with significant costs, negative impacts on the environment (e.g. destruction of stocks or unsold items) and the adverse consequence of diverting human and financial resources away from other activities intended to advance sustainability (such as R&D on eco-design and digital traceability of product information for more efficient recycling).
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Meeting with Frédérique Ries (Member of the European Parliament)

30 Jan 2024 · Revision of the Pharmaceutical Legislation

Response to Waste Framework review to reduce waste and the environmental impact of waste management

10 Nov 2023

ECMA & Pro Carton are delighted to provide the attached feedback to the revision of the EU waste framework We bring together folding carton converters, cartonboard mills, national associations and suppliers to the folding carton industry. ECMA represents over 500 carton producers with a current workforce of 50,000+ located across nearly all countries in the European Economic Area this equates to over 80% of the 13 bill European folding carton market.
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Response to Evaluation and revision of the general pharmaceutical legislation

6 Nov 2023

MLPS Feedback for Directive on Medicinal Products for Human Use: MLPS (Medical Leaflets = Patient Safety), a subgroup of the European Carton Makers Association, expresses its concerns regarding the European Commission's proposed Directive on medicinal products for human use, related to the use of electronic product information (ePI). We support a complementary approach that integrates the benefits of both paper and digital leaflets, leaving no one behind. Accessibility for all: The Commissions proposal clearly states that ePI should always guarantee equal or better quality of information to all patients. This requirement directly contradicts with the Commission's proposal in Article 63 to grant Member States the possibility to replace paper medical leaflets with ePI. For instance, Denmark, up to 25% of the population are not in possession of a smartphone. This approach implies that millions of vulnerable Europeans may be left without guaranteed access to critical medical information, potentially leading to dangerous medication mis- dosing. Print on Demand (POD) - not a viable alternative: Article 63 introduces the concept of "Print on Demand" (POD), which ensures a patients right to get a printed copy when paper leaflets are no longer available. Implementing POD through pharmacies would disrupt the workflow of pharmacists, imposing additional time and resource requirements on pharmacies, leading to increased costs. Furthermore, the use of desktop printers for POD raises concerns about the accuracy and reliability of information, posing potential health risks to patients. Additionally, separating product information from medicine during transport could result in further complications, reinforcing our stance against POD as a viable alternative. Catering to smaller countries: We urge for a complementary approach in smaller countries that offers the advantage of a broader range of languages in digital format while avoiding the risk of leaving less digitally literate and vulnerable patients behind. Simultaneously, the leaflet printing industry is prepared to provide support for smaller countries. Collaborating with pharmaceutical companies, leaflet printers can produce shorter print runs (as low as 1000 copies) to supply paper leaflets in specific languages where required. Ensuring offline access and privacy: With increasing cyber threats, the online storage of health data can be vulnerable to attacks. Patients' medical data is highly confidential, and it remains unclear where and for how long this data will be stored when patients access ePI. Furthermore, tracking through cookies and third-party systems poses risks to patients' confidential online medical data. To safeguard patient privacy, patients must have the option to opt out of ePI due to privacy concerns and access critical information offline. Delegated Act mandating ePI: Article 63(5) of the Directive grants the Commission the power to adopt delegated acts mandating ePI and the right to a printed copy. Given the issues with a digital-by-default approach as outlined above, we emphasize the importance of retaining the paper leaflet through a complementary approach for as long as necessary. We believe that the proposed transition time of five years following the Directive's entry into force is inadequate for mandating a harmonized ePI, especially considering the needs of vulnerable Europeans and concerns about digital literacy. In conclusion, we strongly advocate for a patient-centred approach that prioritizes accessibility and safety by retaining paper leaflets in the packaging alongside ePI as long as digital literacy is not achieved. Patient safety must be the foremost consideration in any changes with significant implications for patient well-being.
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Response to Environmental claims based on environmental footprint methods

21 Jul 2023

The European Carton Makers Association (ECMA) welcomes the Commissions proposal for a Directive for the substantiation and communication of explicit environmental claims. ECMA brings together folding carton converters, cartonboard mills, national associations, and suppliers to the folding carton industry. ECMA represents over 500 carton producers with a current workforce of 50,000+ located across nearly all countries in the European Economic Area. We would like to take this opportunity to communicate our Green Claims policy asks, as follows: 1. Ensure consistency of the Directive with relevant EU legislation while maintaining a level-playing field with imported products. 2. Ensure information requirements are strictly relevant to the substantiation and protect confidential information. 3. Clarify rules for the comparison of different product categories and further develop methods to calculate the life-cycle environmental impacts of products 4. Ensure that existing, well-known third-party verified environmental certification schemes and labels are fully recognized. You can read more concerning our Green Claims Directive policy asks in the attached file.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

18 Apr 2023

Please find attached the feedback from the European Carton Makers Association (ECMA)
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Response to Revision of EU rules on late payments (Late Payments Directive)

1 Mar 2023

The European Carton Makers Association (ECMA) fully supports the revision of the rules of the Late Payments Directive 2011/7/EU. The European economy continues to be negatively affected by late payments, which particularly effect SMEs who feel unable to challenge the longer payment terms being imposed by larger companies. This was demonstrated in a report from the European Commission in August 2016 which confirmed that half of all creditors do not exercise their right to claim late payment interest, compensation and recovery costs as provided by the Directive for fear of damaging their commercial relationships. .... indeed, the European Commissions own evaluation study concluded 80% of companies experienced late payments during the past 3 years We remind the European Commission on the stated objectives of 2011/7/EU To provide creditors with timely payments and measures that enable them to fully exercise their rights when paid late. To confront debtors with strict measures that discourage them from paying late or from establishing excessively long contractual payment terms. ....and that the revision of the rules considers why these objectives have largely not been achieved. ECMA call on the revision of these rules to consider and implement actions as follows: To end suppliers being forced to accept terms of up to 120 days - so called incentives of supply chain financing at additional cost to the supplier, should not be permitted as late payment justification in a commercial relationship Timely payment must become legally binding and the business norm across the EU27 therefore harmonizing the requirements The Directive must contain clear and enforceable rules & tools to make prompt payment the normal business practice In concluding, the revision of the rules of 2011/7/EU gives the European Commission the opportunity to finally end the practice of late payments which brings blight and financial hardship to so many European businesses and to ensure that prompt payment becomes the standard and only accepted business practice. About the European Carton Makers Association The Association brings together folding carton converters, cartonboard mills, national associations, and suppliers to the folding carton industry. ECMA represents over 500 carton producers with a current workforce of 60,000 located across nearly all countries in the European Economic Area this equates to over 80% of the 13 bill European folding carton market.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Confederation of European Paper Industries and

30 May 2022 · Meeting with Fibre Packaging Europe

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius), Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius) and

3 Mar 2022 · EU circular economy implementation

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

3 Mar 2022 · EU circular economy implementation

Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

ECMA supports the ambition of the EU Green Deal and welcomes the upcoming revision of the Waste Framework Directive, which offers the opportunity to decrease waste generation and optimize recycling. The paper and board industry has invested heavily over decades to build the infrastructure to ensure our products are collected and recycled – indeed more paper and board packaging is recycled, by volume, than all other packaging types combined. The recycling rate for paper and board packaging was 84.2% in 2018. With the pending review of the Waste Framework Directive, ECMA recommends: 1. All packaging should be ‘fit for purpose’ and this should be considered as a waste prevention measure. Well designed, responsibly sourced, efficiently produced, low-carbon folding carton packaging that is appropriately used and effectively recycled provides multiple benefits – it minimises damage to products, extends their useful life, facilitates efficient distribution, gives safe and convenient access to goods, and communicates vital information to the consumer. Packaging which is “fit for purpose” prevents waste and should be introduced as a measure for all packaging. This will ensure that all packaging is designed to fit the product exactly with minimum void space, thus preventing both overpackaging and critically underpackaging and the related unnecessary waste and losses. Packaging needs to meet functionalities and avoid product or food losses. 2. Separate collection facilitates high quality recycling. The main barrier to greater paper and board recycling is the divergence among collection systems for paper and board at source. Separate collection of paper packaging, supported by application of the existing standards for paper grades for recycling (EN643), will contribute to high-quality recycling and increase the use of secondary raw materials. In Europe, paper fibres used in packaging have 6.3 recycling loops per year on average with scientific studies showing these fibres can be recycled and reused more than 25 times with no significant loss in quality or integrity. 3. Recycling and reuse both support waste prevention. The waste hierarchy states a preference for reuse over recycling… but the reality is not so clear. There are now several studies that have demonstrated that recyclable single-use packaging has a lower environmental footprint compared to reusable packaging. ECMA recommends that decisions on the use of reusable packaging are made on a case-by-case basis and by applying a science-based approach following a full lifecycle assessment. About ECMA: The European Carton Makers Association brings together folding carton converters, cartonboard mills, national associations and suppliers to the folding carton industry. ECMA represents over 500 carton producers with a current workforce of 60,000 located across nearly all countries in the European Economic Area – this equates to over 80% of the €12.3 bill European folding carton market.
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Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager) and Confederation of European Paper Industries and

11 Jan 2022 · Sustainable Products Initiative

Response to RoHS exemption for the use of mercury in other discharge lamps for special purposes

9 Jul 2021

Dear Ladies and Gentlemen, As indicated in the consultation, carton makers are widely using mercury-containing UV lamps for safe curing. We fully support the further comments submitted by our suppliers and assume the text in Annex 4(f) - IV can be reworded into "Mercury in lamps emitting light in the ultraviolet spectrum". Best regards. Jan Cardon ECMA Technical Advisor
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Response to Electronic instructions for use for medical devices

24 May 2021

The feedback from the 'European Carton Makers Association' is contained in the attached document
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Response to Revision of EU rules on food contact materials

18 Jan 2021

The European Carton Makers Association welcome the opportunity to contribute to the discussion on the policy options as referenced in the inception impact assessment. Our feedback is contained in the attached document.
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Response to Environmental claims based on environmental footprint methods

17 Aug 2020

The European Carton Makers Association support the European Green Deal and the aspiration to move from a part linear to fully circular economy. We fully support this ‘Substantiating Claims’ initiative as a route for reducing the quantity of misleading claims – so called ‘greenwash’ - and providing consumers and businesses with reliable, comparable and verifiable information to make sustainable decisions. Green claims made by companies should be substantiated via a comparable methodology - currently the array of voluntary environmental labels make comparison quite challenging and open to ambiguity. The Hague 17.08.20
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

28 Jul 2020

Please see attached document for full feedback from ECMA
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