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European Container Glass Federation

FEVE

FEVE represents the economic and technical interests of the European container glass industry.

Lobbying Activity

Meeting with Heiko Kunst (Head of Unit Climate Action)

18 Dec 2025 · Product benchmark update – glass sector

FEVE urges binding 90% glass collection target in Circular Economy Act

5 Nov 2025
Topic — The consultation gathers feedback on the Circular Economy Act to boost EU sustainability.
Message — FEVE calls for a binding 90% separate collection target for glass packaging. They urge the EU to formally recognize permanent materials in the policy framework.12
Why — This would reduce energy costs and prevent discriminatory national bans on glass bottles.34
Impact — Producers of fossil-based packaging and state-run waste systems would lose market influence.56
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Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

16 Oct 2025 · Simplification: Packaging and Packaging Waste Regulation (PPWR)

Glass Industry Urges Lower Electricity Costs to Drive Electrification

9 Oct 2025
Topic — The EU consultation explores policies to transition energy demand from fossil fuels to electricity.
Message — FEVE requests extending carbon cost compensation to glassmakers and lowering network charges to a minimum. They also suggest cutting grid connection fees and prioritizing industrial network access applications.123
Why — Lowering power costs would make high-volume glass production using electric furnaces economically competitive with gas.45
Impact — Public finances would lose revenue if taxes and renewable levies are shifted to government budgets.6
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Meeting with Eric Mamer (Director-General Environment)

24 Sept 2025 · The meeting was organised to discuss practical issues of the minimisation requirement under Art. 10 of the packaging and packaging waste regulation (PPWR)

Meeting with Anna Athanasopoulou (Director Internal Market, Industry, Entrepreneurship and SMEs)

8 Sept 2025 · Packaging and Packaging Waste Directive

European glass makers demand state aid for green electrification

5 Sept 2025
Topic — The Commission is updating rules for compensating industries for high electricity costs.
Message — The federation requests reviewing thresholds to include hollow glass in the compensation scheme. They argue high electricity prices currently discourage the sector from switching to greener technology.12
Why — Accessing these subsidies would lower operational costs and protect European market competitiveness.3
Impact — Non-EU glass exporters would lose their current price advantage in European markets.4
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European glass industry urges faster permits and financial support

8 Jul 2025
Topic — The IDAA aims to support industrial decarbonization while maintaining European competitiveness and productivity.
Message — FEVE requests a 12-month limit for permitting decisions with automatic approval if authorities miss the deadline. They also want financial support to cover the high costs of switching from gas to electricity.12
Why — These measures would protect profit margins and ensure timely upgrades during fixed investment cycles.3
Impact — Local regulatory bodies lose oversight when industrial projects are automatically approved after twelve months.4
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Glass industry warns against unrealistic zero emissions cap by 2040

4 Jul 2025
Topic — The consultation reviews the EU Emissions Trading System and market stability after 2030.
Message — The federation demands stronger carbon cost protections and slower emissions cap reductions. They argue reaching a zero emissions cap by 2040 is currently unrealistic.123
Why — The industry would avoid high carbon costs and maintain its global competitiveness.45
Impact — Shifting the emissions cap share would force the power sector to decarbonize faster.67
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Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen), Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

13 May 2025 · Glass manufacturing

Meeting with Heiko Kunst (Head of Unit Climate Action), Mette Koefoed Quinn (Head of Unit Climate Action) and

15 Apr 2025 · Exchange of views on the revision of the EU Emission Trading System and challenges faced by ceramic, glass and pulp and paper sectors.

Meeting with Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall)

26 Mar 2025 · Role of glass production in the context of the Clean Industrial Deal

European glass federation urges harmonized rules to protect Single Market

31 Jan 2025
Topic — The European Commission is consulting on the Single Market Strategy 2025 to improve cross-border trade.
Message — FEVE calls for harmonized EU legislation for glass packaging to prevent national trade barriers. They urge the Commission to grant carbon cost compensation and align national energy policies.123
Why — These measures would reduce compliance costs and ensure fair competition with other materials.45
Impact — National retail monopolies would lose the power to impose unilateral product bans and requirements.67
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Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

17 Jan 2025 · Decarbonising the glass packaging industry and opportunities for collaboration in the new mandate

Meeting with Andrea Wechsler (Member of the European Parliament) and European Association of Research and Technology Organisations and

11 Dec 2024 · EU Energy and industry policy

European glass industry urges robust green claim standards

13 Jul 2023
Topic — The consultation addresses rules for using environmental footprint methods to substantiate green claims.
Message — The federation supports the proposal but highlights gaps in current environmental impact calculations. They advocate for including packaging circularity, infinite recyclability, and human health impacts.12
Why — The glass industry benefits from inclusion of recyclability metrics which showcase their products' environmental performance.3
Impact — Businesses using misleading environmental claims will face stricter verification requirements and potential penalties.4
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Meeting with Pascal Arimont (Member of the European Parliament)

9 May 2023 · PPWR and glass packaging

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and spiritsEUROPE and Comité Européen des Entreprises Vins

2 May 2023 · Packaging and Packaging Waste Regulation

European glass industry urges material-specific waste reduction targets

20 Apr 2023
Topic — The consultation reviews EU packaging requirements to promote recycling and prevent waste.
Message — The federation requests material-specific targets to ensure all materials contribute equally. They want performance criteria to recognize product presentation to protect brand identity. They advocate for keeping glass out of mandatory deposit return schemes.12
Why — This would protect the sector's profitability and help maintain its strong export position.3
Impact — Environmental groups lose if policy triggers a shift from circular glass to plastic.4
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Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Nestlé S.A. and

21 Feb 2023 · PPWR

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

15 Sept 2022 · Circular economy, the revision of the packaging and packaging waste directive, and specificities of the glass packaging sector

Response to Revision of the Energy Tax Directive

17 Nov 2021

FEVE , The European Container Glass Federation, welcomes the opportunity to provide feed back on the Commission proposal to revise the Energy Taxation Directive (ETD). Given the 4,000 characters limitation, this input will focus on the main elements. A more elaborated position paper is attached to the contribution. To reach carbon neutrality, European glass manufacturers will have to invest massively in R&D and new technologies. This investment effort will take place in a context of high CO2 prices and energy prices. Maintaining the competitiveness of European manufacturers already exposed to unfair competition from countries with no or laxer climate policies is therefore essential. However, FEVE has noted with concern that the draft Energy Taxation Directive 2022 no longer explicitly mentions mineralogical processes in Article 3 (b) which are out of scope. Considering the energy intensity and high trade intensity faced by the European glass industry, keeping the current applicable tax exemption is essential for its international competitiveness. Adding mineralogical processes in the new ETD would cost hundreds of millions of Euros to the glass industry. This would constitute a double burden with the Emission Trading Scheme, and severely undermine the capacity for the glass industry to invest in low carbon technology and succeed its energy transition. Based on above considerations, GAE asks the EU Commission to keep 'mineralogical processes' in the list of uses of energy products and electricity in Article 3 1. (b) of the Proposal for a COUNCIL DIRECTIVE restructuring the Union framework for the taxation of energy products and electricity. The more the glass industry moves towards low carbon production technologies, the more electricity it will use as an alternative to fossil fuel (increasing the share of electricity in its energy mix). Taking mineralogical processes not explicitly out the scope of the energy taxation directive will increase production costs and will increase glass industry electricity tax burden, therefore making investments into decarbonisation more insecure and costly, and less attractive. This contradicts the aim of the Commission that “electricity should always be among the least taxed energy sources in view of fostering its use”. Additionally, it has to be noticed that the move to electrification is already penalized by the fact that glass industrial sectors are not compensated for indirect carbon costs associated with electricity.
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Response to Carbon Border Adjustment Mechanism

17 Nov 2021

FEVE , The European Container Glass Federation, welcomes the opportunity to provide feed back on the Commission proposal to introduce a Carbon Border Adjustment Mechanism. Given the 4,000 characters limitation, this input will focus on the main elements. A more elaborated position paper is attached to the contribution. CBAM and free allocation CBAM should not be perceived as an alternative to the free allocation of ETS allowances as both measures address different types of carbon leakage. For instance, a CBAM alone would not solve the issue of carbon leakage for EU industries that are mainly export-oriented. From a legal point of view, the co-existence of free allowances and a CBAM under the EU ETS umbrella can be WTO compatible (see the legal study by AEGIS Europe https://static1.squarespace.com/static/5537b2fbe4b0e49a1e30c01c/t/60ec0a57e370ac6322a86209/1626081879682/AEGIS+Europe+-+CBAM+WTO+Legal+Analysis+-EXECUTIVE+SUMMARY-+KS+and+NCTM+-+Confidential+3+June+2021+REV.pdf). The consistency with WTO rules can be achieved by treating importers and EU manufacturers on the same footing, requiring importers to only buy allowances above the benchmark levels. The co-existence of free allowances and CBAM would reduce additional costs for EU manufacturers, allow sufficient time for the deployment of low carbon technologies and alleviate the impact on EU value chains and final consumers. Solution for exports EU manufacturers will bear carbon costs for the entirety of their production, while foreign manufacturers will only face additional costs for the exports to the EU. This asymmetry will make EU exports more expensive than local production in regions where no (or less) carbon costs exist. This will inevitably result in lower access to export markets for the European industry, with a negative impact on EU trade balance, on EU manufacturers competitiveness and on global CO2 emissions. It is therefore crucial to design a system for EU exports as part of CBAM . Such solution should be developed in time for the implementation of CBAM. This would act as a further incentive to ensure third countries set up carbon pricing schemes. Monitoring and Verification Under the EU ETS, EU operators must comply with annual monitoring, reporting and verification requirements with data verified by an EU accredited verifier. Shall a CBAM be introduced, the same level of control should apply to non-EU operators importing products. Ideally, emissions should be calculated and reported at installation level, as it is the case for EU operators. Defining the exact carbon content of imported products is critical to the success of the CBAM. Both direct and indirect emissions should be accounted plus emissions resulting from the transport of the goods up to the EU border. Should the legislator wish to propose the introduction of benchmarks (at the relevant statistical level; i.e. NACE or Prodcom), these should be set per product and country of origin. To avoid the import of carbon-intensive products to the EU, the imported product benchmarks per country of origin should be set at adequate levels so to incentivize non-EU operators to present emissions’ reports verified by an EU accredited verifier. Circumvention measures The CBAM proposal is complex and open to loopholes and circumvention. In the Commission proposal, the definition of circumvention (i.e. finding ways to avoid the CBAM) is too restrictive and limited to slight product modifications. There are however other means to get round the CBAM such as resource shuffling (allocating low carbon production in a country for EU exports with no effect on the overall CO2 emissions), transhipment strategies (if exemptions exist) or costs absorption (only part of the foreign production is subject to CBAM). The proposal should therefore better define and address circumvention risks.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

FEVE , The European Container Glass Federation, welcomes the opportunity to provide feed back on the Commission proposal to review the Emission Trading Directive (ETS). Given the 4,000 characters limitation, this input will focus on the main elements. A more elaborated position paper is attached to the contribution. Ensuring cost-effectiveness FEVE supports the objectives set in the Climate Law, but stresses the importance to achieve these objectives in the most cost-efficient manner. In this context, all measures aimed at increasing the carbon prices without affecting the climate ambition are unnecessary slowing down the transformation of the EU industry (which face a huge challenge as they need to reduce their CO2 emissions by 61% between 2005 and 2030). This is e.g. the case for the rebasing (one-off cancellation of allowances) and the strengthening of the Market Stability Reserve (MSR). Addressing Carbon Leakage In order to achieve this ambitious reduction target, industry will have to invest massively in low-carbon technology. However, the high carbon prices, and the lack of a level playing field with non-EU regions, makes this extremely challenging. It is therefore essential to reinforce the existing carbon leakage protection measures as long as no global carbon pricing system exists. This can be done by applying the following measures: 1. The Cross-Sectorial Correction Factor (CSCF) needs to be avoided. To ensure this, the 3% flexibility between auctioning and free allocation shares needs to be increased. This is largely possible, since the impact assessment on the 2030 targets acknowledged that the abatement potential of the power sector (which is the historical reference of the auctioning share) is much larger than energy intensive industries’ (i.e. 70% vs. 22%). 2. In the same spirit, allowances in the MSR could be given to industry to avoid the CSCF instead of being cancelled. 3. The ETS secondary legislation should be revised to account for the impact of the COVID crisis. According to the current rules, free allocation for the period 2026-2030 will be based on the average production levels in the period 2019-2023. This will penalise EU companies which had unrepresentatively low production in 2020 due to covid pandemic. Other reference years should be used to calculate the Historic Activity Level. 4. Should a CBAM be introduced, it should co-exist with free allocation. From a legal point of view, the co-existence of free allowances and a CBAM under the EU ETS umbrella can be WTO compatible (see the legal study by AEGIS Europe https://static1.squarespace.com/static/5537b2fbe4b0e49a1e30c01c/t/60ec0a57e370ac6322a86209/1626081879682/AEGIS+Europe+-+CBAM+WTO+Legal+Analysis+-EXECUTIVE+SUMMARY-+KS+and+NCTM+-+Confidential+3+June+2021+REV.pdf). The consistency with WTO rules can be achieved by treating importers and EU manufacturers on the same footing, requiring importers to only buy allowances above the benchmark levels.. 5. As electrification is one option for the glass industry to decarbonise, it should be added in the list of sectors eligible for indirect compensation Supporting industry to transform Setting ambitious climate targets will not be enough to succeed in decarbonising our society. Public authorities should also massively invest in renewable energy (green electricity, Hydrogen, biomass) and infrastructures as this is not in the hands of industry. More financial support is also needed for industry to invest in low-carbon technologies. FEVE therefore welcomes the increase of the Innovation Fund, but is of the opinion that this increase should mainly come from the auctioning revenues, and not from the free allocation share (as proposed by the Commission) because that makes the introduction of the CSCF more likely.
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Meeting with Florika Fink-Hooijer (Director-General Environment)

13 Jul 2021 · EU Green Deal and the industry’s commitments to a resource-efficient and low-carbon circular economy

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and The European Steel Association and

7 Jun 2021 · Carbon Border Adjustment Mechanism

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

7 Jun 2021 · Decarbonisation and circular economy projects

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

7 May 2021 · Decarbonisation, EU Circular Economy Action Plan and packaging policies

Response to Revision of EU rules on food contact materials

29 Jan 2021

The European Container Glass manufacturing industry (FEVE) welcomes the revision of the FCM legislation and calls upon the European Commission to: • Develop harmonised legislation for glass packaging materials intended for food contact • Ensure the safe recycling of packaging materials into food contact applications You will find more details in the position paper attached.
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Response to Environmental claims based on environmental footprint methods

28 Aug 2020

The European Container Glass manufacturing (FEVE) industry welcomes the European Commission’s ambition to ensure that consumers and businesses have access to reliable, comparable, and verifiable information to make sustainable decisions. FEVE has been an active member of the Product Environmental Footprint (PEF) pilot phase for food and beverages (on Wine, Packed Water, Beer, Olive Oil and Dairy Products). The PEF aims to simplify the calculation of the environmental impacts of products and help harmonise environmental declarations. However, we caution that the PEF methods have large gaps. The European Commission has for instance acknowledged that the quality and duration aspects of food products are not well captured in the description of the product’s function . These gaps need to be addressed before using the PEF methodology as a comparative tool in policies and requiring companies to substantiate their green claims on this basis. In addition, several improvements are needed to make Life Cycle Assessment (LCA) a robust tool that can be the basis of a reliable PEF methodology for businesses and consumers. • Life Cycle Assessment (LCA) is not a static nor final methodology. As outlined below, the gaps in LCA are many and need to be addressed before codifying the PEF into legislation, which is based on this LCA methodology. We are concerned that because LCA is based on ISO standards which require a long process to change, LCA shortcomings will be repeated in the PEF. We believe that the PEF is an opportunity however for the EU to address these gaps and would welcome a process to improve the methodology as part of the PEF process ahead of it being codified into EU legislation. • LCA can help identify hot spots in a production process or in a value chain. However, due to methodological issues or data availability, some environmental impacts of products are not yet taken into account, for instance: circularity of packaging, infinite recyclability, avoidance of food waste, biodiversity, toxicity, direct/indirect land use, microbiological pollution, littering, food chain contamination by microplastics, direct health effects from products, etc. In addition, the outcomes of LCAs are highly dependent on the dataset used and their robustness. • As a comparative tool, the PEF has also shown many limitations. For instance, several food pilots have recognised the limitations in the methodology to perform comparison between packaging materials. • Failing to correctly address the multi-functionality of packaging, comparison between products packed in different packaging is not appropriate and meaningful. The PEF is based on a methodology that is not yet robust enough to make such comparative assertions between products/services/organisations. It should rather be used to measure the environmental performance of a product and its improvement over time. • In addition to the general shortcomings, there are also specific challenges when applying LCA to food & beverage products. Their environmental impacts need to be assessed against a wide range of product functions such as human health, preservation of taste and organoleptic properties, shelf life and prevention of food waste, etc. All these functions are integral part of the sustainability of food but are not captured by the PEF. Finding the right balance between quality and sustainability is an important area. The choice of the functional unit is critical in that respect. To sum up, FEVE believes that the PEF is not yet robust enough to make comparative assertions between products/services/organisations as it is an incomplete methodology which could lead to completely biased conclusions. The gaps described above should be addressed before it is integrated in policies and businesses and consumers take decisions based on it.
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Response to Carbon Border Adjustment Mechanism

31 Mar 2020

FEVE Contribution on the Inception Impact Assessment on Carbon Border Adjustment Mechanism. 31th of March 2020 FEVE , The European Container Glass Federation, welcomes the possibility to provide feedback on the Inception Impact Assessment on Carbon Border Adjustment Mechanism (CBAM). In the absence of equivalent measures taken by other regions of the world regarding carbon pricing, CBAM is one of the possible options (together with free allocation, consumption charges,…) to protect EU industries against the risk of carbon leakage. In this respect, CBAM deserves to be carefully examined. FEVE does not have yet a clear position on CBAM mainly because a lot remained to be defined. But we want to raise the following concerns: 1. It is essential to design any CBAM to be WTO compatible and to discuss with our trade partners to avoid any retaliation measures (which could affect products not covered by the CBAM). 2. It is also crucial to give industry a medium/long term vision. The ETS revision had the merit to give industry some certainty until 2030 (carbon leakage list, level of free allocation,…). The system should not be changed in a few years’ time to propose a completely different mechanisms. This 10 years visibility period is important to maintain the current levels of investment and to attract new ones. 3. Each sector is different and any impact assessment should be carried out at an appropriate NACE or even PRODCOM level, in agreement with the different sectors. CBAM should not be the only option to be assessed as consumption charges might work better for some sectors. 4. CBAM will only protect EU companies selling their products in the EU. Net exporters will face a major disadvantage and should be compensated. 5. The possible impacts on the whole value chain of a sector should be analysed. If a CBAM is only designed for basic materials, it could become less expensive to buy a complex product directly from outside the EU rather than producing it in the EU from the basic materials. 6. A transition period will be necessary where CBAM and free allocation still co-exist in order to allow the sectors to adapt. 7. The carbon intensity benchmarks defining the level of the CBAM should be set at a high level to encourage non-EU companies to provide their own carbon footprint data. Monitoring and verification of these data will be crucial provide trust and to allow the CBAM to work adequately. 8. The funds raised with the CBAM should be reinjected in the EU economy, with a priority for low CO2 projects in industry. OoO FEVE is the Federation of European manufacturers of glass containers. It is listed in the EU Transparency Register with number 1550133398-72. Founded in 1977 and headquartered in Brussels, FEVE is an international not-for-profit association. Its members produce over 20 million tonnes of glass per year. The association has some 60 corporate members belonging to approximately 20 independent corporate groups. 160 manufacturing plants are located across 23 European States and include global blue chip and major companies working for the world’s biggest consumer brands. The European container glass industry provides a wide range of glass packaging products for food and beverages as well flacons for perfumery, cosmetics and pharmacy to their European and world customers. With its 162 manufacturing plants distributed all over Europe, it is an important contributor to Europe’s real economy and provides employment to about 50,000 people, while creating a large number of job opportunities along the total supply chain.
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Response to A new Circular Economy Action Plan

17 Jan 2020

FEVE - The European Container Glass Industry fully supports the recently published Commission Circular Economy roadmap and action plan. We are committed to collaborate with the Commission to achieve its goals and objectives and we call for support to our industry in this effort. An efficient EU Circular Economy would also contribute to the targets set by the European Green Deal and to the achievement of the UN Sustainable Development Goals. By having fully integrated glass recycling into our industrial processes for more than 50 years and advocating for separate collection systems of glass across the EU, the industry is a pioneer of the Circular Economy model for packaging in Europe and therefore a key enabler of a Responsible Consumption and Production lifestyle. Today we have achieved a recycling rate of 76%. Glass is a permanent material that is infinitely recyclable in a closed loop without losing its properties and, thanks to its inertness, is perfectly fit for food and beverage packaging no matter how many times it is recycled. We incorporate more recycled content than virgin materials in our packaging: on average 52% of our raw materials is recycled glass. Glass also offers a reusable option for customers who are part of refund schemes. Refillable bottles can be reused up to 40 times and still be recycled at the end of their life. By further optimizing our business model, we can support the EU commitments to the UN 2030 Sustainable Development Goals. The circular production of a glass packaging is inherently relevant to the UN Sustainable Consumption and Production Goal (SDG 12). As a closed loop production system, we are circular by nature and we work in tight partnership with our stakeholders – from the energy and raw material suppliers to the end consumer - to make sure our Circular Economy works better and better (UN SDG 17). With this aim, we have recently set the foundations of “Close the Glass Loop” an industry platform to drive a material stewardship programme to increase the quantity and quality of available recycled glass. With ‘Close the Glass Loop’ we want to achieve a 90% average EU collection rate of used glass packaging by 2030 (up from the current average of 76%) and improve the quality of recycled glass. However, there are major challenges ahead of us which need to be addressed with a systems approach, which requires human and financial resources to be allocated, and throughout our own value chain. We strongly believe that a real Circular Economy can be created only by taking a systemic approach that would encourage economic, social and political players that today work in an independent and isolated way to handle complex challenges with a global approach. Adopting a circular economy model to effectively manage the end-of-life of packaging is crucial. However, while major resources have been quickly put in place by policy and market forces to fix the plastics problem hardly any attention is paid to support existing alternative packaging materials like glass which have proven to be circular already, with little resources being made available to optimize our already existing circular economy model. The glass packaging value chain also needs investments in generalizing separate collection, improving sorting techniques, informing consumers. It is also important not to destroy the existing and well-functioning bottle bank network by introducing competing systems like Deposit Refund Schemes for recycling. We call on policy makers to work arm in arm with our industry to ensure that future decisions improve the investment conditions, stimulate innovation and keep us competitive in Europe. We call on the European, National and Local authorities to concretely support the “Close the Glass Loop” platform in achieving its objectives which are totally aligned and functional to the achievement of the EC Circular Economy goals.
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Response to Revising the rules for free allocation in the EU Emissions Trading System

9 Jul 2019

FEVE welcomes the public consultation on the draft regulation on adjustments to free allocation due to activity level changes and supports, as proposed, an effective start of the production change mechanism by 2021 based on 2019-2020 data as well as a mechanism as dynamic as possible to reflect the reality of the glass sub-installations activities changes. Our main comment relates to Article 5.4 of the draft regulation which stipulates that if the activity level of a sub-installation is zero during one year, the rolling average of two years is no longer applied, and the allocation of this sub-installation will be zero for the next year. Although FEVE understands that over-allocation should be avoided, we cannot support this principle. This principle is not aligned with the EU ETS directive which foresees in Article 10a 20) that the 2 years rolling average will apply with no exception to the rule. By doing so, the ETS directive has created a symmetrical system between increase and decrease of Activity Level. Article 5.4 would break this symmetry. One installation can have several sub-installations producing different products. If during one year, one specific product is not produced in its respective sub-installation, this sub-installation will receive no free allocation the next year, which will create an under-allocation that cannot be recovered for the rest of the period (see table in the attached document). This case can occur quite often for industries producing by campaigns, like in the glass industry, without a reduction of the whole production of the site. Indeed, the same installation can, for instance, alternatively produce flint glass and coloured glass. Reducing the level of allocation like described in article 5.4 would penalize sites that are multi-products compared to sites that are single-products. If Article 5.4 was introduced to deal with cessation of activities and avoid over-allocation, which we fully understand, we suggest addressing this issue in the cessation section, but not by breaking the symmetrical treatment between increase and decrease of activity levels. Furthermore, installations might have to temporarily stop their activity for some years and can resume it afterward. For the year following the restart of the activity, the allocation adjustment should be based on the average of the activity levels of the last two years with “non 0” activity (activity levels before the stop and after the restart), instead of the average of the « 0 activity » year and the first year of activity after the restart of operation.
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Response to Migration limits for lead, cadmium and possibly other metals from ceramic and vitreous food contact materials

26 Jun 2019

FEVE input on the Commission’s inception impact assessment on Migration limits for lead, cadmium and possibly other metals from ceramic and vitreous food contact materials FEVE – The European Container Glass Federation – is the voice of container glass manufacturers in Europe representing 160 manufacturing sites for glass containers in the EU28 and Switzerland and Turkey from 23 groups of companies. Together the sector maintains 125,000 direct and indirect jobs. The members produce 21 million tonnes of glass material per year, resulting in over 80 billion packaging units of bottles and jars for food and beverages but also and flacons for perfumery, cosmetics and pharmaceutical products. The vast majority is produced for food and drinks for the EU market but also globally. Our members supply packaging for the world’s biggest consumer brands and small-sized companies. Glass packaging is today the second leading packaging material for the beverage consumption market in Europe with 29.3% market share, and is the market leader for spirits, wines, and beer markets (source EuroMonitor 2017). For food contact, our members are exclusively producing soda-lime glass which: • Is a homogeneous material made of inorganic raw materials like sand, soda ash and lime-stone; • Is effectively inert in food contact – there is virtually no migration of (potentially dangerous) substances from soda-lime glass to the food which ensures human health protection; • Is impermeable to both gases and liquids – e.g. gases like oxygen or carbon dioxide cannot leave or penetrate through the soda-lime glass, which ensures preservation of the organoleptic properties and taste of the food; • Is permanent – it can be endlessly recycled, and once recycled does not lose any of its intrinsic food safety, chemical or physical properties. It is important for the glass packaging industry to have a clear and fit for purpose EU framework in place to demonstrate compliance of our products that are placed on the market. A harmonised testing food contact materials framework for glass at EU level is also desirable as we experience individual EU Member States taking individual initiatives which would add additional testing costs and constitute a barrier to free trade. FEVE is therefore in favour of a harmonised legislation for glass packaging to ensure free movement of goods, reduce administrative and testing costs and give certainty in the value-chain and is calling for harmonized food contact materials legislation providing a proper framework for glass manufacturers and the markets they supply. FEVE strongly recommends defining limit values in conjunction with testing methods which are applicable to glass – see e.g. the work which is under finalisation inside ISO TC166 and the corresponding glass standard “ISO 7086: Glass hollowware in contact with food. Release of lead and cadmium”. Today in Europe, 74% of glass bottles, jars and flacons put on the market are collected for recycling. Due to the permanent capacity of glass material, glass packaging can be endlessly recycled with no quality degradation during the processing and melting phases. This makes glass a genuine circular product. The biggest user of packaging material is destined to food and beverages markets, and, therefore, the capacity to safely recycle materials into food contact applications has become a major topic. FEVE therefore calls for the recognition in the food contact materials framework legislation that packaging made either entirely or partially from recycled glass and used in contact with food is safe for food contact and does not have to undergo any further authorisation of recycling processes. This is due to the inertness capacity of glass material with no or very limited migration regardless the number of times the material is recycled.
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Response to Commission Delegated Regulation establishing the Innovation Fund

20 Dec 2018

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Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

FEVE welcomes the opportunity to comment on the Commission’s Roadmap on an EU Product Policy Framework contributing to the Circular Economy. We would like to highlight the specificity of food products and food packaging in the context of product policy. As fast-moving consumer goods, food & food packaging products are a very relevant category for the Commission’s further work on EU product policy. Indeed, food packaging must respond to two logics: 1) Circular design, which means promoting recycling of materials and reuse of products. In this respect, permanent materials which retain their full properties even when recycled multiple times should be rewarded. Only these materials can avoid extraction of virgin materials once produced. 2) Food safety, to ensure product safety for the end-consumer and maintain high levels of human health. That is why we call for a product policy that is firmly aligned with the principles of a non-toxic environment in the EU. Specific comments on the Product Environmental Footprint: FEVE has been directly involved in the elaboration of 5 pilots (on Wine, Packed Water, Beer, Olive Oil and Dairy Products). From this experience, we can raise the following points: - Future action based on the pilot phase of the Product Environmental Footprint (PEF) must be carefully assessed. - Life Cycle Assessment (LCA) is not a static nor final methodology, it requires constant scientific and operational improvement. We are concerned that the PEF process will prevent much needed research and methodological innovation in LCA, by standardising processes into policy or legislation. - LCA can help identify hot spots in a production process or in a value chain. However, due to methodological issues or data availability, some environmental impacts of products are not yet taken into account, especially in the use-phase and in the end-of-life. - As a comparative tool, the PEF has shown many limitations. For instance, several food pilots have recognised the limitations in the methodology to perform comparison between packaging materials. - There are specific challenges when applying LCA to food products. The European Commission has acknowledged that the quality and duration aspects of food products are not well captured in the description of the product’s function. Finding the right balance between quality and sustainability is an area that FEVE is particularly interested to be involved in. FEVE is looking forward to contributing to stakeholder consultations and dialogue with the EU institutions on product policy and the circular economy, in particular on the following points: - Methodological innovation in LCA, especially for comparative or policy purposes; - Product policy applied to food and food packaging, addressing issues of sustainability, quality and safety; - Recyclability and maintaining materials at their highest level of utility for the circular economy, through non-toxic material cycles.
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Response to Evaluation of Food Contact Materials (FCM)

22 Dec 2017

FEVE – the European Container Glass Federation – welcomes the possibility to comment on the European Commission roadmap for the evaluation of food contact materials (FCM). As the Federation of European manufacturers of glass containers and machine-made glass tableware, our members produce over 20 million tonnes of glass per year, of which approximately 95% is for food contact applications. According to our consumer research [Insites Survey, 2014] personal health conditions and food safety are among the top daily life worries of Europeans. 66% of European consumers are highly worried about food contamination or migration of harmful chemicals from the packaging into the food product. 8 out of 10 European believe these chemical interactions are a risk to human health. This shows the importance of maintaining a high level of ambition when it comes to food contact material safety in the European Union. The European Parliament 2016 resolution on food contact materials identified several shortcomings on the functioning of the current regulation and formulated clear demands for how the European Commission could improve the current legislation and its enforcement. In particular, it urges the European Commission to make use of all the available resources at its disposal to put forward harmonised legislation for the remaining 13 food contact materials not yet regulated at EU level. FEVE supports developing legislation for glass in order to ensure effective functioning of the internal market by establishing one set of harmonized testing methods for glass. In the absence of clearly defined EU regulations, some customers are requesting glass container producers to conduct multiple tests to meet the specific requirements of different Member States. In some instances, glass articles are even being tested according to regulatory test protocols developed for other types of food contact materials (e.g. plastics or ceramics), even though these test protocols are not intended or appropriate for glass containers because they require testing of elements that simply do not exist in glass. In addition, one of the biggest regulatory gaps that should be addressed in the new legislative framework for food contact materials is the impact of recycling on the health and safety of consumers, as unintentional impurities might contaminate the materials during the collection and recycling processes. Especially in the context of increased recycling targets in the Packaging & Packaging Waste Directive, there is a risk that more substances of concern enter material streams that end up as food contact applications. This should be addressed in the European Commission’s further work. FEVE is interested to collaborate with DG SANTE on these aspects and will seek to contribute throughout the consultative process.
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Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu)

21 Aug 2015 · CIRCULAR ECONOMY AND COHESION POLICY