European Rolling Paper Association e.V.
ERPA
Hauptaufgabe und -ziel des Verbandes ist die Wahrnehmung und Förderung der gemeinsamen speziellen Interessen seiner Mitglieder im Zuge der europäischen Rechtsentwicklung z.
ID: 804211322967-55
Lobbying Activity
Response to Single Market Strategy 2025
29 Jan 2025
Please find ERPA's position on the Single Market Strategy 2025 attached.
Read full responseResponse to 2023 Strategic Foresight Report
10 Mar 2023
Please find our position attached.
Read full responseResponse to Review of the general product safety directive
4 Oct 2021
The European Rolling Paper Association (ERPA) represents the interests of predominantly small and medium-sized manufacture od specialized paper products. Endowed with this mandate, we welcome the opportunity to provide our position on the Commission’s call for feedback on the review of the General Product Safety Directive (subsequently abbreviated as “draft proposal”).
ERPA provides a portfolio of safe and high-quality products to consumers which are continuously assessed under safety, usability and circularity considerations. Some of our products are provided to consumers in small and also very small units. These very small units enable us to fully align with the European Commission’s objective communicated in the new Circular Economy Action Plan of March 2020. The objective of the new Circular Economy Action Plan is to reduce (over)packaging and packaging waste. These products are sold in packagings that meticulously fit the size of the product without using unnecessary or exhausting additional packaging material.
Article 8 (7) of the draft proposal governs – inter alia – that manufacturers must indicate their name, registered trade name or registered trade mark and the postal and electronic address at which they can be contacted on the product or, where that is not possible, on its packaging or in a document accompanying the product. The address shall indicate a single contact point at which the manufacturer can be contacted.
While ERPA understands the need for the availability of the contact point of the manufacturer to be provided to the consumers, the limited available space on the packaging itself should be taken into account and aligned with the ambit under which the new Circular Economy Action Plan and the EU Green Deal were made.
Our products are governed by numerous laws. Some of them already prescribe labelling requirements on the packaging. Therefore, we prefer that only the electronic address should be provided on the packaging as this would connect the digital age with sustainability considerations as reiterated by the President of the European Commission in the State of the Union speech on September 15, 2021 . In addition, it seems highly unlikely that a consumer attempts to reach the manufacturer by postal mail in the digital era.
Another area of high concern is that counterfeit products have not been included in this draft proposal verbatim. The rationale for the omission given by the European Commission was that counterfeit products are already addressed by EU legislation.
Counterfeiters operate in a highly organized manner through a worldwide network and contribute to unsafe products. Counterfeit products reportedly caused accidents where consumers were left injured or worse. Not defining (governing) counterfeit products as unsafe is detrimental to consumers. It neglects the key and crucial objective of this proposal and adversely affects legal products in comparison to counterfeit products.
While we agree that an unsafe product must undergo a risk assessment, the qualifying provision of Article 6 of the draft proposal “Presumption of safety” shall not be applicable for counterfeit products. Even if different laws apply to counterfeit products, it does not mean that these products cannot be tackled from the angle of the safety of European consumers.
The draft proposal states that unsafe products are covered in the GPSD regardless of their authenticity. While we agree to the applicability of the draft proposal irrespective of the origin of the product, the importance to tackle counterfeit and unsafe products should be given the highest political and legal priority by inserting a verbatim expression of counterfeit products in Article 6 of this draft proposal. Such signal would send a strong message to consumers and should therefore be legally embedded.
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