Felelős Élelmiszergyártók Szövetsége
FÉSZ
Az 1989.
ID: 640289928623-13
Lobbying Activity
Meeting with Olivér Várhelyi (Commissioner) and
26 Mar 2025 · Meeting with representatives of the Association of Responsible Food Producers
18 Jan 2022
The Federation of Hungarian Food Industries welcome the European Commission's efforts to create a regulation that encourages and promotes the use of those recycled plastics and plastics containing recycled plastics that come into contact with food (FCM) with precise, forward-looking standards. We would like to reflect on the below points of the draft regulation from the viewpoint of Hungarian Food Business Operators (FBOs):
1. The process for approving plastic processing technologies
FBOs are constantly looking for solutions that reduce the amount of plastics used mainly as packaging, however – based on manufacturer feedback – we are afraid that the current version of the draft regulation will not encourage the spread of new processes enough (for which a number of food companies are already involved in the design process as plastics/packaging users), so that they only partially achieve the desired goal.
2. Clarification of definition
We consider it necessary to clarify the definition of 'recycled plastic' (Chapter I, Article 2, point 3, paragraph 4 of the draft regulation). Although 'recycled plastic' is defined as a pre-transformed plastic material, it already indicates in its name that this processing has already taken place (recycled). We consider it justified, e.g., to supplement the definition with the part „plastic prepared for recycling” or 'plastic intended for recycling' instead of 'recycled plastic'. By modifying this definition, it is more distinct from the definition in paragraph 5, and it is easier to interpret.
3. Determining the administrative burden on FBOs
Paragraph 22 of the draft regulation refers to the monitoring of recycled plastic batches and the need for related documentation. The draft regulation does not address the administrative obligations that FBOs will incur. How long does one FBO need to keep the documentation for batches of incoming recycled plastics? Until the whole batch is used up, e.g., until the finished products/raw materials are placed on the market? Or until the end of the shelf life of finished products? An important goal is to place as little additional administrative burden on FBOs as possible in relation to the use of recycled plastics, thus encouraging the use of such sustainable materials.
4. Labelling requirements for FBOs when using recycled plastic FCMs
Article 8 of the draft regulation refers to the provision of „relevant guidance" by FBOs to the consumer or other FBOs on the packaging of finished products/raw materials packaged in or in contact with recycled plastic, but the draft regulation makes no reference to exact specifications. As businesses are obliged to comply with complex labelling rules and are expected to comply with new labelling obligations soon (as parts of the Farm 2 Fork strategy: FOPNL, COOL, eco scheme, animal welfare labelling, etc.), we have to make sure that they have to indicate the use of recycled plastics and any waste management suggestions in the simplest way possible. In what form and what information do FBOs need to label on the packaging of products about the recycled plastics used? (Percentage of recycled plastic used, code number of recycling scheme, other descriptions important to the consumer?) Is it necessary to indicate at all whether the packaging contains recycled plastic or, if so, what percentage, if this fact has no effect? How can the consumer handle it? Who will decide whether and on what basis to label these data?
5. Integrate recycling schemes into quality assurance systems
In Article 9 (9) of the draft regulation the legislator refers to the obligations of FBOs to integrate the various recycling schemes into their quality assurance system or, in the case of smaller FBOs, into their HACCP system. As the draft does specify this, can FBOs expect a guidance for the various recycling schemes on how to integrate processes into their quality assurance systems or HACCP systems? This would be essential to SMEs.
Read full responseResponse to Setting of nutrient profiles
2 Feb 2021
The Federation of Hungarian Food Industries (FHFI) welcomes the opportunity to comment on the proposal to revise EU rules on the information provided to consumers is part of the EU’s ‘farm-to-fork’ strategy.
We highly support the aims to ensure better labelling information to help consumers make healthier and more sustainable food choices and tackle food waste.
At this stage of the revision process we would like to comment on the below points:
Front of pack nutrition labelling:
FHFI supports union wide harmonisation of the forms of expression of front of pack nutrition labelling since the coexistence of several different schemes can hinder the free movement of goods and consequently the competitiveness of food producers.
It is crucial however that these additional forms of nutrition labelling remain voluntary for the food business operators.
Country of origin labelling:
FHFI is on the view that the current provisions are a good compromise to inform consumers about the origins of their food while letting food business operators maintain their competitiveness.
Therefore, we see no need to create additional provisions for country of origin labelling for the time being.
Read full response