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Flexible Packaging Europe

FPE

Flexible Packaging Europe represents European manufacturers of flexible packaging materials including pouches, sachets, and food packaging.

Lobbying Activity

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

21 Nov 2025 · Simplification: environmental omnibus

Flexible Packaging Europe calls for mandatory sorting and EPR reform

4 Nov 2025
Topic — The EU is consulting on the Circular Economy Act to promote sustainable production and resource efficiency.
Message — The organization requests stricter waste collection rules and mandatory sorting of recyclables from residual household waste. They also propose that fees paid by producers be reserved specifically for improving packaging recycling infrastructure.123
Why — These measures would help companies secure enough recycled material to meet incoming EU environmental standards.45
Impact — National governments would lose the flexibility to spend packaging producer fees on general public services.6
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Meeting with Jessika Roswall (Commissioner) and

29 Oct 2025 · Roundtable- closing the Loop : Addressing the Plastic Recycling Crisis in Europe

Meeting with David Cormand (Member of the European Parliament)

18 Sept 2025 · Circular Economy Act

Meeting with Yannis Maniatis (Member of the European Parliament) and eFuel Alliance

16 Sept 2025 · Introductory Meeting

Meeting with Eero Heinäluoma (Member of the European Parliament)

10 Sept 2025 · Circular Economy Act & Packaging Legislation

Meeting with Stefan Köhler (Member of the European Parliament)

9 Sept 2025 · Politischer Austausch zum Circular Economy Act und dem Sekundärrecht zur PPWR

Meeting with Günther Sidl (Member of the European Parliament)

9 Sept 2025 · General exchange of views

Meeting with Massimiliano Salini (Member of the European Parliament)

9 Sept 2025 · PPWR

Meeting with Nicola Zingaretti (Member of the European Parliament)

2 Sept 2025 · Circular Economy Act

Flexible Packaging Europe urges swift approval of plastic recycling rules

11 Aug 2025
Topic — The Commission is establishing rules for reporting recycled content in plastic beverage bottles.
Message — The association supports the proposed rules for calculating and reporting recycled plastic content. They urge the European Commission to approve the act quickly to provide certainty.12
Why — The organization would benefit from increased legal clarity for its manufacturing members.3
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Meeting with Andreas Glück (Member of the European Parliament)

5 Jun 2025 · Environment Policy

Meeting with Aurel Ciobanu-Dordea (Director Environment) and FoodDrinkEurope and

22 May 2025 · Discuss with interested stakeholders the practical aspects and challenges of ensuring compliance with Art.5(5) of the PPWR (concerning PFAS limits in food-contact packaging)

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

8 May 2025 · Packaging and circular economy

Meeting with Christine Singer (Member of the European Parliament)

3 Mar 2025 · PPWR + Green Claims

Meeting with Markus Ferber (Member of the European Parliament)

12 Feb 2025 · Implementation of the PPWR

Meeting with Valérie Hayer (Member of the European Parliament)

11 Feb 2025 · Filières de recyclage des emballages

Meeting with Antonella Sberna (Member of the European Parliament)

10 Oct 2024 · Challenges and Opportunities in the Packaging Sector: Market Trends, European Regulations, and Sustainability Goals

Meeting with Laurent Castillo (Member of the European Parliament)

26 Sept 2024 · Législation européenne sur les emballages

Meeting with Christine Singer (Member of the European Parliament)

24 Sept 2024 · Austausch neue Legislaturperiode

Meeting with Giorgio Gori (Member of the European Parliament) and Euroheat and Power and

18 Sept 2024 · Presentation of priorities

Meeting with César Luena (Member of the European Parliament)

18 Jul 2024 · Packaging waste

Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

15 Apr 2024

The FPE welcomes the opportunity to provide feedback on the draft Regulation amending Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food and amending Regulation (EC) No 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food as regards recycled plastic and other matters related to quality control and manufacturing of plastic materials and articles in-tended to come into contact with food. To name just a few of the highest priority issues: Regarding Article 3a(iv), we consider that a migration limit of 0.15 µg/kg food for substances known to be genotoxic is appropriate, but is disproportionate at the risk management stage for substances not known to be genotoxic. Based on the current de facto limit of 0.01 mg/kg food, setting now a 67-fold lower value for substances not known to be genotoxic is not a reasonable risk management decision. According to the current Regulation (EU) No 10/2011, good technical quality is sufficient for use in plastic FCMs, as also explained in the Commission's guidance document purity could be even lower than that for direct food additives. To ensure that the requirements of the new Article 3a(iv) are met for addition to plastic FCMs, the purity level of additives would have to be much higher than for direct addition to food, which makes no sense at all. We therefore call for in-depth discussions and an impact assessment before such requirements are introduced in order to minimise the burden on the industry. At this stage, it is not even known whether the essential substances would be available in the proposed quality, in the quantity and at a cost level required by our industry. We are very concerned that many substances will simply no longer be on the market for use in FCMs. Article 6 point 5: PT4 refers to disinfectants. It is not clear to us why biocides that are preservatives could not also be (more) relevant here, for example PT6 and PT7. We would propose to include PT6 and PT7 (and possibly also others) with the additional requirement that these need to be petitioned for food contact use. The proposed amendment to Article 17 would have an impact on the compliance assessment of the vast majority of plastic food packaging and would require compliance with specific migration limits that are up to a factor of 10, or even more, lower than those on which the current compliance is based. We know from experience that this is not always achievable. It would have a massive impact on the flexible packaging industry and on its customers and should not be implemented without evidence of consumer harm in the current situation and without a thorough impact assessment. In the interest of consistency and based on the fact that the current conventional exposure scenario is significantly over-protective, we request that Article 17 point 2 (a) be amended so that the conventional S/V = 6 dm²/kg food applies in all cases. For further, more detailed comments on the Quality Amendment, please refer to the attached document. We remain at your disposal for further clarification and discussion. Ernst Simon Director Regulatory Affairs Flexible Packaging Europe
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Flexible Packaging Europe urges longer transition for bisphenol ban

7 Mar 2024
Topic — The European Commission is consulting on banning bisphenols in food packaging.
Message — FPE requests a 36-month transition for aluminium packaging with BADGE-based coatings. They also seek explicit wording on BPA precursors to ensure a level playing field.12
Why — This would prevent costly analytical testing and provide time to develop complex technical alternatives.34
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Meeting with Lara Comi (Member of the European Parliament) and FoodDrinkEurope and TomatoEurope Processors Association

21 Nov 2023 · PPWR

Meeting with César Luena (Member of the European Parliament)

16 Nov 2023 · PPWR

Flexible packaging industry urges realistic circularity targets in Taxonomy

3 May 2023
Topic — Technical screening criteria for economic activities contributing to a circular economy.
Message — FPE calls for targets aligned with the Packaging and Packaging Waste Regulation. They request lower recycled content thresholds and recognition for at-home refill pouches.123
Why — This ensures the flexible packaging sector can qualify for green investment reporting.45
Impact — Environmental advocates seeking strict closed-loop recycling standards across all plastic packaging types.6
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Flexible Packaging Europe demands harmonized rules and flexible recycling targets

20 Apr 2023
Topic — The EU is reviewing packaging requirements to improve design, recycling, and waste prevention.
Message — FPE urges the EU to prioritize market harmonization and provide clear deadlines for new design-for-recycling criteria. They request that recycled content targets be calculated as a producer average rather than per packaging unit. Finally, they demand product-specific impact assessments for proposed bans and reuse targets.123
Why — Portfolio-wide averaging would allow them to maintain market access for specialized food packaging.4
Impact — Environmental protections may be weakened if recyclability standards ignore a lack of collection infrastructure.5
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Meeting with Silvia Sardone (Member of the European Parliament, Shadow rapporteur) and PepsiCo

18 Apr 2023 · Meeting on Packaging Waste regulation proposal

Meeting with Vlad-Marius Botoş (Member of the European Parliament)

18 Apr 2023 · Packaging & Packaging Waste Regulation (PPWR)

Meeting with Pietro Fiocchi (Member of the European Parliament, Shadow rapporteur)

16 Mar 2023 · Packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur)

13 Mar 2023 · PPWR

Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Tetra Pak Group and

20 Feb 2023 · PPWR

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

27 Oct 2022 · Circular economy and the revision of the EU packaging rules

Meeting with Cyrus Engerer (Member of the European Parliament, Shadow rapporteur)

11 Oct 2022 · Waste Shipment Regulation

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

22 Feb 2022

Feedback of Flexible Packaging Europe, the organisation representing the interests of the European producers of flexible packaging The revision of the Waste Framework Directive (WFD) is a necessary complement to the ongoing revision of the Packaging and Packaging Waste Directive. While the 2018 revision has brought many advances such as higher recycling targets and capturing the waste hierarchy in legislation, this time round the WFD can address circularity blockers and turn them into enablers in line with the ambitions of the 2020 Circular Economy Action Plan. Flexible Packaging Europe’s preliminary views are the following: • Waste prevention should be operationalized with provisions favouring resource reduction at source by a combination of approaches. For packaging, which is warranted for necessary product protection, favouring light weight solutions makes the most straightforward option. Waste prevention is different from waste reduction, which can be tracked by an increase in recycling targets. • The revision of the WFD is an opportunity to fix sub-optimal waste collection systems, namely by adjusting Article 10 on derogations. The role of eco-modulated EPR schemes from 2024 and recyclability as a norm from 2030 should be well reflected. In short, all packaging must be separately collected for recycling. • We would support separate collection at source of flexible packaging in a stream with other lightweight packaging, including rigid plastics, metals, and beverage cartons. We invite the Commission to assess the benefits of mandating sorting of recyclables from residual and organic waste before landfill, incineration, or organic recycling, when separate collection is not possible. • While Member States are still implementing the 2018 WFD, we urge the Commission to issue the Guidance on EPR schemes and eco-modulation, focused on the net-cost approach. The WFD revision should examine the need to improve transparency, reporting and oversight aspects of EPR minimum requirements. • The definition of recycling should be clarified to include emerging technologies with various technical readiness levels as well as processes which yield multiple substances and include several steps. Overall, we expect that the revision of the WFD will be done in coherence with other relevant legislation, in particular the upcoming changes to the PPWD. We provide further details and explanations in our attached paper.
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Response to Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

18 Jan 2022

Flexible Packaging Europe welcomes the opportunity to provide feedback on this important piece of legislation. We are supportive of the overall direction of the draft, but highlight several shortcomings which may inhibit the take up of recyclates in flexible packaging. Article 2, paragraph 3, point 5 – definition of “recycled plastic materials and articles” Ensure coherence with the definition of “plastic materials and articles” found in Regulations 10/2011 and 1935/2004, which does not exclusively refer to the finished state. Article 6 – requirements for collection and pre-processing Clarify that the conditions listed are not cumulative and that inputs can include FCM-compliant offcuts and process scraps, which are a valuable secondary raw material. Articles 14, 15, 16 and 19 – approval of technologies Set a deadline in Article 15 for the Commission’s approval of novel technologies, after which the technology would be considered suitable. A similar deadline should be set in Article 16, which gives the Commission the prerogative to re-examine technologies considered suitable and in Article 19 which concerns authorisation of individual recycling processes. Operators should be allowed to pursue authorisation as soon as they consider that there is sufficient knowledge about the technology. This is particularly relevant for processes already authorised under national legislation proving high decontamination potential. Article 25 – registration of recyclers and decontamination installations Clarify what is the competent authority for installations located outside the EU. Article 31 – transitional provisions Recyclates used behind a barrier in line with existing legislation should be exempted from the authorisation process under this Regulation and the general risk-assessment process should apply. Annex 3, part B We recommend deleting the mandatory indication of the recycling installation number in the Declaration of Compliance as this would be commercially sensitive information. We would welcome a DoC which applies to converted materials, even if they are not exclusively made of recycled plastic and may even be combined with non-plastics. We elaborate further on our position in the attached file.
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Response to RoHS exemption for the use of mercury in other discharge lamps for special purposes

9 Jul 2021

Ladies and Gentlemen, We appreciate the opportunity to comment on this legislation proposal. FPE (Flexible Packaging Europe) and etma (European Tube Manufacturers Association) together represent the economic and technical interests of more than 120 member companies producing flexible packaging or tubes. These packaging systems are used for food, pharmaceutical products, cosmetics, and technical products. For example, flexible packaging or tubes are used for more than half of all food products placed on the European market, while they require only one sixth of the material of all primary packaging. The member companies employ about 60,000 people at more than 400 sites across Europe. Most of the companies operate production lines with UV lamps for curing printing inks and varnishes. These production lines are indispensable for the packaging manufacturers for both economic as well as environmental reasons. UV curing of inks and varnishes requires significantly less energy than the comparable drying of solvent-based systems and at the same time avoids the emission of VOCs. A ban on medium-pressure mercury lamps would jeopardise a significant part of the investments made on modern production equipment. Furthermore, any restriction of this technology within the EU would weaken the competitiveness of EU industry compared to manufacturers from non-EU countries, as the latter could continue to use mercury-based UV lamps. In our experience, the only technology currently capable of replacing medium-pressure Hg lamps and allowing the continued use of UV curing equipment would be UV emitting LEDs. However, this technology still has several disadvantages, including the very limited range of the wavelength spectrum and the low output power. These drawbacks limit the potential applications of this technology quite considerably, especially when it comes to the curing of printing inks or the corresponding formulation of clear varnishes and white inks. The performance and availability of systems is currently not yet suitable to sufficiently replace the existing technology. It will be several years before a suitable alternative for the current UV technology based on Hg lamps will really be available. In all this, we understand that, strictly speaking, the production lines operated by our member companies are not, in principle, covered by Directive 2011/65/EU at all, according to Article 2: "4. This Directive does not apply to: (d) large-scale stationary industrial tools; (e) large-scale fixed installations;" For this reason, it is of immense importance for our industry that this wording remains as it is. Notwithstanding this, and in order to avoid misinterpretations and to provide legal certainty in case the derogation in Article 2 does not apply in a specific case, we ask for a further extension of derogation 4(f) of Annex III: "Mercury in other discharge lamps for special purposes not specifically mentioned in this Annex" at least until 2026 and preferably even beyond. Yours sincerely Dr. Ernst Simon Director Regulatory Affairs Flexible Packaging Europe Consultant to etma
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Response to Revision of EU rules on food contact materials

29 Jan 2021

The FPE welcomes the opportunity to comment on the Initial Impact Assessment. Please see the attached document ("FPE response to the IIA.pdf") for details.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

31 Jul 2020

Flexible Packaging Europe (representing the flexible packaging industry in Europe) welcomes the opportunity to share its views on the inception impact assessment regarding the review of packaging and packaging waste rules. As the circular economy becomes a cornerstone of the EU’s industrial base, we appreciate the relevance of updated packaging rules. This initiative is of importance for us as it impacts how our products (flexible packaging) are designed, managed at end-of-life, and perceived. Most importantly, it contributes to our broader vision for a sustainable flexible packaging market where waste is minimized and resources are recovered and recycled, without pollution into the natural environment. Last but not least, this initiative is integral to our efforts to contribute to the EU’s objective to become carbon neutral by 2050. Having in mind the significance of this initiative, it is of utmost importance to define the problem and identify the causes in a way which will yield the correct policy options. Clear definitions will also make the economic, environmental, and social impact assessment more calibrated and effective. We are therefore contributing to the Commission’s better understanding of the problem, main drivers and possible solutions from a flexible packaging perspective, in line with the Better Regulation principles. - We are pleased to see that a well-functioning internal market for packaging while minimizing its negative environmental impact remains the double goal of EU packaging rules. - However, we take issue with the way the initiative addresses problems underlying packaging waste generation and packaging recyclability. In the current form, the approach can undermine the waste hierarchy and lead to increased carbon emissions. We discuss this in further detail in our attached position paper. - Packaging policy must go hand in hand with aims of the Green Deal, the climate agenda and the Farm2Fork Strategy. We ask the Commission to undertake a holistic analysis of all proposed policy options to ensure that packaging measures lead to further carbon savings. - While the inception impact assessment identifies a variety of drivers leading to increases in the amount of packaging placed on the market, we expect the Commission to engage into a thorough and holistic examination of each one. - EU packaging rules must be based on resource efficiency principles without sacrificing functionality and product safety. We regret seeing that this concept has not been captured adequately in the inception impact assessment. We specify in our attached position paper some options for guiding the impact assessment and are looking forward to engaging further with policymakers and stakeholders.
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Response to Reducing marine litter: action on single use plastics and fishing gear

24 Jul 2018

Flexible Packaging Europe (FPE) represents over 80% in turnover of the European flexible packaging converters with flexible packaging predominantly made of plastic. FPE supports systematic action to tackle litter, including the littering of plastic packaging. We will continue supporting initiatives to help solve the issue. We expect a policy applying to certain packaging categories to be appropriate (able to efficiently tackle the issue without risk of unintended consequences), coherent (supporting and not interfering with existing EU packaging policy in term of content and timing), proportionate (reflecting shared responsibility and accountability of involved stakeholders), evidence-based (based on robust impact assessment) and which considers the specificities/functionalities of packaging, existing waste management infrastructures and their economic dynamics. We are concerned that the proposed legislation is not fully consistent with these principles. Appropriate/Coherent: Focus on awareness raising campaigns and improved collection – first implement the newly adopted CEP We strongly believe that, to prevent packaging put on the market from being littered, the focus should be on awareness raising campaigns to promote responsible disposal and on improved waste collection, recycling and management systems in all EU Member States. The newly adopted Circular Economy Package (CEP) contains comprehensive measures including new Extended Producer Responsibility (EPR) requirements for packaging to further improve the effectiveness of packaging waste management systems and achieve those prevention goals. For those packaging items targeted in the proposal (incl. packets and wrappers), we strongly recommend to first and rapidly implement the CEP and the new EPR requirements rather than proposing to change them before their effectiveness can be assessed. FPE fully supports the goals and measures of the CEP. Proportionate: Remove the extension of EPR requirements to litter clean-up costs For the packaging items targeted in the proposal, we are concerned about the proposed requirement to include the not further specified costs for litter clean-up in EPR levy for the targeted packaging items. This could potentially lead to an unsustainable cost burden on industry and risk compromising the achievements of longer-term CEP goals. As recognised in the revised Waste Framework Directive, “the fight against litter should be a shared effort between competent authorities, producers and consumers”. The litter clean-up costs should therefore not be the sole responsibility of the producers and we think the extension of EPR obligations to these costs should be removed. Evidence-based: Assess social, economic & environmental implications of the proposed measures We are very concerned about the lack of comprehensive and robust impact assessment supporting some of the measures proposed and their potential unintended consequences. This includes among others the uncertainty about the overall efficiency and economic effect of requiring producers to pay for litter clean-up. The same goes for the proposed 90% separate collection target for bottles and its impact on the waste management of other packaging materials. About flexible packaging & circular economy Flexible packaging solutions (incl. packets and wrappers) are generally very resource efficient, able to perform the required packaging functions while minimizing the use of material and energy throughout their entire life cycle – thus supporting a circular economy. Effective and widely available collection combined with continuous improvement of sorting and recycling technologies will definitely increase their recycling performances (and further reduce risks of being littered). To make this happen and accelerate the process, FPE is engaged together with more than 60 European stakeholders of the entire value chain of flexible packaging in the CEFLEX project (www.ceflex.eu)
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Response to Evaluation of Food Contact Materials (FCM)

22 Dec 2017

Flexible Packaging Europe represents manufacturers of flexible packaging in Europe. We welcome this proposed review of food contact legislation and would wish to provide input during the consultation phase. At this stage, we make the following points: 1. The operation of Good Manufacturing Practice (GMP) is an essential part of the process of producing safe Food Contact Materials (FCM). This is recognised in article 3 of Regulation (EC) No 1935/2004 – “Materials and articles … shall be manufactured in compliance with good manufacturing practice so that …”. Regulation (EC) No 2023/2006 is an important part of the legislative framework and should be explicitly included in the evaluation Roadmap. 2. In “Drivers” first row, there is the sentence: “FCMs are not inert and substances with hazardous properties may within them be transferred to food in sufficient quantities to cause a risk to consumers.” This seems to imply that the majority of FCM are inherently unsafe – which is not true. We suggest an alternative wording: “FCMs are not inert and substances within them may be transferred to food. If hazardous and in sufficient quantities, this could cause a risk to consumers.” 3. In “Drivers” fourth row, there is an assumption that the safety assessment of FCM substances will be achieved through an EFSA assessment of the risk of all substances and the creation of positive lists. This is possible for Intentionally Added Substances. The Roadmap should acknowledge that Non-Intentionally Added Substances (NIAS) are also present in FCM. These cannot be risk assessed by EFSA and placed on a list. There is a need to raise the issue of industry self-assessment of NIAS and how this can be done in a way that is effective and transparent. 4. A barrier to the extension of harmonised measures is the sheer number of substances that require assessment and the limited resources of EFSA to do this. Industry self-assessment of substances is also a possible solution for this issue.
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Meeting with Karl-Friedrich Falkenberg (Director-General Environment)

12 Feb 2015 · Prevention's potential in packaging to deliver resource efficiency