Free Pack Net Holding
FPN
Within the Circular Economy and Green Deal framework we are focus to implement RTP-Reusable Transport Packaging (made in PP-Polypropylene) for the Large Household Appliances market sector and TV.
ID: 218718048158-08
Lobbying Activity
Response to Circular Economy Act
23 Aug 2025
Thank you for the opportunity. The argument is very complex and there is not the possibility to write a Treaty. Premises: 1) manufacturers, retailers, online platforms and logistics companies have to be considered equal in responsibilities like mentioned in the PPWR. 2) Circular Economy on raw materials require deep eco-design analysis on products and sectors and the wide extension of EPR. 3) Circular Economy on Products: firstly, the circular economy is focused on the use, not the production of objects, and operation & maintenance skills of reusables products and reusable packagings are now a key field of competency to develop Circular Reverse Logistics, Repair, Refurbishment and Re-Sell, DPP, LCA and Environmental labelling on the whole life cycle (including the huge amount of damaged products, transports and the huge amount of water to recycle 1 ton of cardboard - from 10 to 20 tons for 1 ton of cardboard). Secondly, that THE SUCCESS OF THE CIRCULAR INDUSTRIAL ECONOMY is based on models innovation, competitiveness and the full understanding of different financials macro indicators. Maintaining ownership of goods and materials in the Circular Economy gives resilience on a corporate, national and European level. Small flexible factories closed to the market and capable to produce (repair,.........) different products simultaneously, reducing the whole environmental impact and TCO - the Large Household Appliance sector with its standard products 60x60cm and obsolete technologies and financial models ( built to stock) is an example to be seriously evaluated. THE CONCLUSION: manufacturers/retailers have to learn that in a CIRCULAR INDUSTRIAL ECONOMY they earn their money not at the Point of Sale but in the use phase of objects ! Will the penny finally dropped with business leaders and financial analysts? I remain available for any support. Thank you
Read full responseResponse to Measures to reduce microplastic pollution
17 Oct 2023
The generation of micro pollutants plastic is is a wide argument that require specific actions in different market segment. We therefore prefer to be focused on the area of problematic packaging materials that in different areas of their use are generating micro plastics. We want to outline one of the most dangerous material today used for disposable packaging, the Expanded Polystyrene. It borns as a material composed of micro-granules which are expanded during the production process. As part of the same production process, a large quantity of micro-plastics are generated and end up on the floor of the production site, where they are subsequently collected roughly to be usually disposed of together with the dry material, therefore preventing an appropriate disposal process with the rest of the plastic material. Subsequently, after the granular material has been expanded and formed the packaging, the mere movement of the same causes further micro granules which are disposed of in an inappropriate manner as described above. Even when expanded polystyrene packaging arrives in our homes, further micro granules are generated. In fact, it will have happened to everyone to receive a washing machine packaged in expanded polystyrene at home and, during the unpacking operations of the washing machine, the packaging breaks, crumbling into many micro-granules which cannot be collected and disposed of inappropriately as described above. In addition, even when the expanded polystyrene packaging is appropriately collected, in the shredding systems thereof, an abnormal quantity of micro granules is generated which are inappropriately disposed of as described above. In conclusion, given the large number of cases at our disposal, we can confirm that expanded polystyrene is a very dangerous material which, thanks to its ability to dismember and crumble, constitutes a real and enormous danger for the pollution of our land, lakes, rivers and seas Thank you
Read full responseResponse to Ecodesign for Sustainable Products - Product priorities
2 Feb 2023
Ecodesign for Sustainable Products ANALYZED SECTOR: LARGE HOUSEHOLD APPLIANCES (LHA) The Packaging problem. 1. Disposable packaging or better Problematic Packaging (Expanded Polystyrene and cardboard) in the LHA sector, are not able to protect adequately appliances during warehousing, transports and handling and in Europe the average damage rate from the Factories to end consumers is 5%, equal to 5.5 Mpcs per year, with an average economic impact of 20 per piece, that include all costs for manufacturers and retailers. In addition, 2. Disposable packaging materials or, better, problematic packaging materials are not able to resists autonomously to packaging requirements indicated on the external side of the product packaged. Usually, symbols of lateral forces are indicated up to 1200 Kg and, stacking level symbols (vertical forces) to be used during warehousing is no more than 5, 6 level. However, within laboratory tests, products are tested for vertical forces up to 1200 Kg and more. Therefore, is the Appliance that have to be designed and produced with robust metal structures able to resist to these forces usually 1200 Kg vertical and lateral. Dishwasher have to wash dishes and not resist to 1200 kg; customers are paying for technical performances that the y will neve use. 3. It is therefore clear that the normal rules for Ecodesign and MEErp are not taken into consideration by eco-designers and producers, creating an environmental and economic disaster that transforms into enormous damage for the community and the environement. 4. On Nov 30th 2022, EC Regulation COM(2022) 677 final 2022/396 Final, article 26 is stating that on Jan 1st 2030 the 90% of LHA have to be packed with Reusable Transport Packaging (RTP). In accordance with ISO definition for packaging, RTP are structural and able to protect product inside. Market experience show that using RTP, damages are reduced to zero and due to the fact that RTP are able to resist autonomously to vertical and lateral forces, Appliances/products, have to be able to be designed ECO DESIGNED, only for their specific function. COM (2022) 677 Final and Ecodesign for Sustainable Products are strongly connected. Recommendations : if Ecodesign for Sustainable Products, aim to indicate information-related requirements and environmental performances in order to ensure greater sustainability while supporting consumers on their choice towards more environmental friendly and less expensive solutions, the adoption of a label dedicated to the type of packaging used must be introduced immediately and without delay. This will i) create synergy with Com 677 Final, ii) support European citizen during their choice, iii) support manufacturers towards the re- ecodesign of products by introducing the Product Technology Change, because the dishwasher have to wash dishes and not resist to 1200 Kg! Thank you
Read full responseResponse to Fitness check of how the Polluter Pays Principle is applied to the environment
11 Dec 2022
PPP considerations respectfully offered to EC. Re-Think the very nature of Principles. Pollution taxes always affect the final customers and they enter the income of the consortia, the States and, in percentage terms, those of the Commission. In the packaging sector, the "compliance fee" for those who place bulky problematic packaging materials (ie: expanded polystyrene) on the market has existed for at least 25 years. However, they are very little and represent the legalized way out for companies that, while declaring themselves environmentally conscious, do not want to change towards more circular and environmentally friendly systems. All these costs go into the industrial cost of the products, significantly increase when the percentage margins for the sale are entered and triple when the retailers also add their margins. In the end, the final consumer pays; European citizen who has no choice. If we want to solve the problem, we need to rethink the principles behind the PPP model, introducing tax relief mechanisms or other, for companies that DO NOT pollute; while Companies that, although an environmentally friendly technology (BAT - Best Available Technology) is available on the market, do not use it, have to pay MUCH more (PPP). The BAT technologies should be mapped and identified by the European Commission, which could use as a "circular" measurement criterion, probably the same criteria that have already been used in the ISO-TC-323/WG4 group (circular economy - measured initiatives), attributing a "blue" sticker (or other) which allows the consumer to be able to recognize the "environmental quality of the choice he is about to make". This allows to widen the gap between THOSE WHO POLLUTE and THOSE WHO PRESERVE THE ENVIRONMENT. This allows European citizens to have an alternative, having perception of WHAT they are buying and HOW much their choice affects the environment. I remain available. Thank you
Read full response