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IK Industrievereinigung Kunststoffverpackungen e.V.

IK

Wir, die IK Industrie­vereinigung Kunststoff­verpackungen e.V., sind der Wirtschaftsverband der deutschen Kunststoff­verpackungs­industrie.

Lobbying Activity

Meeting with Peter Liese (Member of the European Parliament)

14 Oct 2024 · PPWR

Meeting with Christine Schneider (Member of the European Parliament)

9 Apr 2024 · PPWR

Meeting with Andreas Glück (Member of the European Parliament)

14 Mar 2024 · Packaging and Packaging Waste Regulation

Meeting with Peter Liese (Member of the European Parliament)

13 Mar 2024 · Austausch

Response to Initiative on EU taxonomy - environmental objective

3 May 2023

The proposed criteria for the manufacture of plastic packaging proposed in Annex II 1.1. are not suitable for describing a sustainable economic activity. On the contrary, the criteria would considerably endanger the transformation to a circular economy for plastic packaging, because the proposed criteria are in many cases unbalanced, unrealistic and, moreover, are not at all scientifically justified. Examples are given in the detailed comments attached. The proposed criteria therefore do not comply with the requirements of the underlying taxonomy regulation, according to which the criteria must, among other things, "be based on conclusive scientific evidence" and "take into account the life cycle" of products (Article 19 of Regulation (EU) 2020/852). The proposed criteria would make it massively more difficult for nearly all manufacturers of plastic packaging to access investments in better product design and processes. The same applies to the entire plastics value chain regarding their investments in new materials and the expansion of recycling and sorting processes. Such investments are a prerequisite for a transformation to the circular economy to succeed. The proposed criteria would make these investments impossible in many cases. In addition, the proposed criteria for packaging draw on many ideas currently being discussed in the context of the Commission's proposal for an EU Regulation on Packaging and Packaging Waste (COM(2022) 677 final, hereafter PPWR). We note with great concern that the proposed criteria are not aligned with the proposals in the PPWR (see attached document for details). Such contradictions create considerable uncertainty for companies in the plastics industry, the entire packaging value chain and the financial industry. What is needed instead is legal and planning certainty so that companies will actually make the investments on the way to a circular economy for plastic packaging. Furthermore, the Commission proposal contains concrete specifications only for plastic packaging but not for packaging made of other materials. There is no justification given for the different treatment of packaging materials. This justification should be provided, because otherwise there are considerable doubts about the proportionality of the regulation. Environmental organisations such as the WWF and NABU are already warning that the increasing consumption of disposable packaging made of cardboard and paper will lead to a shift in environmental problems, especially for the protection of forests and biodiversity. Moreover, one-sided measures that discriminate against plastics lead to an avoidance behaviour in which packaging made of other materials is coated with plastic. This development worsens the conditions for recycling and contributes to an increase in packaging waste and CO2 emissions, and may also be a cause of microplastic emissions in paper recycling. The one-sided proposed criteria for plastic packaging thus give false incentives for the development of the packaging market. We therefore recommend that the proposals with regard to plastic packaging be withdrawn and, once the PPWR has been adopted, be relaunched on the basis of the legal targets and on the basis of a comprehensible justification. See for our detailed comments the attached document.
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Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur for opinion)

3 May 2023 · Packaging and packagingwaste

Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

24 Apr 2023

Artikel 7 (Minimum recycled content in plastic packaging): Ten German and international business associations from the entire value chain as well as the Wuppertal Institute for Climate, Environment and Energy support a more flexible use of recyclates without weakening the intended security of demand for recyclates. The signatories seek more flexibility in the use of recyclates across different products of the same polymer type and across different companies in order to take into account the different conditions for the market access and the use of PCR, especially in the interest of SMEs. It is also in the interest of the environment to allow for an energy efficient cascading use of PCR. Please find attached our joint letter, containing concrete amendment proposals to Article 7.
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Meeting with Malte Gallée (Member of the European Parliament)

20 Mar 2023 · circular economy & returnable bottles