The International Release Liner Association (IRLA) acknowledges and welcomes the proposed focus on Paper, Pulp Paper & Board as intermediate products under the ESPR and supports their prioritisation within the initial Work Plan bearing in mind their importance to the circular economy. However, when it comes to the varied range of speciality coated papers that are manufactured/marketed and the range of uses to which they are put, it might be premature to include those within the scope of a potential first action since more time may be required to generate data and build consensus on key criteria to be considered for inclusion under the ESPR. Therefore, IRLA would recommend excluding coated papers from the scope of any potential first action in the Paper, Pulp Paper & Board intermediate product sector
The attached file represents the views of the membership of the International Release Liner Association (IRLA) in respect of the consideration of release liners, particularly in the context industrial and professional uses, as non-packaging items and the Association calls upon the Commission, Parliament and Council to clarify that point in any further development of this proposed text, especially as an example in the relevant Annex. With over 80% of release liner use in non-consumer sectors, the ability to collect and recycle segregated siliconized papers and films provides the most significant opportunity to maximise recycling rates in this product sector. Both the IRLA members and their customers are already committed to this objective and to be accountable for their achievements in this respect. The IRLA membership would also like to highlight that self-adhesive surfaces avoid the widespread use of liquid adhesives, with the waste and potential pollution resulting from that option. Since a 'zero pollution environment' is a central goal of the European Green Deal, other European Union legislation should be sure to avoid jeopardising that objective by undermining a fundamentally cleaner technology.