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Metal Packaging Europe External Affairs ASBL

Metal Packaging Europe

Metal Packaging Europe is an association representing producers of rigid steel and aluminium packaging.

Lobbying Activity

Meeting with Martine Kemp (Member of the European Parliament, Shadow rapporteur) and Orgalim – Europe's Technology Industries

2 Dec 2025 · Steel Safeguards

Meeting with Jörgen Warborn (Member of the European Parliament)

28 Nov 2025 · Steel

Meeting with Karin Karlsbro (Member of the European Parliament, Rapporteur) and Orgalim – Europe's Technology Industries

17 Nov 2025 · Stålmarknaden

Meeting with Raphaël Glucksmann (Member of the European Parliament)

14 Nov 2025 · Steel instrument

Metal packaging industry urges EU to recognize permanent materials

5 Nov 2025
Topic — The European Commission is consulting on the new Circular Economy Act legislative proposal.
Message — MPE wants EU law to recognize permanent materials like steel and aluminium. They also urge for stricter controls on metal scrap exports.12
Why — This would secure their supply of materials and prevent costly mandatory targets.34
Impact — International scrap buyers would lose access to high-quality European secondary materials.5
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Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM.

Metal Packaging Europe urges process-specific benchmarks for CBAM

25 Sept 2025
Topic — This initiative defines rules for adjusting CBAM certificates based on ETS free allowance phase-outs.
Message — MPE requests that free allocation remains available until an export solution is found. They advocate for differentiating benchmarks by production processes and including emissions from downstream activities to prevent circumvention.123
Why — These adjustments would protect the international competitiveness and resilience of the European packaging industry.4
Impact — Exporters of high-carbon products would lose exemptions if the inward processing procedure is abolished.5
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Metal Packaging Europe seeks exclusion of indirect emissions from CBAM

25 Sept 2025
Topic — This consultation defines the methodology for calculating embedded carbon emissions during CBAM's definitive period.
Message — The group demands the exclusion of indirect emissions to protect industry competitiveness. They recommend establishing two distinct default values for aluminium based on primary and secondary production routes. Furthermore, they ask that 2026 emission data not be retroactively adjusted in 2027.123
Why — This would lower compliance costs and prevent domestic metal processing from becoming prohibitively expensive.45
Impact — Environmental advocates lose oversight as a significant portion of carbon impact is ignored.6
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Meeting with Jörgen Warborn (Member of the European Parliament)

18 Sept 2025 · Steel

Metal Packaging Europe urges CBAM expansion to close trade loopholes

26 Aug 2025
Topic — Consultation on extending the carbon border tax to cover more downstream products.
Message — Include specific items like caps and aluminium can ends in the regulation. MPE also calls for moving the administrative verification duty to foreign exporters.123
Why — This would shield EU manufacturers from subsidized imports and lower administrative costs.45
Impact — Non-EU manufacturers lose the competitive advantage gained by avoiding EU carbon costs.6
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Metal packaging group demands inclusive EU steel trade protections

18 Aug 2025
Topic — The European Commission is considering new trade measures to address global steel overcapacity.
Message — The group demands an "inclusive trade policy" covering the "entire Europe's steel value chain" by including packaging codes CN 7310 and CN 8309. They also want "priority access" to EU-produced steel for domestic buyers.12
Why — This would protect domestic firms from being squeezed by high costs and cheap imports.3
Impact — Foreign packaging producers and raw steel exporters would face significant new trade restrictions.45
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Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

Metal Packaging Europe, together with our coalition partners, strongly supports the inclusion of municipal waste incineration and landfilling in the EU Emissions Trading System (EU ETS), as part of the upcoming review planned for July 2026. A recent study (attached) confirms that this measure would deliver significant climate and employment benefits: 1. Major emissions cuts Including incineration in the EU ETS would reduce CO emissions by 47 million tonnes in 2030, rising to 1832 million tonnes in 2040. 2. Job creation Shifting from incineration to recycling could generate 8,70016,400 new jobs by 2030, and 11,60021,700 by 2040, as recycling is far more labour-intensive than incineration. Please find attached the full study and our coalition letter calling for the inclusion of both incineration and landfilling in the EU ETS.
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Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič)

8 Jul 2025 · Metal packaging industry and its challenges

Meeting with Paulo Cunha (Member of the European Parliament)

2 Apr 2025 · Exchange of views on the impact of tariffs and quota systems on downstream steel manufacturing in the EU and the new agenda of the European Commission

Metal Packaging Europe calls for harmonized rules to protect trade

30 Jan 2025
Topic — The European Commission is seeking feedback on its Single Market Strategy for 2025.
Message — MPE urges the EU to dismantle trade barriers and prevent market fragmentation through harmonized provisions. They propose that rules withstand a Single Market test and suggest a two-step TRIS notification process.12
Why — Standardized rules would reduce the financial burden of adapting packaging designs to varying national requirements.3
Impact — Member States lose the power to implement unique national rules that restrict packaging movement.4
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Response to Digital Product Passport (DPP) service providers

10 Dec 2024

Metal Packaging Europe (MPE) welcomes the COMs focus on increasing the sharing of information and transparency along the supply chain with the help of digital product passports (DPP). However, there are concerns, on the scope, granularity and accessibility of the information requested for the DPP. For example, recyclers need different information on materials and substances to make decisions on recycling than consumers to make purchasing decisions based on potential health concerns. Another point is responsibility of providing certain information: Every actor from products value chain should only declare information for the materials or components for which he is responsible, e.g., if a product is made of components that are supplied by different manufacturers it is up to these manufacturers of the components to provide the required information on those, rather than the producers who uses the various components to produce/assemble the product. In addition, it is key that all relevant confidentiality, competition rules and intellectual property rights are observed and upheld and the data needs to be protected against breaches and misuse. Restricting access to the collected data is crucial. It is absolutely necessary to guarantee that DPPs are set up in a way that relevant information is only accessible to relevant actors. Moreover, providing too detailed data on materials/substances and quantities could be detrimental to product manufacturers if it can be accessed by the competition and it might breach their rights. Finally, to keep the granularity of information manageable and to not create excessive administrative burden, the actors should be required to provide only information which they are obliged to share under the different existing pieces of legislation (PPWR, FCM, etc.). The accurate determination of data needed, data providers and differentiated access to data users will be critical for the success of DPP in EU.
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Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

4 Dec 2024 · Metal

Meeting with Pietro Fiocchi (Member of the European Parliament)

26 Nov 2024 · Packaging

Meeting with Elisabetta Gualmini (Member of the European Parliament) and Apple Inc.

26 Nov 2024 · ITRE Committee

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

17 Apr 2024 · Green Claims Directive

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

12 Apr 2024

Metal Packaging Europe (MPE) is responding to the public consultation on the proposed amendments to Regulation (EU) 10/2011 as, although much of the products produced by our members are out of scope of (EU) 10/2011 as amended, MPE represents the manufacturers of metal closures, the gaskets of which are in scope. These gaskets are essential to ensure that closures are hermetically sealed ensuring consumer safety. See our comments attached.
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Meeting with Maroš Šefčovič (Executive Vice-President) and

22 Mar 2024 · Clean Transition Dialogue with the Steel Sector

Meeting with Margrethe Vestager (Executive Vice-President) and

22 Mar 2024 · Discussion of current challenges facing the European Steel sector attended by private industry as well as Ministers and official representatives of Italy, Romania, Poland, Czechia, Belgium, Hungary and Luxembourg

Metal Packaging Europe seeks clarity on BPA restriction rules

6 Mar 2024
Topic — A consultation on a draft regulation restricting bisphenols in food contact materials.
Message — The industry group recommends replacing 'use' with 'intentional use' to improve clarity. They also ask if the ban applies to products manufactured for export markets.123
Why — Clearer definitions and export exemptions would protect production chains and reduce costs for manufacturers.4
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Metal Packaging Europe urges recognition of highly recyclable materials

24 Apr 2023
Topic — The European Commission is revising rules to reduce packaging waste and improve recycling design.
Message — MPE requests a 'highly recyclable' status for permanent materials and universal deposit return systems. They also seek to ensure plastic content targets do not apply to metal packaging components.1234
Why — This classification would allow the metal industry to avoid costly reuse mandates and plastic-related compliance burdens.56
Impact — Environmental groups lose if reuse targets are weakened by broad exemptions for single-use metal packaging.7
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Meeting with Krzysztof Hetman (Member of the European Parliament)

22 Mar 2023 · Exchange of views on Regulation on Packaging and Packaging Waste (meeting delegated to parliamentary assistant)

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and Plastics Recyclers Europe

15 Feb 2023 · Packaging waste

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and European Aluminium AISBL and

22 Nov 2022 · Draft proposal of a Regulation on Packaging and Packaging Waste (PPWR)

Response to Form for the statements relating to the own resource based on non-recycled plastic packaging waste

4 Oct 2022

Metal Packaging Europe (MPE), the association bringing together European producers of rigid metal packaging, welcomes the adoption of an implementing regulation establishing the format for reporting non-recycled plastic packaging waste as an own resource. MPE recalls that this own resource concerns non-recycled plastic packaging waste and that these must therefore be limited to plastics as defined in Article 3, point 1a) of Directive 94/62/EC of the European Parliament and the Council on packaging and packaging waste. MPE also notes that contributions will be calculated based on Eurostat data, which Member States already collect and provide under existing reporting obligations. More concretely, following the Packaging and Packaging Waste Directive (Directive 94/62/EC) and its implementing Decision (Decision (EU) 2019/665), Member States already provide data on plastic packaging waste generation and recycling. Therefore, MPE would like to raise some concerns: - In the Council Regulation (EU, Euratom) 2021/770, Article 6 on the calculation of the own resource based on non-recycled packaging waste refers to Article 6a of the Directive 94/62/EC and the methodology set out in Article 6c of Decision 2005/270/EC. This decision 2005/270/EC was amended by the Commission Implementing Decision (EU) 2019/665. This text should be the reference as it gives new rules in Directive 94/62/EC regarding the calculation for the attainment of the packaging waste recycling targets for 2025 and 2030. - MPE considers that the definitions in point (10) relating to “plastic packaging waste generated” and in point (11) relating to “plastic packaging waste recycled” are not precise enough. These should include elements of definitions concerning plastic and packaging waste. They cannot be based on some drafted definitions in Decision 2005/270/EC because these have been removed by the Implementing Decision (EU) 2019/665. - In addition, the use of the phrase “plastic components of composite and other packaging” in these definitions can be confusing because they cover the notions of composite packaging (defined in article 3(2b) of Directive 94/62/EC) and could also include other recyclable and non-plastic packaging. MPE considers that it is essential to avoid legal uncertainties by adopting definitions which have not been approved by European legislators, to avoid inconsistencies between existing definitions and guarantee any possibility of misinterpretation by Member States. This implementing regulation could constitute a good basis for helping Member States to define more precisely what is considered plastic that can be subject to plastic tax at a national level and whose objective would strengthen this own resource of the EU budget.
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Metal Packaging Europe urges improved sorting for recycling targets

26 Jul 2022
Topic — The Commission is assessing Member States' progress on 2025 and 2035 waste targets.
Message — Metal Packaging Europe supports the report to identify Member States missing recycling targets. They claim optimized separate collection and sorting are prerequisites for high-quality recycling. They also suggest incentivising modern sorting equipment and effective deposit return systems.123
Why — Well-sorted aluminium and steel scrap constitutes a major resource for their new products.4
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

Among its members, MPE has representatives of aluminium and steel sectors. These 2 sectors are top performers in recycling packaging materials. With respective rates of 76%, and 84% our industries have worked closely with European, national and local authorities, Extended Producer Responsibility Schemes, waste management operators and, last but not least, customers, brands and civil society at large, to invest in collection and sorting systems that underpin the recycling infrastructure. Metal Packaging Europe (MPE) welcomes the opportunity to contribute to the ongoing work of the Commission in preparation of the revision of the Waste Framework Directive (WFD) scheduled for 2023. With the overarching aim of reducing the use of primary raw materials for the manufacturing of products needed for the ever-growing population, MPE considers that the current Waste Framework Directive provides the Commission with an opportunity to have circularity truly embedded in the legislation by taking into account the following elements: - Include a definition of high-quality recycling - Recognise the concept of permanent materials at EU-level - Review of the waste hierarchy with the distinction between multi-recyclable and “limited” recyclable - Promote the effective separate collection and sorting of waste to promote high-quality recycling About Metal Packaging Europe Metal Packaging Europe gives Europe’s rigid metal packaging industry a unified voice, by bringing together manufacturers, suppliers, and national associations. We proactively position and support the positive attributes and image of metal packaging through joint marketing, environmental and technical initiatives. We represent the industry’s views and voice opinions so that stakeholders understand how metal packaging contributes to the Circular Economy.
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Response to Revision of EU rules on food contact materials

27 Jan 2021

Metal Packaging Europe is providing feedback on behalf of CEPE (European Council of the Paint, Printing Ink and Artists' Colours Industry ) and Metal Packaging Europe. A document is herewith attached.
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Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

8 Feb 2019

Metal Packaging Europe input to the public consultation on hazardous chemicals - new rules on classification, labelling and packaging; particularly with respect to titanium dioxide Metal Packaging Europe welcomes this public consultation under the Better Regulation initiative. Metal Packaging Europe represents the manufacturers of coated and uncoated metal packaging. Many of our products make use of titanium dioxide pigmented coatings and sealants which are bought in pre-compounded as liquids, powders or pastes with the single limited exception where titanium dioxide powder may be bought in as a raw material for self-compounding of closure sealing gaskets by some manufacturers. Our response here is related primarily to the use of bought in pre-compounded pigmented materials. CEPE, the European trade association for coatings manufacturers represents most suppliers of titanium dioxide pigmented materials into our sector and we are aware that they have responded to the consultation process. We agree with their comments and will not repeat them in detail in our response here, although their response is focused on the unjustified consequences of the proposed classification on consumer use of their pigmented products. We do however wish to raise some points which are of particular concern to our sector. Where pigmented coatings or sealants are bought in pre-compounded, there is always a resinous binder which incorporates or binds the pigment into a high- performance protective film. Where materials are supplied in liquid form, any spray or droplets will incorporate binder as well as titanium dioxide so with respect to inhalation (the only exposure route of concern), there would not be direct physical contact with individual titanium dioxide particles and lung tissue. Where materials are supplied in powder form, the powder is finely ground thermoplastic polymer which has the titanium dioxide pigment incorporated within it before grinding, so there should not be any free unbound titanium dioxide in the powder. As the mode of toxicological action underlying the proposed classification is directly related to particle size and morphology, titanium dioxide bound in a polymeric matrix should not be of concern. In addition, we are concerned that: • Although titanium dioxide is authorized for use in food contact materials and articles, and although it has been made clear that the route of exposure of concern is by inhalation, it has been our experience that the proposed classification would still lead to adverse media and pressure group responses that will be damaging to our sector. • It should be clarified that the proposed classification for powder and powder mixtures should only refer to mixtures that have free unbound and uncoated titanium dioxide particles. • It seems inappropriate and sets a dangerous precedent to apply classification based on toxicological effects resulting purely from particle morphology to a specific chemical substance.
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Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and

15 Nov 2018 · Possible safeguards

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

22 Jun 2018 · Steel tariffs and safeguards

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and The European Organisation for Packaging and the Environment and

2 May 2017 · Packaging and Packaging Waste Directive

Meeting with Jyrki Katainen (Vice-President) and FoodDrinkEurope and

28 Mar 2017 · Plastics Value Chain