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Roundtable for Reusable Crates Trays and Pallets

RCTP

To promote the use of reusable and returnable plastic packaging, resulting in the overall reduction of plastic waste through advocating for a fair regulatory framework for secondary packaging.

Lobbying Activity

Response to Initiative on EU taxonomy - environmental objective

2 May 2023

The Roundtable for Reusable Containers Trays and Pallets (RCTP) welcomes the Taxonomy Environment Delegated Act on the Technical Screening Criteria. The RCTP supports the inclusion of Design for Reuse in Annex II, which includes the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to the transition to a circular economy. Regarding the draft Delegated Act, the RCTP would like to propose the following two recommendations: Records on the number of fillings and Reuse The RCTP believes that robust reusable packaging systems contribute to the transition to the circular economy. Nonetheless, from certain types of transport packaging in open loops, records on the number of fillings and reuse are not being monitored, due to the characteristics and application of the packaging type, for example, plastic beer crates. As the material of such reusable packaging is inherently high in value, it is reused multiple times within a company for the investment to be economically justified. In addition, the records on the number of fillings and reuse are usually owned by the poolers (owners) of the transport packaging and not the manufacturers. Therefore, the RCTP believes that despite not having records on the number of fillings and reuse of the individual packaging units, the activity of manufacturing plastic packaging under design for reuse should still be considered eligible if records are collected. Definition on Reuse Moreover, the RCTP believes that systems for reuse and the number of rotations should be clearly defined in the text. Currently, it refers implicitly to European law such as the Packaging and Packaging Waste Regulation (PPWR), which could be problematic if the definition in the PPWR does not contain a minimum number of rotations and a clear description of the incentives to establish closed and open pools. Therefore, the RCTP stresses the need to include a definition of rotations in the Delegated Act, including a minimum number of 10 rotations. By adding a specific number of rotations, greenwashing practices and single-use packaging being marketed as reusable packaging can be avoided.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

22 Feb 2023

The RCTP welcomes the ambitious proposal of the European Commission for a review of the Packaging and Packaging Waste Regulation (PPWR). Please find below the RCTP's main concerns: Define reuse: Crucial for a successful transition to reuse is to define the properties of Packaging (art. 3) and reusable packaging (art. 10) to ensure the correct application of reuse. In order to ensure this, a minimum number of 25 rotations and a minimum of 5 years should be included in the definition of reusable packaging. We also believe that a definition of reusable packaging must be included under Article 3. Reuse targets: The RCTP welcomes the ambitious reuse targets for pallets, plastic crates, foldable plastic boxes, pails and drums in transport packaging markets (article 26 point 7) and endorses the exclusive use of reusable packaging for delivering goods within Member States, under point 13. Nonetheless, we are concerned that cardboard is excluded from the scope under point 12 and 13. In order to have a just and effective transition to a circular economy, all packaging types including cardboard should be included in the obligation to be reusable when delivering goods within the same Member State. Excluding single-use cardboard packaging from the obligation to move to reusable solutions will significantly hamper the EUs course to achieve a circular economy. Whilst showing the right direction, we believe the 30% target for 2030 could be more ambitious - 50% is justifiable - to incentivise the transition toward a circular economy. Recycled content targets: The RCTP underwrites the goal to keep resources as long in the economy as possible through recycled content. However, to reach a level-playing field and to avoid unattainable targets for high-quality and long-lasting RTPs manufacturers, we want to ensure that the percentage of recycled plastic content reflects current technological and legal constraints and the future availability of material. RTPs are in fact long-standing investment goods which are fundamentally different from fast-moving consumer goods and must be therefore clearly distinguished in the targets for recycled content, with options of a derogation and/or a revision of the target for this specific type of packaging. In addition, the RCTP believes that setting the targets per unit per packaging is not realistic and hampers the scaling of recycled materials. Therefore, we are recommending setting the percentage of recycled plastic content targets per factory at the producer level. Contact-sensitive recycled content target: The 10% of recycled content for contact-sensitive packaging is unattainable due to legal constraints. The RTP industry largely operates in the food segment and produces packaging that is in direct contact with food in a closed loop. Given this limitation, for safety reasons, the market for eligible recyclable material is too small to achieve the proposed target. Other types of plastic packaging: RCTP is worried about the target of 35% of minimum recycled content recovered from post-consumer plastic waste per unit of plastic packaging. Increasing the percentage of recycled content with post-consumer plastic waste in reusable packaging will effectively reduce the quality, longevity and producibility of safe and functioning transport packaging. Due to the nature of RTPs, packaging will last for about 10 to 15 years in the market before manufacturers can claim it back to regrind it into a new product. Currently, 100% of RTPs are already, at end of the life cycle, recycled and remoulded into new crates over and over again. Obligations of manufacturers: The RCTP proposes to apply Article 13 paragraph 8 only for reusable products placed on the market from 2030 onwards. Recalling a significant amount of RTPs before they reach their natural lifetime potential (10-15 years) will cause a waste of resources. For the full position and argumentation, please find the document attached.
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Response to Sustainable Products Initiative

8 Jun 2022

The Roundtable for Reusable Containers Trays and Pallets (RCTP) is happy to submit feedback on the Ecodesign for Sustainable Product Regulation proposal. The RCTP supports the ambitions to make products in the EU market more sustainable, ensuring that waste generation is prevented and used resources are kept in the economy for as long as possible. As returnable transport packaging producers, the members of the RCTP stand ready to contribute to achieving these goals. We welcome the opportunity to provide our feedback and would like to highlight the following points included in the attached paper: • Apply consistency with existing EU policies and avoid duplication • Implement ecodesign requirements taking into account the entire life span of products • Include only relevant, feasible and non-business-protected information in the digital product passport. Please, consult the attached document for a full overview of our contribution.
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