Steel for Packaging Europe
The goal of our organisation is to present the interests of the Steel for Packaging Europe member companies, to promote steel as a packaging material and inform stakeholders of the performance and sustainable benefits of steel for packaging.
ID: 70036906501-10
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
Introduction The Circular Economy Act presents a critical opportunity to reinforce circularity through targeted legislation that supports material-efficient and truly circular systems. By complementing the Critical Raw Materials Act, the Net-Zero Industry Act, and the Clean Industrial Deal, the Circular Economy Act stands as a cornerstone of the EUs regulatory framework, helping to secure secondary raw materials within Europe, reduce import dependencies, and strengthen industrial resilience through circular resource loops. Steel for Packaging Europe (SfPE) offers the following structured position to shape a robust and actionable legislative framework. This paper can be considered an initial reflection document with the objective of helping to draft the future text of the Commission's proposal during the preparation stages. Policy Recommendations: Harmonised EPR schemes: EPR fees should be calculated in such a way that they reflect the actual material-specific net costs for collection, sorting and all other steps prior to recycling for every specific material contained in packaging waste and considering the revenue from sales of the secondary raw material. The EPR fees raised by a material should be earmarked to finance and expand further improved collection and sorting of that specific material. EPR fee structures should reflect the benefits of materials that can be recycled multiple times, through reduced fees for such materials. Enhance Separate Collection and Eliminate Landfilling: Introduce an ambitious high quality recycling definition. Increase the quantity of collection. Support landfill bans for recyclable packaging materials like steel and introduce penalties or taxes on the incineration of recyclable materials or mandatory pre-sorting requirements to ensure that recyclable materials are recovered before incineration. Avoid recycled content targets for steel packaging: Recognise inherent recyclability and high recycling performance. Ensure that high quality recycling is reflected when defining targets and incentives in the upcoming Circular Economy Act. Recognising steel as a permanent material. The upcoming Circular Economy Act should formally recognise permanent materials as distinct from those that degrade through repeated recycling. Such materials retain their intrinsic value and essential properties across multiple loops. Acknowledging this distinction will support higher recycling rates, reduce dependence on virgin resources, and encourage truly closed recycling loops by eliminating waste, minimising landfill use, and phasing out incineration along with the resource losses it entails. Scrap availability Ferrous scrap, recognized as a strategic secondary raw material, should be supplied in adequate quantity and quality to satisfy EU demand for both carbon, including high-performance steels. Its accessibility within the EU should not be contingent upon its end-of-waste status. Conclusion Steel for Packaging Europe calls for a Circular Economy Act that strengthens circular practices by aligning policy tools such as EPR, separate collection systems, and standards with the real-world performance and sustainability of materials. By embedding these priorities into future legislation, the EU can achieve its Green Deal ambitions while supporting resilient, resource-efficient value chains. The only way to increase circularity will be by setting the (still missing) targets on the high quality and multiple recycling, combined with the increased collection. On the other hand, non-recyclable packaging needs to be gradually phased out.
Read full responseMeeting with Peter Liese (Member of the European Parliament) and Mölnlycke Health Care AB
9 Jul 2025 · Austausch
Meeting with Bruno Tobback (Member of the European Parliament)
9 Jul 2025 · The Challenges of the Steel Packaging Industry in Europe
Meeting with Yannis Maniatis (Member of the European Parliament) and Syensqo
8 Jul 2025 · Introductory Meeting
Meeting with Radan Kanev (Member of the European Parliament)
8 Jul 2025 · Challenges to European packaging industry
Meeting with Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné), Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)
4 Jun 2025 · Steel and Metals Action Plan
Meeting with Christine Singer (Member of the European Parliament) and European Aluminium AISBL
18 Sept 2024 · Austausch zur neuen Legislaturperiode
Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
24 Apr 2023
APEAL, representing the steel for packaging sector, fully supports Commissions objective that all packaging on the EU market be reusable or recyclable in an economically viable way by 2030, as stipulated by the Green Deal and the Circular Economy Action Plan (CEAP) 2.0. Our sector welcomes the general approach taken by the Commission but believes that more is to be done to fully close the circular loop. Therefore, our sector has prepared a set of recommendations and amendments to improve the draft Packaging and Packaging Waste Regulation. Considering the criteria for recyclable packaging, the current Commission proposal is a step in the right direction. However, to fully close the circular loop the steel for packaging sector recommends, among others, stricter qualitative criteria to label packaging as recyclable, the introduction of explanatory text per packaging recyclability performance grade and best performing packaging to be rewarded via eco-modulation of EPR fees and by a higher recyclability performance grade. APEAL's position paper is included in attach.
Read full responseMeeting with Alex Agius Saliba (Member of the European Parliament)
18 Apr 2023 · Packaging and Packaging Waste Regulation
Meeting with Tom Vandenkendelaere (Member of the European Parliament, Shadow rapporteur for opinion)
14 Feb 2023 · steel packaging sector: general introduction, recyclability, packaging waste
Response to Waste Framework review to reduce waste and the environmental impact of waste management
21 Feb 2022
APEAL, the Association of European Producers of Steel for Packaging, unites the six producers of steel for packaging in Europe, welcomes the revision of the Waste Frame Directive and believes that this revision should (1) consider further finetuning the waste hierarchy, (2) support “real” recycling, (3) promote optimised separate collection and (4) reduce food waste.
APEAL supports a review of the waste hierarchy: APEAL believes that the waste hierarchy should be adapted to a new circular reality. In the initial legislative proposals of the EC, a 3-step hierarchy was suggested, composed of (1) prevention and reuse, (2) recycling and recovery and (3) disposal. In 2008, a 5-step hierarchy was adopted in the waste legislation (WFD 2008/98/EC), composed of (1) waste prevention, (2) reuse, (3) recycling, (4) recovery and (5) safe disposal. As for the upcoming review of the WFD, APEAL believes that within “recycling”, an additional hierarchical order could be introduced to differentiate from on the one hand permanent materials like steel that can keep their inherent properties, no matter how many times they are recycled and, on the other hand, materials that are downgraded and that can only be recycled a limited amount of times. Not all forms of recycling are equal in terms environmental and economic benefits. This approach would give incentives to the producers of packaging and promote circularity. APEAL also believe that the EU should gradually abandon the practice of disposal or landfill especially for recyclable packaging materials like steel.
APEAL supports “real” recycling: Real recycling should be promoted, not only applying the in the CID 2019/1004 introduced calculation point definition, but also aiming at high-quality recycling and ensuring only recycling processes to be considered as recycling, excluding energy recovery operations and the reprocessing into materials that are to be used as fuels or for backfilling operations. It is APEAL’s view that high-quality recycling, a concept enshrined in both the Waste Framework Directive (WFD) and the Packaging and Packaging Waste Directive (PPWD) should be defined in the upcoming review of the WFD. We believe that high-quality recycling must be based on two criteria: (1) the ability of a material to retain its inherent properties after recycling, and its ability to replace primary raw materials in future applications; (2) the existence (or the development within an acceptable timeframe) of an efficient recycling scheme.
APEAL supports optimised separate collection: Optimised separate collection should be promoted, as it is a prerequisite to guarantee high-quality recycling, ensuring that valuable materials are kept in the circular loop as long as possible. When considering co-mingled collection schemes, cross-contamination risks need to be assessed.
APEAL supports the initiative for the reduction of food waste: Food waste constitutes a significant part of the municipal waste. In the Farm to Fork Strategy, the European Commission supports the use of “innovative and sustainable packaging solutions using environmentally-friendly, re-usable and recyclable materials” and consequently acknowledges the key role of food packaging in the sustainability food systems.
Early 2022, APEAL, supporting optimised waste management, launched its second recycling book on the collection, sorting and recycling of steel for packaging, focusing on 4 best practices:
• Optimised separate collection and sorting
• Collection and sorting of steel caps, lids and closures
• How scrap standards can ensure high-quality input to recycling
• Designing for recyclability in a circular economy
Link (to copy and paste): https://www.apeal.org/news/apeal-launches-new-best-practice-recycling-report/
Read full responseResponse to Food waste reduction targets
26 Oct 2021
APEAL contribution to Inception Impact Assessment, proposal for a revision of Directive 2008/98/EC on waste – part on food waste reduction target:
In the Farm to Fork Strategy, the European Commission supports the use of “innovative and sustainable packaging solutions using environmentally-friendly, re-usable and recyclable materials”. The EU acknowledges thus the key role of food packaging in the sustainability food systems.
As ‘permanent material’, steel has the potential to be recycled over and over again without losing its inherent properties. Currently, steel for packaging is the most recycled primary packaging material in Europe with an average recycling rate of 84% across the EU, the UK, Norway and Switzerland. A ‘permanent material’ is a material whose inherent properties do not change, regardless of the number of times it goes through a recycling process. It means that once it is produced for the first time, and properly collected and sorted, guaranteeing a high-quality input to the recycling operation, it becomes the raw material for new and endless production loops. This model is circular by nature and positively contributes to the policies laid down in the New Circular Economy Action Plan.
Packaging serves multiple functions. It is designed to protect a specific product, convey product information, preserve food and make it safe and easy-to-use for consumers. Packaging materials that extend shelf-life have an important role to play to reduce food waste.
Steel offers the longest shelf life of all packaging materials, up to five years for certain applications. Cans are virtually unbreakable, reducing the risk of leaking or tearing during transportation, warehousing, as well as on retail shelves and in consumers’ homes.
Fruit and vegetables, picked at height of ripeness and usually canned within hours of harvesting, retain their nutrients throughout their shelf life. Misshapen or “ugly” food is often canned and processed minimising product loss at processing and retail. Products packed in steel can be stored for long periods without the need for fridges or freezers.
It is, therefore, our firm belief that steel packaging can provide a meaningful contribution to meet the upcoming food waste reduction targets.
Read full responseResponse to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals
1 Jun 2021
APEAL – the Association of European Producers of steel for packaging – welcome the opportunity to provide feedback on the Inception Impact Assessment on the revision of the REACH Regulation.
Please see the attached for our contribution.
Read full responseResponse to Revision of EU rules on food contact materials
29 Jan 2021
Please see attached document.
Read full responseResponse to Environmental claims based on environmental footprint methods
31 Aug 2020
APEAL welcomes the EC public consultation initiative on substantiating green claims. We support the EC establishing legal framework that provides a level playing field, limits the proliferation of methods to measure and assess environmental impacts, limits the proliferation of labels and claims related to environmental information and ensures that the environmental impact of the products placed on the EU market, incl. the imported ones, can be properly assessed. We believe that the existing 2013 Recommendations (2013/179/EU) should be updated and that establishing a voluntary EU legal framework, without a move towards one accepted method, but that could be used as a complement to existing methods, will not create to a level playing field and will not eliminate misleading claims. We support the EC establishing EU legal framework requiring companies making claims related to the impacts covered by the PEF and OEF methods to substantiate them via these methods. However only when the impact indicators are reviewed, adding indicators is evaluated and supplementary specific PEFCR’s are established, this option could create a level playing field, allowing comparing the environmental impact of similar products. However, we also believe that the methods themselves needs to be made rendered even more robust, including environmental elements that are not incorporated yet, among others taking into account EoL marine litter and multiple recycling stimulating high-quality recycling.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
24 Jul 2020
“APEAL, the Association of European Producers of Steel for Packaging, welcomes packaging waste prevention measures that take into account the wider scope of a circular and resource efficient economy, ensuring a net decrease in carbon emissions. One needs to look at design for high-quality recycling, guaranteeing high-quality input in the recycling operations. Moreover, packaging that can be recycled over and over again without loss of the intrinsic properties of the material (a so-called permanent material), such as steel packaging, allows primary raw materials to be substituted by secondary raw materials, saving carbon emissions and energy, not only just once, but multiple times. Promoting optimised separate collection, both from household packaging waste streams and industrial commercial ones, that guarantee a high-quality input into the recycling operations, will lead to increased recycling rates, enabling to increase resource efficiency. Not only reuse ensures that a material’s value is maintained, also using permanent materials does so.”
Read full responseResponse to Chemicals strategy for sustainability
19 Jun 2020
APEAL – the Association of European Producers of steel for packaging – take this opportunity to thank the European Commission for opening this public consultation and allowing all interested stakeholders to engage with the Chemicals Strategy for Sustainability.
Please find attached our contribution to this consultation.
Read full responseResponse to A new Circular Economy Action Plan
17 Jan 2020
APEAL, the Association of European Producers of Steel for Packaging, welcomes the Roadmap for the next CEAP (Circular Economy Action Plan), incl. the Farm to Fork Strategy.
In this Strategy, action will be taken on among others food waste and packaging (cf. inter alia the European Parliament Resolution 2016/2223 (INI) in which is stated under article 125: “…stresses the positive contribution of food packaging materials and solutions to the prevention of food loss and food waste along the supply chain, for example packaging that …preserves the quality and hygiene of food for longer, or that extend shelf life…”).
In APEAL’s view, the EU sustainable products policy should stimulate that packaging is designed in a way allowing packaging material to be recycled over and over again without loss of the intrinsic properties of the material.
APEAL is convinced that the EU sustainability products policy has the potential to reduce packaging waste significantly.
However, boosting the market of secondary raw materials with mandatory recycled content for packaging, isn’t applicable for packaging materials for which the scrap supply is lower than the demand.
For these materials (among others steel), stimulating the collection of the material waste is the way to further reduce the packaging waste.
The EU sustainable products policy should also stimulate optimised separate collection of waste streams guaranteeing high-quality input into recycling operations.
Furthermore, the EU sustainable products policy should allow that LCA’s (cf. Product Environmental Footprint) factor in more environmental aspects, among others marine litter and deforestation.
APEAL would also like to underline that any adjustment of the legal framework should in any case allow an optimised functioning of the internal market and a guaranteed level-playing field for all packaging and packaging materials.
Read full response