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The European Federation of Corrugated Board Manufacturers

FEFCO

FEFCO’s mission is to promote the common interest of its members across Europe and to improve the image of the Corrugated Board industry.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

The European Federation of Corrugated Board Manufacturers (FEFCO) welcomes the opportunity to contribute to the consultation on the Circular Economy Act. The Corrugated cardboard industry operates within a mature, closed-loop system. With a recycling rate of 86.6% paper and cardboard packaging remain the most recycled packaging materials in Europe. It is collected, sorted, and reprocessed locally into new fibre products multiple times, minimising material loss and supporting regional circular economies. The use of recycled paper as a raw material optimizes resource efficiency and reduces environmental impact. On average, corrugated packaging contains 88% recycled content. Please find attached our feedback, which emphasises the importance of recognising the contribution of the corrugated cardboard sector in accelerating the EUs transition to a circular economy. We call for strengthening separate collection, improving the effectiveness and transparency of Extended Producer Responsibility (EPR) schemes, ensuring policy coherence, and fostering the EU single market and competitiveness for a sector that already combines efficiency and circularity.
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Meeting with Aurel Ciobanu-Dordea (Director Environment) and FoodDrinkEurope and

22 May 2025 · Discuss with interested stakeholders the practical aspects and challenges of ensuring compliance with Art.5(5) of the PPWR (concerning PFAS limits in food-contact packaging)

Response to Restrictions on bisphenol A (BPA) and other bisphenols in food contact materials

8 Mar 2024

The European Federation of Corrugated Board Manufacturers (FEFCO) supports and acknowledges the importance of food safety and environmental sustainability in European legislation. However, we consider that certain measures proposed in the draft regulation are leading to unnecessary costs and administrative burdens. Therefore, while endorsing the objectives of the draft regulation, we encourage a thoughtful consideration of the highlighted concerns substantiated in the attached document. The main points outlined in this position are the following: 1. Limit the monitoring scope only to materials intended to come into contact with food, not articles, unless articles are imported. 2. Limit the scope to paper and board intended for moist and fatty foodstuffs. 3. Clarify monitoring methodology to ensure comparable data 4. Identify an effective frequency of analysis. 5. Legislative overlap and added administrative burden should be avoided. BPA is not intentionally used in the manufacture of paper and board and its production systems.
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Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius)

14 Dec 2023 · Proposal for the Packaging and Packaging Waste Regulation

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič)

14 Dec 2023 · Proposal for the Packaging and Packaging Waste Regulation

Response to Waste Framework review to reduce waste and the environmental impact of waste management

21 Nov 2023

The European Federation of Corrugated Board Manufacturers (FEFCO) supports the intention of the European Commissions revision of the Waste Framework Directive (WFD) to reduce waste production. This legislative update is especially critical given the environmental, economic and societal impacts of food waste. FEFCOs key recommendations for the revision are: 1. The Waste Framework Directive should recognise the vital role of packaging in reducing food waste. 2. The waste hierarchy should be re-evaluated considering the added value of recycling alongside reuse for the prevention of waste. These recommendations are further detailed in the document attached.
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Meeting with Tom Berendsen (Member of the European Parliament) and Smurfit Westrock

5 Jul 2023 · Packaging

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

21 Apr 2023

FEFCO acknowledges the European Commissions proposal for the Packaging and Packaging Waste Regulation. We support maintain the internal market legal basis and introducing harmonised labelling requirements for packaging across EU. Additionally, FEFCO welcomes the packaging minimisation measures and proposed empty space ratio as they will help to reduce packaging waste. The industry prides itself on offering fit for purpose packaging and has worked with manufacturers to ensure that corrugated cardboard packaging is optimised to its fullest extent while still protecting products. However, FEFCO also has concerns regarding several of the proposals key measures, including the reuse targets and the market restrictions on certain packaging types. Please see attached FEFCO's feedback on the proposal's Impact Assessment, including a link to our position paper on the PPWR. The Regulation should aim to make packaging more circular in a holistic way without giving certain materials a disproportionate market advantage. Material neutrality would be better maintained if the legislation were to consider recycling and reuse as equally viable options for packaging circularity.
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Meeting with Tom Vandenkendelaere (Member of the European Parliament, Shadow rapporteur) and Plastics Recyclers Europe

12 Apr 2023 · Packaging and packaging waste

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur) and spiritsEUROPE and

2 Mar 2023 · PPWR

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Confederation of European Paper Industries and

26 Oct 2022 · Circular economy and the revision of the EU packaging rules

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

21 Oct 2022 · Circular economy and the revision of the EU packaging rules

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

5 Oct 2022 · Circular economy and packaging policy

Response to Improving access to and availability, sharing and re-use of chemical data for the purpose of chemical safety assessments

16 Aug 2022

The Packaging Inks Joint Industry Task Force (PIJITF), representing the packaging inks value chain, welcomes the European Commission’s intention to improve the availability of chemical data and exchange of information among the EU agencies. The PIJITF supports several initiatives proposed by the Commission in the Call for Evidence, including: • Use of the “open data” principle through an open platform for data on chemicals. • Removal of legal barriers for the reuse of data across the EU bodies for the assessments performed by the different agencies. In this spirit, it is crucial that that the reuse of data be balanced with intellectual property protection. • Facilitating the use of all available data at EU and national level in hazard assessment and risk assessment. These actions can help ensure proper alignment in the implementation of the Chemical Strategy for Sustainability and the upcoming review of the food contact legislation. To ensure the success of the initiative, the PIJITF recommends consideration of the following aspects: • Prioritization of actions considering proposals of cross-cutting nature, coupled with the need for alignment with other upcoming EU initiatives and between Commission services. For the PIJITF, overlapping and delayed timelines are concerning (i.e., the revision of the Food Contact Material Framework Regulation). • Available hazard data on chemicals should be assessed and, if necessary, completed for the appropriate risk assessment of food contact materials (FCMs). • Data exchange must respect the agencies' areas of competency and current responsibilities, keeping the risk assessment of substances used in food contact materials under EFSA expertise (see attached position). Additionally, we would like to inform that several PIJITF members already have guidelines on NIAS/NLS Risk Assessment which follow the EFSA framework and available data on chemicals from REACH for the evaluation of FCMs, combined with exposure considerations.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Confederation of European Paper Industries and

30 May 2022 · Meeting with Fibre Packaging Europe

Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

7 Apr 2022

The Chemical Strategy for Sustainability (CSS) envisions better coordination and distribution of tasks between EU agencies like EFSA and ECHA concerning the hazard and risk assessment of substances. This translates in the aspirational approach of ‘one-substance, one-hazard-assessment’ (OSOA) followed by a tailored risk assessment as suggested by various stakeholders of the packaging and food value chain. We believe this approach can be incorporated in the ongoing review of food contact materials and articles (FCMA) legislation. FCMA evaluations require a balanced approach that can support the implementation of the Chemical Strategy for Sustainability. One that integrates the practical implementation of ECHA hazard evaluation, and the risk assessments taken by EFSA, with its extensive experience in food safety and dietary exposure. Such an approach has the potential of greatly improving the assessment process for substances used in FCMA across Europe for the future. With the following contribution to this consultation, stakeholders of the packaging and food value chain offer a reflection on the OSAO concept and the need for tailored risk assessments for FCMA.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and APCO Worldwide and

3 Mar 2022 · EU circular economy implementation

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius), Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius) and

3 Mar 2022 · EU circular economy implementation

Response to Waste Framework review to reduce waste and the environmental impact of waste management

18 Feb 2022

FEFCO supports the ambition of the EU Green Deal and is ready to contribute to the objective of the present EU initiative to “decrease waste generation and improve separate waste collection to yield optimal recycling results”. The call for evidence aims to tackle the continued increase in total waste generated, due partly to low recycling rates and low quality recyclates. This assessment is valid overall; however, there are significant differences between product types and materials that should be considered – for paper and board, for example, the recycling rate is the highest among materials in the EU at 84.2%. Within the review of the waste framework, FEFCO’s recommendations are: • ‘Fit for purpose’ packaging should be considered as a waste prevention measure. • Separate collection of packaging should be implemented to achieve high-quality recycling. • Reuse of packaging as a possible waste prevention measure should be considered on a case-by-case basis. The review of the Waste Framework Directive should be closely aligned with the ongoing review of the Packaging and Packaging Waste Directive to ensure that a holistic approach is applied across the waste legislation and there is consistency across the requirements. Please see our detailed feedback enclosed.
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Response to Food waste reduction targets

28 Oct 2021

The European Federation of Corrugated Board Manufacturers (FEFCO) supports the objective of the present EU initiative in proposing food waste reduction targets as these will reduce the environmental impact of the EU food system and support the ambition of the EU Green Deal. Corrugated cardboard packaging has worked with the value chain for many years to provide fit for purpose packaging and prevent food waste. The main points outlined in this position are the following: • Fit-for-purpose food packaging helps to prevent food waste. • Corrugated packaging is based on a renewable source, is recyclable and is recycled in reality and is therefore sustainable. • Food waste reduction targets should be implemented along the entire food supply chain. See FEFCO's specific feedback in the attached document.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

17 Jul 2020

This is a joint feedback from several associations in the paper & board value chain: CITPA, CEPI, ACE, ECMA, EMPHA, FEFCO, PRO CARTON. The paper & board value chain supports the Commission's ambition to contribute to the circular economy through the review of the requirements for packaging and packaging waste. The review should also ensure that the proposed preventive measures will support the functioning of the internal market and free movement of packaging and packaged goods while preventing the possible negative impact on the environment. See enclosed our detailed feedback.
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Response to Chemicals strategy for sustainability

19 Jun 2020

This is a joint feedback from several associations in the packaging and printing value chain: ACE, CEPI, CITPA, EuPC, EuPIA, FEFCO, FPE, Intergraf, I&P Europe, MPE and MPMA (see attachment). The undersigned associations welcome the EU Roadmap on the Chemicals Strategy for Sustainability and support the objectives to enhance citizens and environment protection, while ensuring the functioning of the internal market, in line with the principles set by the European Green Deal. We call on the Commission to speed up the EU harmonisation of food contact materials and evaluate the possible use of the existing data- and knowledge base as part of the Chemicals Strategy for Sustainability to support this development. Risk-based harmonised EU legislation on food contact materials and articles will enhance the policy coherence in the EU and provide the necessary tools to ensure maximum level of consumers’ protection and food safety.
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Response to Farm to Fork Strategy

15 Mar 2020

Joint feedback from 9 associations in the printing and packaging sectors part of the food supply chain: FEFCO (corrugated packaging), CITPA (paper & board converters), EuPIA (printing inks), Intergraf (graphic industry), FPE (flexible packaging), IK (German association for plastic packaging and films), I&P Europe (imaging and printing), ACE (beverage cartons) and MPE (metal packaging). The undersigned associations welcome the roadmap on the Farm to Fork Strategy and support the transition to a sustainable food system which contributes to climate neutrality and the circular economy. The ambition to stimulate sustainable food production and to reduce food waste is an important step in the implementation of the UN Sustainable Development goals. In this perspective, food contact materials and articles are an essential part in the food supply chain, play a key role to ensure consumers safety and for overall sustainability of the food system: • Food packaging maintains the quality of the packaged food and is the means to providing information to consumers on content, origin, nutritional values and thus supports the EU efforts to promote sustainable consumption. • Food packaging prevents food waste and contributes to sustainability by protecting products during transit and storage and by extending the usable life of products on the shelf, as recognised by the European Parliament report on resource efficiency “Reducing food waste, improving food safety” published in 2017. The same report also stresses that “innovative and environmentally friendly solutions in areas such as the management of co- and by-products of food production, food trade, food storage, shelf-life, digital technologies, and food contact materials, can offer significant potential for food waste reduction”. • The loss or damage of food has a higher environmental impact compared to the packaging itself in terms of resources used and the emissions created. In a future where the natural resources are scarce, their efficient use and fit for purpose packaging will be essential to a sustainable food system. • A level playing field for all food contact materials is a pre-requisite for the functioning of the internal market. The free movement of goods in the single market ensures a flow of food contact materials and articles, and packaged food itself. This requires further harmonisation of the EU legislation on food contact materials and articles to reduce barriers to trade and improve the competitiveness of European companies. • All food contact materials and articles are covered by the Framework Regulation 1935/2004, which is currently under review by the European Commission. In order to reach compliance with the obligations of the Regulation and ensure consumer safety, they must be manufactured in accordance with Good Manufacturing Practices (GMP) and provide for traceability at all stages of production. Furthermore, it is good practice to exchange adequate information along the supply chain in order to enable the next actor in the chain to demonstrate compliance. In these complex value chains, many industrial sectors are involved: the producers of raw materials, ink manufacturers, adhesive manufacturers, packaging converters, printers and food business operators. Currently, EU specific measures exist only for a limited number of materials, for example on plastic, ceramics and recycled plastic. A re-thinking of the policy approach is needed with strong alignment between the Farm to Fork Strategy, the new Circular Economy Action Plan and the EU Industrial Strategy. We call on the Commission to integrate the EU harmonised approach towards food contact materials in the Farm to Fork Strategy and ensure its timely development. Risk-based harmonised EU legislation on food contact materials and articles will enhance the policy coherence in the EU and provide the necessary tools to ensure the maximum level of consumers’ protection and food safety.
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Response to A new Circular Economy Action Plan

20 Jan 2020

The European Federation of Corrugated Board Manufacturers (FEFCO) welcomes the EU initiative to increase further the circular economy activities and adopt a New Circular Economy Action Plan. Please see attached document.
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