Other sustainability & regulatory affairs
As the European umbrella organisation for the self-adhesive labelling sector, FINAT actively represents the common interests of its members and affiliated national associations towards decision makers at European level. FINAT participates as a stakeholder in relevant situations and provides decision makers with sufficient and reliable information about effects of new and existing legislation for our industry.
At the moment, there are a number of major issues that are of concern for FINAT:
The Packaging and Packaging Waste Directive and Circular Economy Package
One of the biggest new regulatory developments is the upcoming Circular Economy Package, which among other things, will contain targets for the recycling of municipal waste, packaging waste, landfill limits and mandatory separate collection of the main waste streams.
This package of legislative measurements is expected to greatly impact release liner recycling schemes and is therefore being followed with great interest by FINAT.
On 23 March 2010, the so-called Article 21 Committee appointed by the Commission met on this issue. The question whether Release Liners and RFID tags should be considered as Packaging or Non-Packaging was on the agenda. With the help of some leading experts from the industry, FINAT has therefore submitted a separate Position Paper explaining in more details our industry's arguments in support of the fact that Release Liners should NOT be considered as packaging. In the end, the European Commission removed release liners as an example of packaging, leaving it up to the individual Member States to decide. This decision is also up for review in the new Circular Economy Package.
The Integrated Pollution Prevention and Control Directive (IPPC) and its Best Available Techniques Reference Documents (BREF's)
The Reference document for best available techniques for surface treatment using solvents is currently under review, with self-adhesive labels one of the industry sectors potentially to be added to the new document. In light of this, FINAT is actively participating in the ESVOC BREF STS working group and is a member of the Technical Working Group involved in the review. The first draft of the document, released in October 2017, did not contain self-adhesive labels as a new chapter, and we will be involved until the final document has been agreed upon to watch for developments.
End of 2017, the EU Commission drafted an updated guidance for regulation 2016/161 concerning safety features appearing on the packaging of medicinal products. In the updated final draft document, statements were included that might have a negative impact on the use of labels for serialization of medicine packaging.
Together with national associations and Members, FINAT is now exploring ways to ensure a balanced view reflecting the technical possibilities of our technology is included.