In particular, we ask the negotiators to: (1) Introduce restrictions in the cases of significant risks to human health or the environment with wording aligned with the ESPR, and (2) Introduce bans on PFAS and BPA in packaging. [...] The PPWR must enable restrictions in line with the ESPR: that is, in cases where substances hinder the re-use and recycling of packaging materials, and also in cases where there are “significant risks to human health or the environment.” We do not support language such as “appropriate” or “urgent” in this legislation because the prevention of harm should not be conditional. [...] We recommend the adoption of this formulation: (iv) as appropriate, impose restrictions on the presence or the concentration of such substances or groups of such substances, that negatively affect the re-use and recycling of materials in packaging or packaging components, or which cause significant risks to human health or the environment for reasons not relating primarily to chemical safety. [...] In the CSS, the Commission committed to concrete actions as part of the Sustainable Product Policy Initiative, including to: “minimise the presence of substances of concern in products by introducing requirements [...] on packaging, including food packaging.”3 There is not yet a proposal nor a timeline to update the FCM Regulation and the current regulatory framework does not include harmonised EU. [...] Many states within the US have also already done the same.13 Product tests carried out after Denmark’s ban showed that alternatives are available and the industry can adapt.14 Banning the substance across the EU via the PPWR would give the industry much needed clarity since the FCM regulation does not yet include any harmonised requirements for the paper and cardboard packaging where PFAS is typic.
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