A little over a month after the European Regulation on Packaging and Packaging Waste (PPWR) took effect, the first challenges are emerging in the French self-adhesive label industry. According to the National Union of Adhesive Label Manufacturers (UNFEA), manufacturers are facing issues similar to those already reported by the packaging industry in Germany: a surge in compliance requests, customer questionnaires, and difficulties in determining who is responsible for issuing the EU declaration of conformity.
"Given the differences in skills, knowledge, and approaches, this so-called PPWR is viewed differently by all stakeholders: clients, label manufacturers, and suppliers." , explains Pierre Forcade, executive director of the UNFEA. This situation leads to "delays in its implementation and mistakes made, against a backdrop of stress and pressure from clients on manufacturers."
Compliance requests are on the rise
Since August 12, UNFEA has noted, in particular, an increase in compliance requests and questionnaires sent by clients to their label suppliers.
To meet these demands, label manufacturers in turn reach out to their own suppliers to obtain information about the various components used: inks, adhesives, and other materials.
The main sticking point, however, concerns the division of responsibilities. "Everyone is passing the buck when it comes to preparing a statement of compliance." , notes Pierre Forcade.
The professional organization thus notes that "a lack of understanding of everyone's role" and a lack of procedures among some manufacturers for collecting documents from their suppliers and then forwarding them to their customers for each order.
Eco-design, recycled materials, deposit-return systems: rules that are still not fully understood
Other aspects of the PPWR also remain poorly addressed. The UNFEA specifically cites eco-design requirements, the use of recycled materials, and issues related to adhesives compatible with glass deposit-return systems.
Conversely, the situation seems clearer regarding the possible presence of PFAS. According to UNFEA, suppliers are well prepared, and manufacturers can obtain the relevant documentation relatively easily.
Resources on the PPWR centralized by UNFEA
In response to various questions, the UNFEA launched a section dedicated to the PPWR on its members-only website in July, alongside information regarding the extended producer responsibility (EPR) for commercial packaging. The National Union of Adhesive Label Manufacturers now plans to contact its members individually to identify the challenges they are facing.
For issues related to food contact, it relies on the French Committee for Paper and Cardboard Packaging (COFEPAC), and for issues related to food contact at the European level, on the MCAS Club and FINAT. Some suppliers, such as Avery Dennison, also organize webinars to support companies.
According to Pierre Forcade, the situation should gradually become clearer: "We'll see an increase in the implementation of the PPWR and a better understanding of who does what in the coming months." However, UNFEA intends to remain vigilant to prevent regulatory uncertainties from fueling tensions between manufacturers and clients.
