Wirtschaftsverband der deutschen Kautschukindustrie (WDK) calls upon EU legislators to revise B2B shipping rules under the Packaging and Packaging Waste Regulation, arguing that current requirements are straining SMEs in the rubber industry.
According to WDK, the ‘ever-increasing’ bureaucratic burden of labelling, documentation and monitoring requirements, mandatory conformity assessment procedures, and registration obligations for every overseas shipment is causing concern for German SMEs in the rubber sector.
“The PPWR is aimed at the consumer goods sector and is unsuitable for shipping between industrial companies (B2B),” says WDK’s managing director, Boris Engelhardt. “It’s like trying to force your foot into a shoe that’s two sizes too small: it pinches everywhere and causes more harm than good.
“It’s both fascinating and alarming that companies have to comply with all these requirements, even if they’re only shipping to another branch of their company. And even if they’re reusing packaging in an environmentally conscious way.”
As such, WDK is leading a call for policymakers to adapt the Packaging and Packaging Waste Regulation’s requirements to acknowledge the ‘unique characteristics’ of transport packaging in B2B applications.
This includes an exemption for companies with an annual B2B shipping packaging consumption of less than 10 tons, as well as an elimination of the requirement to establish authorized representatives in countries where companies already have the necessary reporting authority.
Additionally, WDK calls for documentation requirements to be removed for transport packaging between affiliated companies and branches in other EU countries, as this is already thought to be integrated into the companies’ own waste management systems in compliance with the law.
“And we demand a ‘Green Gate’ approach: A single registration and labelling should suffice for each transport package,” continues Engelhardt. “This information should be stored with the initial distributor and accessible to all parties involved. Ideally, this should be the packaging manufacturer, as the first actor in the packaging lifecycle.
“What’s most astonishing for all of us, however, is that the EU, and now also the German Federal Government, is making the packaging regulation mandatory for companies, even though they themselves haven’t yet clarified many details. The EU has already announced up to 80 further delegated acts to implement the PPWR. Legal certainty? Reducing bureaucracy? Not a chance!”
Back in June, EuroCommerce represented retailers and wholesalers in its call for EU Environmental Ministers to introduce a twelve-month grace period and further clarification around the Packaging and Packaging Waste Regulation’s legal deadlines – arguing that ’key questions remain unanswered’ and legal authorities should prioritize guidance and support over enforcement and punitive action.
Since then, the European National Registers for Packaging network has released a guidance document clarifying the legal definition of a ‘producer’ and ‘end user’ under the Packaging and Packaging Waste Regulation, including in sales and grouped packaging applications.
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