Get set for the CEN standards

By Julian Carroll

Mention the words "CEN Packaging Standards"* to members of the packaging industry and the eyes of most people will begin to glaze over. Why? Although the standards have been talked about for years, very few people know what they are about or what their purpose is. But according to the European Organization for Packaging and the Environment (Europen), there is now more reason than ever to get to grips with the CEN standards.

The national standards organizations of 19 European countries are in the process of voting on their adoption. If all goes to plan, Europe will at last have a set of standards on the environmental aspects of packaging.

Whether you like them or not - and there are many good reasons to embrace them - every company with anything to do with packaging and packaged goods entering the European market will be affected. Although most people think of the European Union (EU) Directive on Packaging and Packaging Waste Directive as being about packaging recycling, its true environmental objective is to prevent or reduce the environmental impact of packaging. On top of that, the directive sets out the following "Essential Requirements" for packaging:

• packaging weight and volume should be minimized to the amount needed for safety and for acceptance of the packed product
  
• noxious and other hazardous constituents of packaging should have minimum impact on the environment when the packaging reaches its end of life
  
• packaging should be suitable for material recycling, energy recovery or composting, or for reuse if claimed.

Even though the directive tells us what the environmental requirements are, it does not explain how to design and specify packaging that will meet these legal obligations. The CEN standards have been put together to tell us how the industry can comply with the directive.

As the standards have no force in law, once they are adopted they must be published in the Official Journal of the European Communities. From then on, all packaging that complies with the standards will be deemed conform to the "Essential Requirements" and guaranteed free circulation throughout the EU.

The CEN standards will also fulfill the other, often forgotten, objective of the directive - harmonization within the EU. As 63% of intra-EU trade is dependent on the packaging chain, the CEN standards could have a significant - and beneficial - impact on the European economy in general.

Compliance and conformity are key words in this entire process. When EU member states started adopting the directive into national law in the mid-1990s, most of their attention was focused on establishing systems to meet recovery and recycling targets. Little attention was given to the directive's environmental quality requirements. That attention is now urgently required.

Legislation has already been adopted in the UK and France which enables authorities to inspect packaging and enforce compliance. Other EU member states are in the process of developing their own regulations. However, there is still no unambiguous European answer to the question of who should be legally obliged to provide evidence of compliance. Experience suggests though, that regardless of where the legal obligation may rest, every economic operator will have responsibility to carry out some of the actions needed to prove compliance.

Rational thinking

There are good reasons to resist the temptation to shrug off the CEN standards and consign them to the "too-hard basket". Besides avoiding the obvious risk of breaching legal obligations and the even worse possibility of products being forced from the market, the most compelling reasons are strictly commercial.

Firstly, your customers will eventually demand compliance or that you supply the data to support it. You will ask the same from your suppliers. Secondly, incorporation of the appropriate standards into production criteria will bring added value to a company's products by identifying opportunities for continuous environmental improvement.

Thirdly, it is in the interests of all packaging companies to foster widespread use of the CEN standards as tangible evidence that the industry is taking environmental questions about packaging seriously. For far too long, the industry has lacked such a defense against unfounded criticism of packaging. Use of the standards presents an opportunity to help deflate this criticism. Industry players should therefore grasp this new tool and put it to work to their advantage.

Finally, and perhaps most importantly, failure by the industry to show that the standards can work would open the door for green advocates of command and control legislation to introduce "another way" of achieving the directive's environmental objective. You can be sure it would not be pleasant. The CEN standards represent a viable and more effective alternative and the industry ignores them at its peril.

Julian Carroll is the managing director of Europen

*CEN is an acronym for the Comité Européen de Normalisation (The European Committee for Standardization)