Document QYoYOo23647kmYJGz5ZwDYLL

Ahead of Thursday's WPE meeting scheduled to discuss the PPWR proposal, Metal Packaging Europe (MPE), the European association representing rigid metal packaging (steel and aluminium), would like to bring to your attention some targeted recommendations based on the questions transmitted by the Belgian Presidency for this meeting. For your convenience, our recommendations follow the same order as the structure of the discussions proposed in the Presidency's steering note. Article 5 - Requirements for substances in packaging - Row 244a - Article 5 (2a) There is currently a REACH Restriction under development following a proposal by several Member States, with one of these proposals seeking to evaluate the need for this group of substances in food contact applications: see here. PTFEs which are PFAS according to the REACH definition and which can be used in food contact materials will be regulated as part of this Restriction as well as in the forthcoming review of the Food Contact Regulation, (EC) No 1935/2004 following proper evaluation. MPE supports the Council's general approach on this point and considers that mixing up pieces of legislation goes against the spirit of the European Commission's better regulation guidelines. - Row 233b - Article 5 (2b) Bisphenol A is regulated by several pieces of legislation, including REACH and Commission Regulation (EU) 2018/213 of 12 February 2018 on the use of Bisphenol A in varnishes and coatings intended to come into contact with food and amending Regulation (EU) No 10/2011 as regards the use of that substance in plastic food contact materials, currently being reviewed by DG SANTE. This revision will address the requirements of the EU Chemicals Strategy for Sustainability (CSS) for so-called "chemicals of concern". MPE is against the EP amendment as any necessary ban on BPA in food packaging should be introduced through this revision in an appropriate and effective process.