APPLICATION OF THE DIRECTIVE
" PACKAGING AND PACKAGING WASTE "

The 94/62/EC directive, dealing with packaging and packaging waste, submits all packaging to critical requirements and sets figures for the recovery rate.

What are the critical requirements of the
94/62/EC directive?

• Prevention by reduction at source
• Reuse
• Recovery:
  50 % at the minimum and 65 % at the maximum in packaging waste weight, this includes:

* Recycling: 25 % at the minimum and 45 % at the maximum based on the weight of all the packaging materials with a minimum of 15 % for each material (plastic, glass,...).

• Limits for heavy metal contents

DIB / DIS [common industrial waste / special industrial waste]

 These two points are often the subject of questions from end users or operators since, at the present time, there is no precise definition of these two terms and yet it is that definition which determines the treatment a package has to undergo.

 According to Ademe (French agency for the environment and for energy conservation), if a package considered as DIS is entrusted to an agent performing a pretreatment, renovation and recycling activity, the package after treatment can be considered as DIB. The end user must be able to tell the company retrieving the packaging what it actually contained (nature of the product - traceability). In order to do this, the holder's principal point of contact is the supplier of the product contained within the packaging. According to this vital information, the service provider (or operator) will be able to inform the holder whether or not his system will be able to process this type of packaging. If the content would jeopardise the recycling (as does packaging which has contained pesticides, in particular) and the service provider has no suitable systems, the packaging will then be considered as DIS and destroyed in a public processing centre.

 In all circumstances, dumping on a rubbish tip and burning in the open air are strictly prohibited.

 Several criteria will be the subject of special attention, notably relating to administrative authorisation, the general condition of the site, the waste traceability forms and quality.

Modification of the RID/ADR [regulations for the carriage of hazardous goods by rail/road]

ADR, the European legislative text governing the transport of hazardous goods by road, was modified in January 1999. The new edition includes, in particular, concepts of re-use, reconditioning and reconstruction for plastic packaging. These concepts are defined in a specific manner:

Reconditioned packaging (a plastic barrel or jerrican).

a) which has been cleaned so that the materials used in its construction regain their original appearance, with the former contents having been completely eliminated together with external coatings and labels;

b) in which all of the sealing gaskets which are not an integral part of the packaging have been replaced

c) which has been inspected after cleaning and all packaging with visible damage such as splits, folds or cracks, or where the method of closing or screw threads have been damaged or where there are other major defects, has been scrapped.

 The concept of reconditioning of plastic packaging relates to packaging for which there has been an individual test, notably an airtightness test. Normally, reconditioned packaging must bear the marking RL, and it is the company carrying out the reconditioning that must apply this marking. However, it should be noted that this marking is valid above all for metal packaging and, in terms of legislation, there is nothing specified for plastic packaging.

Reconstructed packaging (a plastic barrel)

a) obtained by converting one UN type to another UN type (an H 1 to an H2, for example): or

b) having had an integral part of the structure replaced.

 The concept of reconstructed packaging relates, essentially, to metal packaging.

Re-used packaging:

 Packaging which, after examination, has been declared free from defects which might affect its ability to pass functional tests: this definition includes, in particular, packaging which has been refilled with goods which are compatible, identical or similar and which is transported within the product despatcher's distribution systems.

 The concept of re-usable packaging relates only to C' shuttle packages, that is when a packer re-uses packaging to pack the same product he must carry out tests on the packaging and these tests must correspond to the initial marking.

Return to the news