A single and specific regulation for the paper and cardboard sector


Cepi brings the voice of paper in Europe. It has been working for two years for the harmonization of the norms on papers and cardboards that are in touch with food. Clear and univocal for all countries, which might enable easier movement of paper products throughout the EU and the creation of a strong European internal market.

Creating food contact packaging that finally speaks the language of paper. This concept might easily sum up the meaning of what the paper industry is currently try to do – and achieve – in Europe in the field of food contact materials. Its aim is to reach the harmonization of the various national norms on this matter.

This topic is known to be very complex. A careful consideration of the European scenario in this field shows that it is really varied, with some materials being regulated and others not, and with a profound imbalance between the materials for which rules have been harmonized and the ones that are still waiting for harmonization to take place.

Many Member States have national norms on food contact and in the management of imports and exports one inevitably end up cumulating the standards of different countries, thereby creating accumulations of norms that make it difficult to disentangle. This leads to problems related to health safety, as well as to the difficulty in laying the right basis for a truly internal market and having a set of norms that are easy to follow and do not pose additional difficulties. It should never be forgotten that Europe makes up for one quarter of the entire world paper production, yet the lack of a harmonised system places it unfavourable competition situation. The comparison between our system with others, e.g. the US one, clearly highlights that these are larger but more harmonised systems; also China is expected to harmonize its food contact legislation. That is why Europe cannot miss the opportunity to act and communicate at the same level with these realities.

The issue also affects another topic, which is very dear to the sector, i.e. the circular economy. Paper is particularly suitable to the concept of circularity, however clear rules are need allowing for the reuse of materials from both an industrial and a health-related perspective, otherwise there is the risk of developing a system that is difficult to implement.

The only solution appears to be in harmonised norms and the work done by Cepi in recent years is meaningful at a national level. That is the reason why it is so important to continue with these initiatives at the level of the supply chain, which can be particularly useful for European authorities, as well.

Cepi’s technical manager Eugenio Cavallini tells us about what has been done so far.


The risks we run

The paper world does not want to get stuck in this comfortable state where many sectors have ended up, thereby preferring a status quo, which is not ideal but at least known. This stagnation does not bring any advantages in the long run, that is why the paper industry has decided to take actions, as it is well aware of the fact that without harmonised norms it runs the risk of facing serious problems. As Mr Cavallini well explains, «the first risk is legal uncertainty, which poses an obstacle to the rapid response by the sector in case of problems, with the twofold consequence of limiting the guarantee of consumers’ safety and jeopardising the reputation of the paper supply chain». The lack of a single and univocal set of norms for the paper sector also implies the risk of reducing its competitiveness, «as a matter of fact, paper-based packaging finds itself in an imbalanced situation compared to other food contact materials that are already harmonised». Furthermore, the lack of clear norms also «leads to possible negative impacts on recycling activities, which are extremely important for our sector. Similarly, negative effects can be registered in many other sectors, in particular on our customers of the food supply chain». Mr Cavallini finally mentions an aspect that is core to the EU, i.e. the existence and functioning of the European single market. To guarantee the single market, Europe established the principle of mutual recognition, according to which anything produced in compliance with the rules of a Member State should be mutually recognized by all other Member States. Unfortunately, we are all aware of the fact that «said principle is not properly applied».

European inconsistencies

Much has been done to solve this situation, but so far «we have used our resources first and foremost to prove that paper is not plastics, i.e. that the paper industry needs different rules than the ones conceived for the plastic sector»,which is often taken as the reference sector when it comes to drawing up the norms to be applied to food contact materials and articles. «This is a massive use of resources, which could be used in different ways».

But the situation is not easy also for other reasons. In Europe, the European Commission is the reference institution for these issues, however «the recent political situation has made the European Commission increasingly cautious when it comes to dealing with new issues and rather more inclined to maintain the status quo». Furthermore, Mr Cavallini explains that in this particular moment all decisions must be authorized at the highest levels. And this does not facilitate new approaches. Difficulties are not limited to presence of excessive red-tape. The paper sector also has to deal with another major problem, i.e. the poor communication of some NGOs often towards consumers, which negatively influences public opinion and consequently exercises strong pressures on European authorities. «This inevitably affects all those who, within the European Commission, have to work towards the development of a new approach». More than that, «the Council of Europe is working on a framework resolution on food contact materials and articles, as well as on guidelines specific for papers and cardboards, however without the involvement of companies and keeping documents classified».

Approach based on three documents

Cepi has had to find its way within this intricate framework pattern and has done so by starting from a clear prerequisite, i.e. the fact that the paper approach used so far is no longer sustainable and cannot be applied to paper and cardboard packaging. «A new point of view and a new strategy are needed. To this end, two groups dealing with the issue of food contact are active within the European association: the Food contact group, dealing with this issue on behalf of Cepi, was sided by the new Fccg, i.e. the Food contact coordination group in 2015, with the latter comprising also other groups of associations active along the supply chain, in particular in the processing sector, and carrying out a coordination activity in the preparation of the proposal on the harmonized measure».

The approach conceived by Cepi, that the association would like to submit to the European authorities, is «based on three documents». The project consists in creating a real regulation taking over the principles of Framework regulation no. 1935/2004, drawing up a guideline specific to the paper and cardboard sector and drafting a guideline on good manufacturing practices.

As Mr Cavallini explains, «the first of the three documents indicates what to do, thereby basically reproducing the contents of regulation no. 1935/04, while the second and third document state how to do it and draw inspiration also from regulation no. 2023/06 on good manufacturing practices. Dialogue with the the Directorate-General for Health and Food Safety (DG Santé) has just started, however our intention is to start from the rules already established in the framework regulation and refer to documents 2 and 3». The principles of regulation no. 1935/04 have been basically reproduced, however the intention is to communicate and highlight the actual difference between the process of papermaking and the manufacturing of other products».

This is therefore not a totally new approach, but it rather aims at a more harmonised review of European regulations in a way that takes the paper sector and its specificities more into account.

In this process, the constant relation with companies and consultation between the European Commission and the association are of fundamental importance. «The first document we are proposing is already the subject of consultations. To reach harmonization, however, one needs an open and constructive dialogue between all the parties involved, i.e. authorities, food producers and consumers. This is thus a supply chain operation, whose aim is to improve the functioning of the internal market and minimize costs and burdens for the industry in line with the current trends of management systems».