بروز رسانی اطلاعات و قوانین در مرداد ماه سال ۱۳۹۸
گزارش استاندارد ها و قوانین اتحادیه اروپا در صنعت بسته بندی :
EU PACKAGING DIRECTIVE
Legislation and Standards
The Directive on Packaging and Packaging Refuse (94/62/EF) is a harmonization of goals for recycling of packaging waste as well as certain requirements for packagings. In Article 9 and Annex II of the Directive the essential requirements for packaging being marketed in the EU are given. These requirements are made in order to reduce the quantity and environmental strain from packaging and packaging refuse. You can find the Directive on: http://europa.eu.int/eur-lex. The Packaging Directive from 1994 was revised in Directive 2004/12/EF of 11 February 2004.
The EU Packaging Directive gives very general requirements to the companies concerning minimization of packaging as well as recycling efforts. The Directive demands that the entire packaging – individual components as well as the entire packaging – only contains max. 100 ppm. heavy metals (article 11 in the Directive). The Directive has an exception for glass packaging regarding the heavy metal requirements. The EU Packaging Directive primarily requests the countries to provide systems for recycling and use of packaging refuse. Specific goals to be met by a certain deadline is described. These goals were intensified in the 2004 revision with new goals which have to be met before the end of 2008.
Annex II of the Directive states a number of general requirements for the packaging, which the companies have to meet. Annex II of the Directive is depicted in Encl. B of this guide.
The 2004 revision elaborates the Directive definition of packaging. It is advisable to be aware of a number of borderline cases as to what is defined as packaging, because these rules are not always conceived as being very logical. The rules apply for example to plastic bags, paper plates and plastic cups, while plastic cutlery and tea bags are not included. On the other hand the mascara brush is part of the packaging, because it is fixed to the lid of the packaging. Crystal glass (e.g. perfume bottles) is not included in the Directive.
Standards are important, as they often support the overall requirements of EU directives. The use of European standards are optional, but if a company uses these harmonized standards it is assumed that they meet the essential directive requirements. This way these standards have become an integrated part of the inner market, and an important tool when wanting free access to the entire EU market. The standards can be purchased through the national standardization organisations.
Basically it is the Directory and the national legislation which has to be observed, but in practice the companies are advised to use the matching standards, because then the rules are presumably met. The companies can choose whether to use EN13427-32 or Annex II of the Directive.
This European standard states the overall requirements and methods to be observed by the person or organisation , who is responsible for marketing packaging or packaged products.
This European standard deals with minimizing the packaging but only adds marginally to the requirements found in Annex II of the Directive.
This standards states the requirements for packaging applying to be classified as re-usable. This guide will not go further into the matter of re-usable packaging. Only when marketing the packaging as re-usable EN13429 is needed.
This standard states the requirements to be met when the packaging is mentioned to be suitable for recycling. See further details in EN 13430.
This standard states the requirements to be met in order for the packaging to be suitable for combustion with energy recovery. See further details in EN 13431.
This standard states requirements and methods for determining the possibility for packaging and packaging material to be compostible and biodegradable. See further details in EN 13432.
This is a European, technical report published by the European standardization organisation CEN. It is not a standard but a technical report documenting how you may (not must) measure/calculate whether the packaging only contains max. 100 ppm heavy metals (= lead, cadmium, mercury and hexavalent chrome). The requirement is given in the Packaging Directive. See further details in CR 13695-1.
This CEN report describes how to measure, calculate and document the packagings contents of environmentally hazardous components. The document does not include the list of nature hazardous materials, which can be found in another directive, 67/548/EF. See further details in CR 13695-2.
The use of standards
The EU Packaging Directive requires the following of a company:
۱٫ Minimize the packaging system so that the packaging just fulfils its purpose – protection, display, information, distribution adaptation etc.
۲٫ Make sure that each packaging component contains no more than 100 ppm. heavy metal.
۳٫ Minimize the use of environmentally hazardous components according to EU Directive 67/548.
۴٫ Meet special demands if the packaging is to be re-used for the same purpose.
۵٫ Make sure that the packaging meets at least one of the following demands:
a. Recoverable to other materials
b. Combustible with energy recovery
c. Compostible – or – biodegradable
Ad) 1. The logical approach would be for the company who brings a packaging or a packaged product to the market to deal with these requirements. This means that all sorts of companies will be performing this task – big or small. It is possible to use the Annex II of the Packaging Directive as well as EN13428. The contents are identical. Our experience during this project has been that the companies need more concrete suggestions for the practical work. Therefore this guide in Chapter 6 has been a good tool for the companies.
Ad) 2. For most companies it will be impossible to obtain the information needed. The necessary data will typically be with the subcontractor or maybe even sub subcontractors and they will normally be very unwilling to provide other than an accordance declaration. See Encl. C. It is recommended, that it is the packaging supplier who uses CR 13695-1.
Ad) 3. The same applies here. For most companies it will be impossible to obtain the necessary information from the subcontractors, so an accordance declaration is in practice the only way. See Encl. C. It is recommended, that it is the packaging supplier who uses CR 13695-2.
Ad) 4. Most companies do not use re-usable packaging, so they don’t have to meet this requirement. In this case EN 13429 should be used.
Ad) 5. The three ways to recycle the packaging requires use of the standards EN 13430-13432. Like mentioned previously it is not realistic to expect the company buying packaging for their products to take on the responsibility. These companies should be able to obtain an accordance declaration from their packaging suppliers. The packaging suppliers should work out these declarations according to the standards. One should be aware that all three recycling methods are not available in all markets.
فرآیند ارائه اسناد و مدارک :
The responsible (that is the one marketing the packaging or the packaged product in EU) has to render that this evaluation has taken place by written or otherwise imperishable documentation. Different EU countries have different rules as to how long this documentation should be kept. Often the limit is 5 years. It is recommended that you keep the documentation five years after the last lot has left the company. The documentation has to be written or otherwise imperishable.
Industrial and Management Systems
صنعت و مدیریت سیستم ها :
To be able to show that a package is designed in accordance with the essential requirements of the Packaging and Packaging Waste Directive, it is necessary to have the following:
§ Working methods for the assessment in accordance with the essential requirements;
§ Documentation of the assessment.
It is not necessary to evaluate how the company obtains higher efficiency over time. However, the standards presume working methods that lead to continual improvements.
When developing the standards, a condition was that the necessary new working methods would be easy to implement in an existing management system, e.g. ISO 9000, ISO 14001, HACCP or BRC. For this reason, we recommend a company with a running management system to merge these systems together. In practise, a new packaging evaluation system can be introduced by implementing additions to an existing quality manual.
A standard design of management systems is:
The strategic level will typically contain:
§ Policies and goals
§ Responsibility and authority
§ System design
In normal situations, the strategic level does not contain much about packaging. The responsibility for the Packaging Directive can be placed on the strategic level.
The tactical level describes business procedures. The assessment procedures for the Directive can be contained in a special procedure or in several existing procedures. For example, suppose that a company already has a procedure for purchasing. To this procedure the company must add a checklist for the specific requirements for the Directive.
The operative level contains instructions to all-important operations in the company. The instruction from OPTI-PACK that the company may want to use will be on this level, see chapter 5.
۱٫ The first step is to get familiar with the rules. The typical reaction is frustration with these “complicated” rules.
Most companies develop packaging according to “good practice traditions”. Intuitively you use previous experience when developing a new packaging. This causes great frustration when you are presented with the demand for written documentation for a number of factors mentioned in the EU Packaging Directive. Immediately you envisage more employees and extended costs.
۲٫ After becoming familiar with the rules you review what you have already done. Normally you have already made some kind of optimization process. You collect this information and obtain written documentation. At this point most companies begin to have a more clear vision of the task.
Once the companies engage in the work, they discover that a financial optimization has already been made. Rather quickly most companies discover that most of the documentation either already can be found in the company or with subcontractors, or that the documentation has been quickly sketched out on a piece of paper and not kept.
۳٫ Then you have to evaluate the existing documentation. Is anything missing? Is the quality of the documentation sufficient for any given public authority in any EU country? Normally this leaves you highly confused. You realize that the rules do not always give a complete answer. Especially the requirements regarding the quality of the minimization process are not very specific.
When the company evaluates their documentation possibilities it is important to be aware of the fact that the authorities require written documentation. That alone makes it obvious that some arguments are not efficient. A typical sales department argument will be: ”If the packaging isn’t a lot larger than the product, we will not be able to sell it.” This argument will not satisfy the authorities. But a letter from a customer – e.g. a supermarket chain – stating that they demand a certain cardboard thickness in order to sell the product will. So save the letter for documentation purposes.
۴٫ At this stage you will be ready for the daily work of a continuous optimization of all existing and future packaging systems. The reaction is typically positive because of the benefits of fewer damages, less packaging and especially reduced transport volume.
Almost all companies realize once they get this far in the process, that their initial frustration was unjustified. Actually the process has paid up. The surprising thing is, that the company can even profit when putting products through the process which you thought were fully optimized because they have been produced in large quantities for years. Often these products surprisingly enough provide the largest profit for the company.
۳: The Work Process
مراحل کار :
The EU Packaging Directive states the requirements for minimization of nature hazardous materials, if they are present in the packaging. The EU Packaging Directive states a limit of max. 100 ppm. for heavy metals. Glass packaging is excepted from this rule.
To most companies this will be a difficult task because they use materials from other companies. These companies have so far been very reluctant to disclose such chemical information. Some might suggest that the company send the packaging to a chemical analysis, but you have to be aware that not all chemicals may be possible to detect, and in all cases it would be very a costly affair.
The only practical solution is to require data from your suppliers. This is not an easy task for a company with little or no chemical knowledge.
We therefore recommend that the packaging responsible requires an accordance declaration for each packaging component (Encl. C). In this declaration the supplier testifies by signature that the following requirements are met:
· The packagings content of nature hazardous materials has been minimized – or even better: the packaging contains none of these components
· The packaging (except glass packaging) contains less than 100 ppm. heavy metals.
If any of these components are present in the packaging, the supplier can either provide documentation or refer to the authority control in their own company.
Optimazation of Package
بهینه سازی بسته بندی :
The following methods can be used:
· Damage analysis. For instance by documented maximum allowed complaint percentage from the market regarding the packaged goods.
· Test transports
· Functional tests
· Scientific calculation and testing.
One way to optimize your packaging is to bring a packaging system into the market and record what happens in practice. In this case you record which damages occur.
· If the complaint percentage is below the stipulated maximum, the packaging can be reduced further.
· If the complaint percentage exceeds the stipulated maximum, the packaging needs improvement.
The documentation can be reports from the internal meetings where material consumption is adjusted in either direction. A special challenge is to stipulate an acceptable complaint percentage. This is an essential strategic key figure which the company can use as a directing tool, but it can also include a number of customer deals.
Another way is to send newly developed packaging on a test transport in order to test the quality. This method contains the following:
· The company defines the wanted test transport (= the most difficult distribution route).
· ۲-۵ packaging systems as close to the most optimal solution as possible are developed.
· ۲-۵ prototypes are sent on the test transport route.
· By receipt you record the state of all test packagings according to predetermined, critical criteria.
· If the maximum limit is exceeded, the packaging is improved. In the case of no damages you evaluate whether to reduce the packaging.
· Through specifications, photos and reports from the test transports you are then able to document that the packaging just meets the predetermined, critical criteria. This way you can document in an overall report that the packaging has been optimized.
The principle in a functional test is, that you stipulate and record which impacts you will protect the product from. By testing for instance drop height, shock, stacking pressure, temperature, humidity etc. you determine whether the packaging is proof against these impacts. You develop 2-5 packaging systems as close to the optimal solution as possible and test all these systems. If some hold and others don’t the closest solution will be in the critical area.
Scientific calculation and testing
The scientifically correct method is based on the packaging designer’s 6 commandments:
۱٫ Measurement of distribution impact
۲٫ Measurement of product durability
۳٫ Evaluation whether the distribution can be improved
۴٫ Evaluation whether the product can be improved
۵٫ Construction according to engineering principles
۶٫ Test whether the new packaging system is working
This apparently simple work plan includes large quantities of scientific theory, which cannot be described on the limited space available in this guide. For further information please refer to the literature list in the final section of this guide.
Producing the packaging
ارائه بسته بندی :
The following methods can be used:
· Same methods as mentioned for the packaging/filling processes (section 6.3)
· Standard goods from packaging producers
Standard goods from packaging producers
Sometimes the situation is that you cannot obtain a more optimal packaging than the standard goods from the packaging producer. If for example 1 kg of flour has to be packaged in a paper
bag the decision process will actually be to choose between standard goods as for instance 150 g, 170 g, 190 g or 210 g paper. The packaging producer does not provide any paper thickness other than these standard goods. Let us assume that a test has shown that 150 g and 170 g paper is not sufficient, while 190 g and 210 g are acceptable solutions. The standard requirement is to use paper quality that lies in the critical area. Theoretically that could be 179 g paper. This could be produced but it would not be appropriate. In this case we recommend that the packaging producer provides a report stating how a special kind of paper would cause substantial waste by change-over as well as procurement. Such a report could cover the entire supplier assortment and be provided on demand. Please note that the argumentation should not be financial but include technical, efficiency and resource arguments.
Packing and filling
بسته بندی :
The following methods can be used:
· Packaging machine specification
· Practical tests
The evaluation will often be done using the companies specific, oldest or most rough packaging machines. Therefore you have to remember to check whether the packaging can be reduced further, when this machine is replaced.
Analysis of package machine specifications
By comparing packaging machine specifications with the packaging it is possible to document that the packaging cannot be reduced further.
· Are the packaging machine specifications in accordance with the packaging specifications?
· Documentation, e.g. report, video, photo.
Another way of documentation is to perform practical tests on the critical packaging machines. The process could be this:
· Buy reduced packaging
· Test on packaging machine
· Evaluate the results – photo or video
· Keep reducing until the critical point is reached (the packaging line stops)
· Choose the previous packaging
· Documentation e.g. report, video, photo.
Customer and user acceptance incl.
presentation and marketing
شرایط پذیرفته شده از طرف مشتریان و استفاده کنندگان که
شامل عرضه و بازاریابی می شود :
The following methods can be used:
· Product identity and branding
· Historical market data
· Specific customer requirements
· Focus groups
· Interviews and analyses
These are only examples. Other methods can be used as well. When using this kind of argumentation you have to provide some kind of documentation (e.g. a report, video, photo).
Product identity and branding
The packaging creates product associations and branding. An example of branding is the Coca Cola bottle. A number of initiatives e.g. company logo print and the like are below the limit for documentation requirements.
Historical market data
Historical market data can be used to document that the packaging cannot be reduced further, if you want to maintain a certain trade. By showing a decline in profits you can render the need for the original packaging volume. A test sale of various packaging designs can also be used to document the optimal packaging solution.
Specific customer requirements
A customer like for instance a supermarket chain can require a thinner packaging material in order to send the proper signal to their customers. In this case the customer clearly defines, what the minimum packaging should be in relation to sale and marketing. It is important to have this requirement in writing.
A focus group is a certain kind of interview, where a group of people are gathered to discuss a certain subject. See www.opti-pack.org Toolbox.
Interviews and analysis methods
The idea is to stop and question relevant customers in a store or a mall. You start with a number of general questions in order to ensure that the person is within the target group and in order to ensure a representative mix in the target group. Only then the person is interviewed.
The packagings still have to meet all rules and regulations. A lot of people think that e.g. a UN-approved packaging for dangerous goods is automatically approved concerning the EU Packaging Directive. This is not the case. Whoever fills the dangerous goods into the packaging is still obliged to render that he is not able to use less packaging if he has to meet the UN requirements. Since there are not a lot of approved packagings on the market, and since these goods are not transported in large quantities, you have to document that the given UN-approved packaging is the smallest available in the market.
 When transporting dangerous goods internationally, it is required that they are contained in a packaging which is approved and meets certain functional requirements stipulated by the UN. This means that the packaging has to be UN-labelled.
فلزات سنگین :
The supplier is requested to either by measurement and/or by calculation and/or information and data to investigate whether there are heavy metals (lead, cadmium, mercury and hexavalent chrome) in the packaging component.
If any heavy metal is present in the packaging component the supplier has to investigate whether the total contents of heavy metals are within the limit of 100 ppm.
We refer to the method described in CR 13695-1:2000 paragraph 8, which can be obtained from the national standardization organisations.
It can be very difficult to obtain this information for the many companies that buy a number of different packaging components and put them together in a coherent packaging system to match a certain product. These companies have to receive documentation from their suppliers – maybe
more than one step back in the supply chain. In this case an efficient tool will be accordance declarations where a known supplier vouches for the packaging component and possibly a control authority declares that the rules are being kept.
مواد خطرناک :
You have to determine whether any of the packaging parts contain one or more environmentally hazardous components classified by the symbol ”N” in Annex I in the EU Directive 67/548/EF (incl. later amendments), and whether the component has been added to the packaging in order to fulfil a certain function. Only in this case you need CR 13695-2.
This documentation is probably best obtained by the packaging producer and his material suppliers. EU Directives can be obtained via http://europa.eu.int/eur-lex/da. (CEN Report) CR13695:1 can be obtained for the national standardization organisations.
Information on environmentally hazardous materials can be found on homepage www.mst.dk/kemi/02040000.htm or on www.kemi.se. On www.di.dk there is a link to a PC program, which can be used as an inspiration when producing documentation relating to CR 13695-1 and -2.
As mentioned for heavy metals it is also very difficult in this case for a lot of companies to obtain the relevant data, when they by a number of different packaging components and put them together in a coherent packaging system designed to match a certain product. These companies have to receive documentation from their suppliers – maybe more than one step back in the supply chain. In this case an efficient tool will be accordance declarations where a known supplier vouches for the packaging component and possibly a control authority declares that the rules are being kept .