In depth: Packaging associations comment on environmental performance pilots

Packaging to be addressed in EU environmental footprint projects

By Joseph James Whitworth

- Last updated on GMT

Related tags European union European commission

Packaging associations give their view on EU PEF pilot projects
Packaging associations give their view on EU PEF pilot projects
Packaging will form part of 11 food and beverage-based pilot projects starting next month to measure and communicate a products environmental performance.

The Product Environmental Footprint methodology (PEF) was developed by the European Commission to address the current proliferation of methods to calculate and communicate environmental performance.

Beer, coffee, dairy, feed, fish, meat, pasta, packed water, pet food, olive oil and wine were selected for the second wave of PEF pilots (click here to see who proposed and is involved with each category​).

The Product Environmental Footprint Category Rules (PEFCRs) from the PEF pilot phase will become the product rules used by the sector in the EU or internationally to measure performance of products based on PEF.

Packaging as part of the product

Packaging will be addressed in the different selected pilots as part of the product, according to the European Organization for packaging and Environment (EUROPEN).

It contributes to food waste prevention throughout the packaged products life cycle – preventing damage during transportation and on-pack information stopping food waste.


Considering packaging in isolation, independently from the product, would not be appropriate and meaningful, said Virginia Janssens, managing director of the organisation.

“Packaging is part of the product and responds to specific product requirements different for each product type,” ​she told

“Considering only packaging would simply lead to make wrong decisions failing to address the main environmental impacts of the product’s life cycle. This is why a holistic approach is needed instead of taking one particular element (e.g. packaging) in isolation.”

Janssens said there is a proliferation of initiatives to inform consumers and other stakeholders about various environmental characteristics of products.

“These initiatives are highly diverse in terms of scopes, assessment methods and communication tools (these include various labels, claims, product declarations etc).

“This situation has the potential to confuse or even mislead consumers and other stakeholders and to lead to unnecessary burdens for food industry operators.”

ENVIFOOD protocol

EUROPEN is one of a number of organisations which form the European Food SCP round table, set up in 2009, out of which comes The ENVIFOOD protocol.

The protocol is a voluntary initiative that is co-chaired by the food supply chain and the European Commission. It is an LCA-based methodology representing an intermediate step between ISO standards, the EC’s PEF and product-specific rules.

FEVE, the European Container Glass Federation is a founding member of the round table which aims to establish the European food chain as a contributor towards sustainable consumption and production (SCP).

Being sustainable is not just about the environment, it is a broader look at other categories within three pillars: environment, social and economic, as a firm may have low CO2 ​but other negative impacts.

Between LCA and PCR

The group told this publication that the ENVIFOOD protocol is between the wide-ranging LCA and product category rules (PCR).

Electricity savings

Fabrice Rivet, technical director at FEVE, said the pilot projects will finish towards the end of 2016. 

“LCA results are not always comparable and they are generally favourable to the organisation paying for it as there are parameters that can be adapted and adjusted to get the result you want, such as electricity mix and recycling methodologies,” ​he said.

“It is important to be part of the discussion, it can’t end in simple labelling with red, yellow, green, for good and bad. Different products have different unique selling points and there is a danger of over simplifying things.

“We believe LCA is good to drive improvement in the sector, you get a picture first and later you see if it has improved or not and you highlight hotspots to concentrate on. We recognise the efficiency of LCA but we have big big questions as LCA and PCR are not possible to compare products as it is too complex, there are too many factors to simplify.” 

Adeline Farrelly, secretary general of FEVE, said its role is to ensure coherence between pilot projects and products packed in glass.

“When people are looking at the environmental footprint of glass, they need to use the right methodologies, the right figures and understand the different unique selling points of different products,” ​she said.

“The current method is a wide LCA, the ENVIFOOD protocol is narrowing it down to drive comparability. There are a limited set of factors and it is not about saying a problem is simple when it is complex. How it works out remains to be seen if it will be an improvement.”

EAFA/FPE participation

Graham Houlder, European Aluminium Foil Association (EAFA) and Flexible Packaging Europe (FPE), sustainability director, told us that it will look to participate on the pilots at TS (Technical Secretariate) level or as a Stakeholder involving flexible and/or aluminium foil containing packaging such as beer, wine, water and coffee.

“I think what we are all interested in is how the packs end of life and use phase will be treated as packaging is likely to be regarded as an intermediate product for which the definition of the end of life/use phase is (apparently) not (yet) an option,” ​he said.

“Ultimately the PEF will hopefully make it clear how packaging is helping Europe to move closer to the goal of a Resource Efficient Circular Economy -this will be the real prize for all packaging and in particular for foil and flexible packaging."

He said the hope is for an agreed transparent and credible lifecycle assessment tool in which the added value of packaging over the full product lifecycle is clear.

“However, we need to be very careful that this desire for simplification of LCA does not compromise industry’s need for full reliable LCAs to support decision making.”​ 

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