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Position paper on agricultural plastics and their exclusion from the scope of PPWR
AUTHOR : the CPA
Following the adoption of the ‘PPWR’ (Packaging and Packaging Waste Regulation) by the European legislator, the question of its application via delegated acts in particular is now on the table. The Comité de la Plasticulture et de l’Agroenvironnement (CPA)1 sets out its position and recommendations for agricultural plastics.
The purpose of this position paper is to recall the legal framework and agronomic benefits of silage and wrapping films, as well as round bale twine and netting. It also aims to maintain the definitive and unequivocal status of these agricultural supply products in future delegated acts concerning PPWR.
Indeed, during discussions to draft the PPWR, notably under the Spanish Presidency of the Council of the European Union, certain proposals sought to introduce a definition of primary production packaging such as articles designed and intended for use with unprocessed agricultural, forestry or fishery products, provided that they fulfil a packaging function. The wording of this proposed new definition led to confusion and possible interpretation that contradicted current regulations and usage. This proposed wording was not adopted at France’s request. To avoid such confusion and contradiction, it should be stated that silage and wrapping films are agricultural supply products and specifically excluded from the definitions in the PPWR delegated acts.
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