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Customer Requests: CEPI recommends use of harmonised disclaimers for voluntary declarations in the European pulp and paper industry
Companies are experiencing, in their daily customer contacts, requests for various declarations, frequently related to non-relevant topics and often totally misplaced. Answering such requests can cause misunderstandings with customers.
In order to help companies give responsible and harmonised answers to their customers CEPI recommends a set of standard disclaimers (see annex), to be routinely used depending on the type of request and on the individual discretion of each company. These disclaimers are recommended to be used routinely when signing declarations in reply to those requests, by inserting them in the declaration document. Using the same disclaimers across the pulp and paper industry will reduce the pressure of making unsubstantiated declarations and reduce reputation risks as well as the risk of possible financial claims for individual companies and the sector as a whole.
i. These disclaimers are not intended to be used when such declarations of compliance are mandatory (required by law). These shall be prepared and issued mandatorily, following the forms and ways of releasing them as the legislation requires.
ii. These disclaimers are intended to be used for voluntary declarations regarding statements attesting to the compliance with specific legislation or with qualitative and technical adaptations to non-binding technical standards. For such requests for voluntary declarations, three standard disclaimers are recommended by CEPI:
a. Issuing a declaration on the absence of certain substances
b. Refusing a declaration of compliance with non-relevant legislation
c. Issuing a declaration of compliance with non-relevant legislation
For more information, please contact Jori Ringman, at email@example.com, telephone n°: +32 47825 50 70
CEPI aisbl - The Confederation of European Paper Industries
The Confederation of European Paper Industries (CEPI) is a Brussels-based non-profit organisation regrouping the European pulp and paper industry and championing industry’s achievements and the benefits of its products. Through its 18 member countries (17 European Union members plus Norway) CEPI represents some 520 pulp, paper and board producing companies across Europe, ranging from small and medium sized companies to multi-nationals, and 950 paper mills. Together they represent 24% of world production.
Website: http://www.cepi.org/ firstname.lastname@example.org
Annex : Disclaimers
1. Requests that may be relevant to our sector, but which are made in a form that is neither in line with legislation nor with scientific common sense. The most frequent case to be considered is a request to declare the “absence” of certain chemicals, whilst the applicable legislation sets a specific limit or no limits are set at all. The voluntary release of such declarations should be accompanied by the following disclaimer:
With reference to the present declaration, ‘absence’ means that the final product may contain substances that were in the incoming raw materials as traces or impurities and were not intentionally added during the pulp and papermaking process.
2. Requests related to declarations that are totally irrelevant to our sector1.
In case the company decides not to release any declarations, the following disclaimer should be used:
The declaration that has been requested cannot be released, as it concerns2 [(for example) the restrictions on the content of the chemicals listed in the Directive 2002/95/EC, the so called ‘RoHS directive’, on the use of hazardous substances in electrical and electronic equipment.]
This legislation is not applicable to pulp and paper products.
3. In case the company nevertheless decides to voluntarily release a declaration where the request is related to legislation or standards that are not relevant to pulp and paper, the voluntary release of such declarations should be accompanied by the following disclaimer:
Where the present declaration refers to legislation or a standard in which this product is not included in the scope, ‘compliance’ means a declaration of intent by the manufacturer, whereas there are no legal means to formally comply due to the limitations set by the scope of the referred legislation or standard. ‘Absence’ means the final product may contain substances that were in incoming raw materials as traces or impurities and were not intentionally added during the pulp and papermaking process.
* * *
1A typical example is the declaration on the compliance with the restrictions on the chemicals listed in Directive 2002/95/EC (RoHS Directive) regarding the use of hazardous substances in electrical and electronic equipment. Naturally, such declarations are mandatory in special cases where the product is used for electronic applications.
2Insert the reference and scope of the legislation or standard relevant to the request.
The disclaimer has been translated into Spanish by our member Aspapel. Read it here
CEPI is the coordinating association of the EU co-funded project “Fibre+: Innovative Paper Packaging Products for European SMEs Based on Functional Modification of Recovered Fibres”.
The coordinator of the project is Dr. Eugenio Cavallini, CEPI Technical Manager, and the Scientific Coordinator is Prof. Stergios Adamopoulos from the Technical University of Larissa. The project will create innovative processes modifying recovered fibres for new functional packaging products, reducing the need of the sector for virgin fibre and supporting the competitiveness of the SMEs in the EU packaging sector.
With this project the consortium is set to create a new generation of packaging through the improvement of physical and chemical properties of recycled papers that are more recyclable, less hygroscopic, stiff and durable, in particular those used for corrugated packaging. Research will focus on potential treatments for fibre improvement, exploring new possibilities for both, cost reduction (energy and raw material efficiency) and quality increase in packaging design.The project will proceed with the selection of the best modification treatments that will be validated on a pilot plant and then implemented on industrial scale, during the demonstration phase. Training the staff of all the participants and disseminating the results to interested corrugated packaging SMEs will be the final stage.
Fibre+ started 1st December 2012 and will last until the end of November 2015.
It is run by a consortium of 10 partner organisations: 2 associations (CEPI and FEFCO - Belgium), 5 research organizations/institutes ( the Technical University of Larissa – Greece, the Georg-August University of Goetting – Germany, the Complutense University of Madrid – Spain, Innventia – Sweden, the Polish Packaging Research and Development Centre, COBRO – Poland) and 3 companies (Rapina Paper Mill – Estonia, Pargianas Nikolaos & Co. Chemicals – Greece and DSSmith Packaging Italia – Italy). During the evaluation phase it has become evident that the REA (EC’s Research Executive Agency) experts appreciate this project very much, as they gave it a high score, marking it as a highly valuable project.
All Fibre+ consortium partners are actively engaged in the project and are set to do their best to achieve the goals that have been set for Firbre+.
For more information, contact Eugenio Cavallini at email@example.com
An amendment to Annex I of the Packaging and Packaging Waste Directive on packaging definitions has been published in the Official Journal of the European Union.
The amendment harmonises the list of products being defined as “packaging”, which now includes rolls, tubes and cylinders. The amendment also lists exceptions, which are valid for industrial cores used in the paper industry.
The relevant paragraph for industrial cores in the Annex reads:
“Rolls, tubes and cylinders around which flexible material (e.g. plastic film, aluminium, paper) is wound, except rolls, tubes and cylinders intended as parts of production machinery and not used to present a product as a sales unit”
Industrial cores fall under the list of exceptions since they are:
- “intended as parts of production machinery” in the downstream printing and converting machines, where a defected core would lead to rejection of the whole roll of paper as it would not run in the machine as intended.
- “an integral part of a product and it is necessary to contain, support and preserve that product throughout its lifetime and all elements (paper and the core) are intended to be used together” as referred to in Article 3, criterion i of the Directive
- reused many times.
- not “used to present a product as a sales unit” as paper is sold “per tonne” and not “per core”. Examples of products where “tubes and cylinders” are used as sales units and therefore are clearly packaging are potato crisps (Pringles), tennis balls and badminton shuttlecocks sold inside a sealed tube.
Hence, the Confederation of the European Paper Industries (CEPI) concludes that industrial cores are not packaging. CEPI will inform its national associations and relevant industry sectors on its view and advocate the transposition and implementation of the Directive to adopt the same interpretation.
The Commission Directive of 7 February 2013 amending Annex I to Directive 94/62/EC on Packaging and Packaging Waste enters into force 1 March 2013. Member States have to comply with this Directive by 30 September 2013 at the latest.
Jori Ringman-Beck, CEPI Director Recycling, Product, Environment; +32 478 255 070, firstname.lastname@example.org
Commission Directive of 7 February 2013 amending Annex I to Directive 94/62/EC of the European Parliament and of the Council on Packaging and Packaging Waste:
Other EU language versions: http://eur-lex.europa.eu/Result.do?checktexts=checkbox&TypeAffichage=sort_key&page=1&idReq=1&Submit22=GO
CEPI aisbl - The Confederation of European Paper Industries
The Confederation of European Paper Industries (CEPI) is a Brussels-based non-profit organisation regrouping the European pulp and paper industry and championing industry’s achievements and the benefits of its products. Through its 18 member countries (17 European Union members plus Norway) CEPI represents some 520 pulp, paper and board producing companies across Europe, ranging from small and medium sized companies to multi-nationals, and 1000 paper mills. Together they represent 25% of world production.