A further 12 per cent have internal procedures to demonstrate compliance. Of the remaining companies that have no procedure in place yet, all but one are currently based outside the EU in Accession States where compliance is not yet required.
What this means, according to Europen, is that even without pan-European enforcement (only France and the UK currently act to ensure compliance), companies in the packaging chain are actively seeking to meet the essential requirements. While not exhaustive, the survey covered packaging manufacturers and users across a wide range of sectors and countries and, in Europen's opinion, is a fair representation of the activities of larger companies in this area.
The survey carried out for Europen tallies with another, commissioned by the UK Department of Trade and Industry, which found that the majority of UK companies surveyed were using the CEN standard or procedures based on it, particularly in assessing whether new packaging met the essential requirements.
These survey results lend weight to Europen's argument that further obligations on companies in the packaging chain, such as the use of packaging environment indicators proposed by MEP Dorette Corbey last year, should not be considered until there is consistent enforcement of those that are currently in place across EU Member States, and a proper evaluation can be made of their effectiveness.
Europen, the European Organisation for Packaging and the Environment, has made the results of its survey available to the European Commission's environment directorate general. The organisation is also sending it to officials in the EU Member States and is developing examples of best practice based on the experience of Europen members in complying with the directive.