Developments in European packaging standards and UN testing

PACKAGING TECHNOLOGY AND SCIENCE VOL 5 243-254 (1992)

Developments in European Packaging Standards and UN Testing

Ben Parsons Pira International, Randalls Road, Leatherhead, Surrey KT22 7RU, UK

Take a look at the map of Europe (Figure 1): twelve European members and seven EFTA or associate members. A population of approximately 343 million; major language and cultural differ- ences, yet committed to the European Community. The Union of Crowns between Scotland and Eng- land took place in 1603 and the Act of Union of Parliament in 1707, yet still the separatist debate continues. What chance Europe? Ignoring the social issues, there can be little doubt that the politicians are going to push ahead with the current programme of legislative and economic changes. It is not so much these changes that cause concern to outsiders and members alike, but the lack of coordination and implementation of directives through- out member countries. Only in time will the situation become clear, and this is a commodity in short supply to industries competing in world-wide recession.

The European Community (EC) has identified three distinct mechanisms of ensuring attainment of environmental targets:

(i) enactment of regulatory measures; (ii) use of market forces; (iii) creation of financial instruments. Legislation will continue to form one of the main pillars of the community strategy. During the last fifteen years alone, over 200 articles of legislation have been introduced that have sought to regulate environmental management in one way or another.

It has become clear that a more subtle approach to compare environmental standards is to use market forces, e.g. the EC regulation on eco-labelling.

The Community is looking to see the first eco- labelled products on the shelves prior to the end of 1992. Labels will seek to take packaging considerations into account when evaluating a given product.

The final method of encouraging improved environmental performance is by the use of financial instruments that are envisaged to act as positive incentives and will fund demonstration projects and preventive programmes. It is not intended that funds made available through the initiative should seek to replace any other source of funding for environmentally conscious-related activities!

The twelve European member countries are Bel- gium, Denmark, France, Germany, Greece, Ire- land, Italy, Luxembourg, the Netherlands, Portugal, Spain and the United Kingdom.

The seven EFTA countries are Austria, Finland, Iceland, Leichtenstein, Norway, Sweden and Swit- zerland.

Until June 1992, Portugal held the six-monthly chair. Their main objective was to obtain agreement to the 5th Environmental Action Programme with the objective of increasing the membership before the end of June, when the United Kingdom took the chair, to be followed by Denmark in January 1993.

Within Europe there would appear to be two types of packaging legislation: that backed by law as in Germany and Switzerland and then the understanding between Government and Industry, which is often backed by the implied threat that if agreed targets are not reached they will be enforced by law. Whichever the legislation and rules, the aim

Received August 1992 0894-3214/92/050243 12 $11.00 $31992 by John Wiley & Sons, Ltd.

244 6. PARSONS

&32q$.3

Figure 1. Map of Europe showing twelve European members and seven EFTA members

is to reduce the amount of packaging used and materials should be reused or recycled. The EC legislature, for instance, aims to recover 90% of used packaging and 60% must be reused or recycled.

The demand to recycle puts pressure on other packaging-food packaging in the UK accounts for 60% of the packaging produced, resulting in non-food outlets taking more than their fair share of recycled materials, and often non-packaging users must be found. This will not be easy. This aim to reduce packaging and to recycle and reuse tends to ignore the function of packaging, which is to protect and preserve the product and to convey the sales message as well as all the legally required

information on contents, country of origin, manufacturer and how to use the product. Packag- ing has already to fit a demanding bill within tight cost considerations. Designers and test houses are likely to be among the beneficiaries of these developments. In the UK we are already helping customers meet the German demands, in both design and test house functions.

Exporters to Germany since December 1991 have to take back transport packaging for recycling or arrange for its collection and recycling by a third party. The Appendix gives a list of addresses that include Resy and Duales, the Green Point system (Griine Punkt). All these systems are likely to involve costs, and agreement on the Resy system

EUROPEAN PACKAGING STANDARDS 245

should be sought with customers. Companies participating in the Duales system will have to pay between 12 and 20 Pfennigs per item, depending on the size of the container.

Important environmental legislation affecting packaging has been enacted in Germany, applying

The important features of this ordinance are related to:

Transit packaging, 1 December, 199 1 ; secondary packaging, 1 April, 1992; sales packaging, 1 Janu- ary, 1993.

both to German-produced products and imports. Germany is a major industrial nation with the third

of the most environment-sensitive countries in Eur-

It bans the sale of all packaging that cannot be

and recycling is given a very high priority. highest ranking economy in the world. It is also one reused, Or incinerated for

ope, with a powerful environmental lobby. It is therefore natural that Germany is a leading country in advancing legislative and other means to protect the environment.

About 32 million tonnes of household and industrial waste has to be disposed of each year in the old Federal Republic of Germany alone. Landfill capacities available for only a further 2-5 years, after which period there will be neither adequate waste incineration nor dumping capacity available.

Packaging forms a major portion of German household waste and has high visibility; the packaging industry’s reaction to the waste disposal crisis is regarded as too slow. It is therefore not surprising that a German environment minister was the first to announce one of the most radical pieces of legislation affecting packaging waste. This legislation could be considered a landmark in the history of environmental law affecting waste, since some of the major EC countries and the EC Com- mission itself have shown sympathy with it and may well adopt its basic tenets. The German environment minister believes that the enacted measures will help in avoiding litigation between Germany and the EC concerning harmonization, since the ordinance will not discriminate between materials but only between packaging that is refillable and that which is not.

This German legislation is thus crucial to the understanding of future trends in legislation related to packaging waste in Europe, and is therefore discussed in some detail.

THE GERMAN PACKAGING WASTE ORDINANCE

This ordinance (with the exception of the sections on the ‘duty to take back waste packaging’ and on ‘charging deposits’) came into force on 1 December, 1990. The sections on ‘duty to take back’ etc. came into force between 1 July, 1991 and 1 January, 1992.

It obliges the distributor/retailer to remove the transit or transport packaging, such as paperboard outer boxes, plastic foam granules or film and other transit packaging, before offering the product for sale, or else provide a receptacle so that purchasers can remove this material in the store rather than take it home.

It obliges the retailer to take the goods out of their secondary packaging, such as blister packs or film wrappers, at the point of sale, or else provide a receptacle so that purchasers can leave this material in the store.

It obliges the filler, distributor or retailer to set up adequate collection facilities for used packaging either at the store or within the sales catchment area.

It imposes a mandatory deposit of 50 Pf on all non- refillable beverage containers and on plastic containers for laundry cleaners and household cleaning products, with the exception of refill packs.

It imposes a mandatory deposit of DM 2 on containers for paints, solvents, pesticides, oils and other hazardous household products.

The responsibility for the collection and re-cycling of all packaging waste associated with the goods now lies for the first time with the filler/distributor/ retailer, and must be carried out outside the public waste disposal system.

There are labelling requirements associated with the ordinance, according to which it is mandatory to declare on the pack the material it is made from and the return system applicable. In addition, it will be mandatory to post signs in the stores to make consumers aware of their right to remove the packaging from their purchases before taking them home.

246 B. PARSONS

All the above conditions are not required if a separate, consumer-friendly system for collecting the packaging is established by the filler, distributor or retailer.

The ordinance exempts the used packaging from hospitals, doctors’ practices, blood banks, laboratories and similar institutions, which must use separate waste management systems.

Definitions of packaging

According to the ordinance, the three categories of packaging mentioned above are defined as follows:

(0

(ii)

(iiij

Transportation or transit packagings-pallets, cardboard packaging, plastic foam dishes, shrink films and similar wrappers that serve mainly to protect goods from damage on the way from manufacturer to distributor and are, as a rule, removed by the distributor before the goods are sold to the final consumer. Outer or secondary packaging-blister packs, films, cardboard collation packaging and similar wrappers intended to make the sale of goods through self-service easier, to reduce the possibility of theft or for advertising purposes. Sales or consumer packaging-sealed or open packages and wrappers, such as beakers, packets, blister packs, buckets, barrels, bottles, cans, paper and cardboard packaging, boxes, sacks, dishes, carrier bags or similar wrappers, which are used by the final consumer for transportation and/or are needed until the goods are used or consumed.

Beverage packaging

Packs for beverages are defined as packets, cans, bottles, cartons and tubes made from all types of material, with a capacity of 0.2-3 litres and which cannot be refilled.

Carbonated and still soft drinks for refreshment;

Beverage categories include:

Fruit juices, fruit nectars and vegetable juices;

Liquid milk products and other drinks derived from milk;

Fruit juices and fruit nectars mixed with milk or whey;

Natural mineral water, spring water, table water, bottled drinking water and spa water;

Beer, including alcohol-free beer;

Wine, vermouth, other drinks made from fresh grapes and those given wine aroma using other plants or materials and sparkling wines;

Drinks made from non-denatured pure alcohol with a defined alcohol content and compounded alcoholic preparations used for the manufacture of drinks.

Duty to take back

The legislation obliges distributors to take back all forms of packaging after use and to reuse it for the purpose, or to put it into a collection system that will either recycle or derive energy from it. Thus, the distributors are obliged to take the packaging waste out of the public waste management system.

Duty to charge a deposit

All waste packaging that cannot be reused or refilled is subject to a mandatory deposit. In the case of drinks, detergents and household cleaning products, however, there is an exemption if there is a separate, privately organized system that guaran- tees a weekly collection of the waste packaging. For hazardous household products, however, there is no exemption and the deposit is also mandatory.

Deposit on beverage containers

According to the ordinance, it is the duty of the fillers and distributors who sell drinks to final consumers to charge a deposit of 50 Pf for every package that cannot be refilled. This deposit is to be charged by every distributor in the chain. The deposit must be reimbursed each time an empty package is returned.

EUROPEAN PACKAGING STANDARDS

Deposit on detergent and household cleaner packaging

As for beverage packaging, it is the duty of the fillers and distributors who sell detergents and cleansing agents for household use to charge a deposit of 50 Pf for every pack of capacity greater than 0.5 litre, with the exception of flexible packaging used for refills.

Deposit on packaging for hazardous household products

For the products listed below, categorized as hazardous household products packaged in pressurized gas bottles, buckets, bottles, barrels or canisters made from glass, metal or plastic, that are not refilled, the distributors must charge a deposit of DM 2 per pack to the final consumers:

Colourants and painting agents, containing solvents or heavy metals, with a capacity of 0.5 litre upwards;

Solvents, either halogen-free or containing halo- gens;

Acids and dyes;

Laboratory and fine chemicals;

Photochemicals ;

Wood preservatives with a pack capacity of 0.5 litre or more;

Plant sprays;

Disinfectants and pesticides;

Combustion engine oils and gear box oils, lubricat- ing oils and hydraulic oils, with a capacity of 3.5 litres upwards;

Adhesives and sealing agents with a capacity of 0.5 litres or more.

Reimbursement of deposits

In the case of packaging for beverages, detergents and household cleaners, the deposit (50 Pf/pack)

247

must be reimbursed each time an empty package is taken back. The duty to reimburse the deposit in the case of hazardous goods for household use is restricted to product packages from those manufacturers whose products are stocked by the distributor concerned.

DUAL SYSTEM DEUTSCHLAND

The German decree on packaging waste allows for and anticipates consumer-friendly collection systems being set up by industry, since this is seen as a more manageable alternative than having packaging waste collection handled by retail distribution net works.

An umbrella corporation called ‘Dual System Deutschland’ has been set up by German industry to finance and manage packaging waste collection and recycling. It is backed by a large number of individual companies from various branches of industry concerned, including retailers, fillers and packaging manufacturers, with other sectors expected to follow. Within this system, the German plastics industry, for example, has started a venture called Kunststojiierpackungs-Verwertungsgessells- chafi (KVG), which is open to all polymer manufacturers and convertors. The following are the main elements of the system set up by the Dual System Deutschland corporation:

(9

(ii)

(iii)

All packages designed to be collected through the system will be awarded a ‘Green Point’ label (see below). For each package bearing this label, the Corporation receives between 1 and 5 Pf. All households in Germany are provided with green bins, free of charge, in which to put the discarded packages bearing the label. The bins are emptied at regular intervals, again free of charge. Collected waste packaging is sorted into material categories by the Corporation and sorted materials are recovered and made available, free of charge, for recycling.

Green Point label

According to the system, the corporation will li- cense participating companies to use the ‘Green Point’ label for their packaging, for a correspond- ing fee of 1 to 5 Pf per item. Without the label, the

248 B. PARSONS

packaging will not be handled by this privately run collection system and will, therefore, be subjected to the deposit mandate. A similar system (‘Red Dot’) is proposed, but not established as yet, that would accomplish the collection of packaging con- taminated by its contents.

RECYCLING TARGETS

In order to ensure that such systems will help realize the objective of reduced packaging wastes, the German authorities have set down stringent requirements and targets.

IMPACT ON IMPORTED PACKAGING

The decree discriminates in favour of reusable/ refillable packaging and against one-way packages. As mentioned earlier, packaging imported into Germany will be subject to exactly the same laws that apply to locally produced packaging. The impact of the decree on imported packaging is expected to be the same as on that produced locally.

Most of the imported packaging, be it from other European countries or from other developing countries, would, except in some special cases, be of the one-use type, and hence subject to the deposit mandate, unless it can be collected through the

‘Dual’ system. To be eligible, the imported packaging (including paper/cardboard) will have to be recyclable or suitable for incineration to recover its energy content, and must bear the ‘Green Dot’ label. This will have to be obtained by the importer, who will need agreements with the manufacturers of similar packaging or the suppliers of similar materials in the country in order to guarantee that it can be reutilized and is acceptable within the system.

PACKAGING STANDARDS

The UK aim is to achieve our own domestic recycling targets within a European approach, but in such a way that does not impose unnecessary financial or environmental penalties on industry or the customer. It is very easy to be distracted by the environmental issues and to ignore the more funda- mental standards and legislative items that attract less attention and yet in the not too distant future could be on the European Statute Book.

The major packaging standard being developed with the CEN Committee (European Committee for Standardization-Comiti: Europeen de Nor- malisation) in Europe is TC261. Let us take a look at this Committee. The following working groups within subcommittees SC1 and SC3 are selected for closer scrutiny, while broadly detailing the work of other Committees (Tables 1-3).

Table 1. CEN/TC261 Packaging scopes of the various subcommittees (SC1-SC4)

SC1 : PACKAGING GENERALITIES SC1 studies general items whatever the materials, shapes or contents and whatever the distribution systems and transportation chains adopted. SC1 coordinates and prepares the relevant standards.

SC2 establishes standards for primary packaging, which is defined as all packages in direct contact with the product. All aspects of these are to be studied whatever the materials, shapes or contents and whatever the distribution system and transportation chain concerned.

SC3 covers the preparation of standards for distribution packaging, transport packaging and unit loads, including accessories. SC3 deals with al l aspects, including dimensions, test methods and performance requirements, but excludes work items that are the agreed responsibility of SC1, SC2 and SC4.

SC4 covers al l environment-related aspects of packaging and will, among other things, deal with the following aspects: materials recovery, energy recovery, other types of recovery, degradability, symbology, terminology and the determination of environmental impact criteria.

SC2: PRIMARY PACKAGING

SC3: DISTRIBUTION PACKAGtNG, TRANSPORT PACKAGING AND UNIT LOADS

SC4: PACKAGING AND THE ENVIRONMENT


CEN/TC261 /SC1 /WG4-Test methods and test schedules

The majority of tests studied in this working group are going through or have gone through a procedure that adopts the appropriate I S 0 standards (Table 4). Table 5 gives the EN standards; the target dates for their completion are largely June 1993, except Vibration in December 1993.

On the subject of vibration, the two IS0 standards 2247 and 83 18 were tabled for acceptance; two members tabled motions for revision work. One delegate comes from an organization testing for aerospace and science applications with Vibration tables up to 10 m long, and is the main proposer for revision. It is essential that working

Table 2. CEN/TC261 /SC1 working groups (WGS)

WGl : Terminology (terms and definitions) WG2: Marking WG3: Dimensions coordination WG4: Test methods and test schedules WG5: Range of capacities

groups recognize the needs of the packaging world and that the standards remain pertinent to the mainstream operation, i.e. dedicated to packaging operations.

With regard to EN 22233-Conditioning of testing ( I S 0 2233), after much debate delegates agreed to divide the table of Article 2233 into two tables: one with standard conditions; the other with op- tional environments, which will appear as a non- integral part of the standard.

Here it was felt that I S 0 20/65 is close enough to 23/50, and a proposal to eliminate 20/65 from the European Standard has been put forward. Condi- tion requirements are currently under discussion.

CEN/TC261 /SC3/WG&Distri bution packaging, transport packaging and unit loads

The key priorities of this working group were to adopt

I S 0 445 I S 0 6780

(Basic terms and definitions) (Principal dimensions and tolerances)

Table 3. CEN/TC261/SCl packaging scopes of the SCI working groups (WGI-WG5)

SC1: PACKAGING GENERALITIES Sub Committee 1 studies general items whatever the materials, shapes or contents and whatever the distribution systems and transportation chains adopted. SC1 coordinates and prepares the relevant standards.

WG1 is responsible for the elaboration of a standard that lists and defines the principal terms used in packaging. This WG1 is responsible for coordination, evaluating and checking any terminology proposed by other sub-committees and working groups within TC261 in order to ensure coherency between the different WGs.

WG1 : Terminology (terms and definitions)

WG2: Marking The work of WG2 is restricted to marking concerned with all aspects of the handling package. This working group is responsible inter aha for the implementation of I S 0 780 as a European standard.

WG3 is responsible for the standard on dimensions coordination in the field of packaging up to unit loads inter alia by the implementation of IS0 3394 and I S 0 3676.

WG4 coordinates and prepares the range of basic test methods in the field of TC261. This working group may prepare additional test methods upon request from SC2, SC3 or SC4.

WG5 will prepare standardization activities when required by EC authorities.

WG3: Dimensions coordination

WG4: Test methods and test schedules

WG5: Range of capacities

250 B. PARSONS

Table 4. CEN/TCZ61 /SC1 /WG4 test methods and test schedules

Work item title Object and field of application Stage target date edition

Retaking of I S 0 standards to EN standards by PO procedure

IS0 2206 Identification of parts I S 0 2233 Conditioning for testing I S 0 2234 Stacking test (static load) I S 0 2244 Horizontal impact test IS0 2248 Vertical impact test dropping I S 0 2272 Compression test I S 0 2873 Low-pressure test IS0 2874 Stacking test (compression tester) IS0 2875 Water spray test I S 0 2876 Rolling test I S 0 8768 Toppling test

I S 0 8474 Water immersion test IS0 41 80 1 and 2: general rules for performance test schedule IS0 2247 Vibration test (low frequency) IS0 2528 Water vapour transmission test I S 0 831 8 Vibration test (variable frequency) IS0 41 78 Distribution trials, information to be recorded

Retaking of I S 0 standards to PO procedure

12/92

12/92

Table 5.

Work item title Object and field of application Stage target first working

document ~~ ~~

Revision of future EN standards EN 22233 Conditioning for testing EN 22234 Stacking test (static load) EN 22244 Horizontal impact test EN 22873 Low-pressure test EN 22874 Stacking test (compression tester) EN 22875 Water spray test

EN 2247 Vibration (low frequency) EN 2831 8 Vibration (variable sinusoidal frequency)

Revision of future EN standards

06/93 06/93 06/93 06/93 06/93 06/93

12/93 12/93

I S 0 86 1 1 :ed.2 I S 0 TR 10233 (Performance requirements).

The key pallet sizes are likely to be: 1200 x 800, 1200 x 1000 and 1140 x 1140 mm.

There has, however, developed an industrial- based initiative within Germany. The three major German Chemical Companies and ICI have decided to go it alone, and with the pallet manufacturers they have set up a Chemical Industry pallet scheme (the VCI Scheme): the pallet manufacturers will collect pallets free of charge, provided that the

(Test methods) industry is prepared to buy back the refurbished pallets at the new price.

The VCI pallet sizes are 760 x 1 140 800 x 1200

1000 x 1200 1100 x 1300 1140 x 1140 mm.

Pallet size 760 x 1140 mm is the least used pallet, the main four pallets running from 800 to 1140 mm.


It should be pointed out that the Chemical Indus- try scheme meets the requirement of the Ordinance.

The draft work programme is given in Table 6. Quality has in recent years been high on the

European Agenda and in June 1989 the following testing laboratory standards came into existence:

EN 45 001 General criteria for the operation of testing laboratories

EN 45 002 General criteria for the assessment of testing laboratories

EN 45 003 General criteria for laboratory accreditation bodies

EN 45 01 1 General criteria for certification bodies operating product certification

EN 45 012 General criteria for certification bodies operating quality system certification

EN 45 01 3 General criteria for certification bodies operating certification of personnel

EN 45 014 General criteria for suppliers’ declara- tion of conformity

The standards follow very much ISO/IEC guides, in particular 2 and 25. The criteria are those to which laboratories should conform and which should be used by accreditation bodies in accredit- ing laboratories. All member countries are bound to implement this European standard. Any quality- conscious laboratory is unlikely to ignore these standards. To those addressing the European market place they are essential reading, not forgetting that many of the standard tests carried out by Pira and other European test houses are NSTA or ASTMS-based.

UNITED NATIONS TESTING

The railways of Europe invented the first international regulations for the carriage of dangerous goods in the late 19th Century; they are still in existence today and form the basis of European road regulations. These original railway regula-

Table 6. Draft work programme for SC3/WG4

Title Description of project ( IS0 or EN base document)

Target date Priority 1(32) ratinga

Pallet terminology Basic terms and definitions in the field of pallets, pallet superstructures, pallets with super structure and rolltainers (newly drafted I S 0 445) Principal dimensions and tolerances ( IS0 6780) Principal dimensions and tolerances Principal dimensions and tolerances Principal dimensions and tolerances

Flat pallets, Part 1

Pallet super-structures, Part 1 Pallets with superstructure, Part 1 Rolltainers, Part 1 Flat pallets, part 2

Flat pallets, Part 3 Flat pallets, Part 4

Flat pallets, Part x

Pallets, Part y

Design rating and maximum working load ( I S 0 TR 10232) Test methods ( IS0 861 1 :ed. 2) Performance requirements ( IS0 TR 10233) Constructional specification for 1200 x 800 mm wooden pallet Supporting component tests and classification (CEN/TC175 (pallet wood), EN409 (Nail tests), etc.)

Pallet superstructures, pallets with superstructure & rolltainers, Parts 2, 3 and 4 for each

Design rating and maximum working load, Test methods and Performance requirements, respectively, for each category

al = immediate start; 2 = commencement after items rated 1 are under way; 3 = start date.

03/93

03/93

12/95 12/95 03/95 12/95

12/93 06/94

12/95

12/95

12/95

1

1

1 1

2

2

3

252 B. PARSONS

tions stipulated, amongst other things, the type of packaging to be used in a very rigid format some- what like the detailed specifications that existed in 49 CRF (Code of Federal Regulations).

Today in Europe the railway regulations, like other modes of transport, are based on the Recom- mendations of the United Nations Committee of Experts on the Transport of Dangerous Goods- the Orange Book.

The Orange Book first published a set of recommendations on packaging of dangerous goods in 1970 and it was shortly after this that Pira was asked by the UK drum and chemical industry to look at these recommendations. At this time there were no proposals to make these mandatory.

Pakforsk in Sweden also looked at the procedures around this time.

By the mid-1970s Pira had issued the first UK certificates for UN-certified packages but it was clear that the UN test procedures as originally written were ambiguous. The UK government at the end of the 1970s decided to promote a rewrite of these original provisions to eliminate many of the problems without getting away from the basic philosophy, that of design type testing.

Most regulations up to the 1970s that specified packaging set down rigid material and dimensional criteria, e.g. a steel drum had to be made from 1 mm thick steel. There was no room for new initiatives without resorting to laborious bureaucratic procedures. The UN packaging system in essence says: design a package that will pass the performance tests and you can carry dangerous goods in it, thus leaving room for innovation.

Today the majority of European countries have the UN test regime as a national (domestic) requirement in addition to being a party to the various international conventions. The UK along with France and Ireland do not use the UN test regime as a domestic requirement, although both UK and France are committed to a changeover during the next 2 to 3 years. Within the United Kingdom, UN-tested packages are not prohibited; they are deemed to meet our legal requirements.

Although the UN recommendations publish a text for the testing of packages for the transport of dangerous goods, this has no force of law until it is adopted by one of the conventions covering the transport of dangerous goods. Those conventions are :

The International Regulations concerning the Car- riage of Dangerous Goods by Rail-RID.

The International Maritime Dangerous Goods Code-IMDG.

The Technical Instructions for the Safe Transport of Dangerous Goods by Air-ICAO Technical Instruction.

The European Agreement Concerning the Interna- tional Carriage of Dangerous Goods by Road- ADR.

The first three are not exclusive to Europe. Today it is the general philosophy of the modal

regulators to adopt the UN recommendations where it is safe and practical. However, this is a philosophy of the recent past and whilst it is broadly fair to say that the sea and air regulations follow the UN closely, RID and ADR have only begun the process seriously in the last decade and they hope to complete most of the work in time for the 1995 editions of the regulations.

Packaging provisions from the UN are all repro- duced in each of the modal regulations and they follow the UN Recommendations-although, because of the various legal processes, sea, road and rail are not up to date with the current text of the UN. However, there does appear to be a willingness to try and get all the texts aligned by 1995.

Neither the UN nor the modal agencies stipulate how testing is to be carried out or how the package marks are to be allocated. This is left to Competent Authorities. The term ‘Competent Authority’ often causes problems; generally it is a Ministry (of Transport) in each country but this is not absolu- te-it is up to each Government to decide what the term means.

Normally the Competent Authority establishes the rules for package testing. Most of the European countries have centralized certification-unlike the US system-where one or two bodies in a country issue the packaging mark. Testing, on the other hand, is sometimes centralized at the same organization that issues certificates, e.g. France, the Neth- erlands, Sweden and Switzerland, whilst other countries, the UK and Germany in particular, have several test laboratories that submit test reports to a centralized certification body. In the UK we have 20 test laboratories that must submit test reports to Pira-Pira itself is a test laboratory, so it has a dual function. Pira checks each report and if it is sat- isfied an authorization is issued.

Pira is often queried by US industry as to whether European Competent authorities will ac-


cept the US system of self-certification. Legally, we in Europe must accept this system because the UN has chosen not to define a mandatory regime. But what of the practical problems; in general, although we have been queried once or twice about the validity of marks, we have heard of no real difficul- ties.

The checks and balances that the US government have on the certification scheme can put many European countries to shame. The system of administrative penalties that the RSPA (Research and Special Programs Administration) of DOT (Department of Transportation) can impose is far more effective than the laborious system through the courts. The message must be spread in Europe and the rest of the World how the US system is enforced; if it is not, the self-certification system could die for all the wrong reasons.

Let us turn to the UN provisions themselves: do we in Europe see problems in the UN system and how is it likely to change? The system is undergo- ing a review in Geneva now and the US government and organizations like HMAC (Hazard Material Advisory Council) and NABADA-The Association of Container Reconditioners-are all making a contribution to these changes, which should be complete by the year end. There will then be a gap before we see any more reviews.

The UN provisions do not stipulate precise testing or reporting procedures and countries have been left to interpret the regulations themselves. Although the European certification and testing organizations meet regularly, the meetings are on an informal basis and because of the relationship these organizations have with their governments it is difficult to establish fully standardized test procedures.

Pressure is being exerted from industry because a growing belief exists that one country can be more liberal in its testing than another and there is a need for more standardization. There have been informal requests for the UN to adopt full testing protocols but the UN Committee already have much work in the dangerous goods field. It is likely that CEN or the EC will try to develop these for Europe. It would seem appropriate that the USA monitors such work because, if successful, it could be commended to the UN as a supplement to the Orange Book of the future.

The LJK is considering a proposal to the UN to establish the minimum contents of a test report/ certificate. This may alleviate some of the problems with testing and would help government and the

packaging and chemical industries. Such a report requirement exists in the RID/ADR regulations.

APPENDIX

Useful addresses

German Glass Industry Assoc. Stresemannsrasse 26,4000 Dusseldorf 1. Tel. 02 11/ 16 89 40; Fax 02 l l / l 68 94 27.

German Assoc. for Paper Raw Materials Bismarckstrasse 12, 5000 Koln 1. Tel. 02 21/51 20 26; Fax 01 21/52 92 20.

German Corrugated Industry Assoc. Hilperstrasse 22,6100 Darmstadt. Tel. 0 61 51/8 20 91 2.

Assos. of the German Food Industry Hauptstrasse 305, 5000 Koln 90. Tel. 0 22 03/8 10 75; Fax 022 03/8 10 78.

German Aluminium Packaging Recycling Co. (DAVR) Haus der Metalle, Tersteegenstrasse 28, 4000 Dus- seldorf 30. Tel. 02 11/45 47 10 (Temporarily at Georg von Boaselager-Strasse 25,5300 Bonn 1. Tel. 02 28/5 52-22 03 or 2106; Fax 02 28/5 52 22 68.

Duales System Deutschland Rochus Strasse 2-6,5300 Bonn 1. Tel. 02 28/979 20.

British Standards Institution 3 York Street, Manchester M2 2AT. Tel. 061 832 3731, Fax 061 835 2895.

AFNOR Tour Europe, Cedex 7, F-92080 Paris La Defence, France. Tel. 33(1) 42 91 55 55; Fax 33(1) 42 91 56 56.

Industry Assoc. for Liquid Food Cartons (FKN) Sohnleinstrasse 17,6200 Wiesbaden. Tel. 05 11/2 90 21 ; Fax 26 03 72.

Tinplate Information Centre (IZW) Kasermenstrasse 36,4000 Dusseldorf 1. Tel. 02 11/8 01 86; Fax 02 11/32 62 17.

Interseroh AG Postfach 90 06 40, Industriestrasse 11, 5000 Koln 90. Tel. 0 22 03/170 40; Fax 0 22 03/170 417.

German Branded Products Assoc. Postfach 41 49, Schone Aussicht 59, 6200 Wiesba- den. Tel. 06 11/52 20 71; Fax 06 11/52 85 29.

254 B. PARSONS

Resy Materials Recycling Assoc. (Vfw) Hilpertstrasse 22,6100 Darmstadt. Tel. 061 51/8 20 91; Fax 061 51/89 15 20.

Organization for the Reprocessing of Used Plastics Packaging Community Fellnerstrasse 5, 6000 Frankfirt 1. Tel. 0 69/55 08 19; Fax 0 66/59 57 12.

PO Box 190329, Bismarckstrasse 12, 5000 Kohn. Tel. 0221/51 22 52/511797; Fax 0221/529220.

Official Office of Publications for the European

2 rue Mercier, L-2985, Luxembourg.

Documents

Developments in European packaging standards and UN testing