Association «StekloSouz» of Russia. Proposal TR CU 005/2011 «On the safety of packaging» to be supplemented with mandatory requirements for disposal

Dear colleagues!

As part of the planned work on the development of technical regulation with the participation of the Association "StekloSouz" of Russia under the leadership of Deputy. Director for Standardization of the Department of Glass Containers, Standardization Expert Sergeeva L.S. Work is underway to fulfill the instructions of the Russian Ministry of Industry and Trade to amend the Plan for the Development of Technical Regulations of the Eurasian Economic Union.

Association "StekloSouz" of Russia proposes TR CU 005/2011 "On the safety of packaging" to supplement the mandatory requirements for disposal.

The Technical Regulations of the Customs Union "On the Safety of Packaging" (TR CU 005/2011) establishes requirements for packaging (closures) and related requirements for storage, transportation and disposal processes, mandatory for use and execution in the customs territory of the Customs Union, in order to protect life and health of a person, property, environment, life or health of animals, plants, as well as prevention of actions that mislead consumers of packaging (closures) regarding its purpose and safety.

In order to implement priority areas in the field of waste management and to improve technical regulation, standardization, metrological control and supervision, we consider it necessary in the Amendment to TR TS 005/2011 to provide specific requirements for the characteristics of secondary raw materials obtained from waste intended for use in production semi-finished products and / or finished packaging and identification of the components of its chemical composition, since the safety of packaging is also ensured by a set of requirements for the materials used.

We propose to include in the draft Amendments to TRTS 005/2011 for a specific understanding the following term with the appropriate definition:

- "recycled material - material that is recycled from recovered recycled material in the course of a manufacturing process and is a product or component for inclusion in a product."

Note: primary glass packaging cannot be classified as recycled material, since it is made mainly from primary raw materials and partly from secondary material - cullet, mainly in a ratio of 70: 30. One Vozdvizhensky plant made jars from one cullet.

- In order to implement the priority areas of the state policy of the Russian Federation in the field of waste management and to improve technical regulation, standardization, metrological control and supervision, we consider it necessary to include (provide) an article on “reusable and reusable packaging. In the standards for reusable packaging, provide for requirements for it in terms of sanitary-hygienic and physical-mechanical indicators (present in foreign standards).

- On the territory of the Russian Federation, provide for the creation of collection points for reusable glass packaging (containers), metal cans and packaging made of paper and cardboard (waste paper).

- Limit the release on the territory of the Russian Federation of polymer packaging and packaging made of combined materials for industrial and household products (such as packs, bags, bags, bottles, cans, packaging and labeling materials, containers, trays, tubes, cups, boxes, etc.). P.).

- On the territory of the Russian Federation, provide for the application of mandatory material labeling on packages made of polymeric and combined materials, indicating if it is completely made from recycled material.

Deputy Director for Standardization of the Department of Glass Containers of the Association "StekloSouz" of Russia

L.S. Sergeeva