Comment on Packaging Regulation

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Animal Friends Croatia's comment in a public hearing on the Packaging and Packaging Waste Regulation, March 3, 2017.

Animal Friends Croatia commends the introduction of Article 14a requiring the mandatory charge of plastic bags in stores beginning in 2019. This is a solid measure that has proven to be effective in reducing the consumption of plastic bags in other European countries where this measure has been established. That way, consumers are encouraged to be aware that plastic bags are not free at any stage of their life cycle. They are oil and natural gas derivatives; they are unsuitable for recycling due to contamination, low weight, and the high cost of the recycling process; and they are rarely reused. Plastic bags take an indeterminate amount of time to break down in landfills and in nature. They end up in trees and waterways, endangering the lives of animals, who might get entangled or mistake plastic bags for food. During the decomposition process, they are a threat to entire ecosystems, accumulating in the seas and entering food chains.

Consumer education on plastic bag usage is extremely important. It should focus on promoting sustainable, durable, and reusable alternatives such as cloth bags, baskets, and multi-use plastic carrier bags, because every lightweight plastic bag is excessive.

We suggest that the ban on free-of-charge distribution of lightweight bags should be followed by the ban on free-of-charge distribution of very lightweight carrier bags to discourage consumers from misusing them. We believe that no bag should be free of charge, because it really is not.

To make this measure effective, we consider it necessary in Article (2) to determine the exact minimum price of a plastic bag. "Purchase price" of a bag could amount to a few lipas, which is not enough to make consumers change their habits, and would effectively undermine this regulation. We urge the Ministry to determine the minimum price for a bag worth at least 1 HRK. In addition, we suggest that part of the amount charged for bags goes to the Environmental Protection and Energy Efficiency Fund to finance environmental and sustainability projects.

To encourage consumers to invest their money in longer lasting, economical, and reusable bags—in other words, to carry their own bag from home—the cost of a lightweight disposable bag should be large enough to stimulate thinking about the real value of that bag. That cost also includes the environmental damage that a bag can cause, which will encourage consumers to choose a better solution for themselves and the environment.

We also discourage waiting for the deadline ordered by the European Commission to implement the charge. We encourage making the regulation effective as soon as possible. This will confirm Croatia’s initiative, which will introduce the charge to protect its environment, animals, and economic and tourist interests. Therefore, we suggest that the date in Article (1) be replaced with the date of December 31, 2017.

Animal Friends Croatia launched the campaign to ban the distribution of free-of-charge plastic bags with the support of Green Action and other NGOs in 2009. The campaign included a petition to ban plastic bags, which was signed by more than 27,000 citizens, which indicates a high environmental awareness of Croatian citizens on the issue of plastic bags. In addition to environmental and animal protection, this measure is necessary to comply with the EU requirements, which demand a multiple reduction in plastic bag use in Croatia. Currently, Croatia annually spends 150-170 bags per capita.

Being a tourist destination, Croatia has additional reasons to implement strict regulations: protecting its forests, coast, rivers, lakes, and sea. In conclusion, we wish to commend this regulation, but appeal to make it even more specific, and so more effective.



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