New Packaging Directive Annex confirms: industrial cores are not packaging

Feb 14, 2013

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.


Additional information:

Jori Ringman-Beck, CEPI Director Recycling, Product, Environment; +32 478 255 070,

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:


About CEPI

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.