Circular Economy Package: Joint cross-industry packaging value chain recommendations

Packaging plays a positive role in a Circular Economy by optimising resource use, minimising product waste and protecting products all along value chains. Packaging is cross-sectoral and, in order to perform its functions, the full lifecycle of the packaging, intrinsically connected with the product it contains and value chain must be considered in its entirety.

Future legislative measures must take account of the multitude of packaged products and complexity and particularities of their (material and sector) value chains. This holistic approach is reflected in the Packaging and Packaging Waste Directive (PPWD), which integrates both product and waste measures, covering all packaging materials, packaging types and packaging systems in a non-discriminatory manner.  Along with the Internal Market as its sole legal base, the PPWD should remain lex specialis and is different in scope from pure EU waste stream directives.

Our industries support a long-term strategy and an enabling EU policy framework that facilitates sustainable resource use from a full lifecycle perspective, incentivises economies of scale and takes into account value chains at all levels with each of their different needs, supply and demand realities.

To further enable our industries to transition towards a resource-efficient and competitive Circular Economy, the related legislative proposal should:

1.    Safeguard the free movement of packaging and packaged goods in the EU Internal Market, thereby providing businesses with the security to invest and roll-out innovations on a large scale. The role of the PPWD in safeguarding against protectionist measures, market distortions and fragmentation must be maintained.

2.    Ensure full implementation and enforcement of existing EU laws, particularly the Waste Framework Directive and PPWD;

3.    Strengthen the legal framework for Extended Producer Responsibility (EPR) for used packaging:

      - Introduce a clear definition of EPR in the PPWD. EPR means the producer’s full or partial financial and/or operational responsibility for a product, extended to the post-consumer state of a product’s life cycle, as a means for Member States to meet EU recycling and recovery targets.

      - Stipulate binding EU minimum performance requirements for EPR schemes to enable (a) more transparency in types of packaging material collected, material flows, cost, tendering procedures, geographic scope, (b) more accountability delivered by monitoring, reporting, audits, financial solidity and nationally defined roles and responsibilities for all actors involved in packaging waste management and (c) better enforcement by requiring Member States to implement and enforce authorisation procedures for all EPR schemes;

      - Provide EU guidance to Member States that use EPR, on the roles and responsibilities of each and all actors involved in packaging waste management (i.e. producers, private and public waste management operators, consumers, local, regional and national authorities and EPR schemes);

     - Retain flexibility for Member States in implementing EPR in a way that reflects national, regional and local realities, in line with the subsidiarity principle and without hindering the free circulation of packaging and packaged goods.

4.    Establish a solid, comparable and harmonised calculation method for measuring and reporting national packaging recycling rates that is feasible to implement for all packaging materials i.e. based on the input into a final recycling process after sorting operations have been completed. 

5.    Set realistic and achievable packaging recycling targets, after setting a clear starting point to ensure that changes would bring real economic and environmental benefits. Assess the impact of a new and harmonised methodology and definitions on existing targets, and ensure that potential new targets take into account new starting points, different packaging waste management infrastructure, different packaging waste generation and implementation capacities of the 28 Member States;
6.    Promote the diversion of packaging materials from landfill in favour of recycling and/or energy recovery.

The undersigned organisations are prepared to work constructively with the EU Institutions to help ensure that, in line with the Better Regulation agenda, the Circular Economy package is evidence-based and delivers tangible and sustainable benefits for European citizens, businesses and society as a whole.

Signed by the following industry organisations (in alphabetical order):

* ACE - The Alliance for Beverage Cartons and the Environment, AIM - European Brands Association, A.I.S.E.- The International Association for Soaps, Detergents and Maintenance Products, ARA - Altstoff Recycling Austria AG Packaging Compliance Scheme, Austria, Cosmetics Europe, DSD - Der Grüne Punkt Dual System for Packaging Recycling, Germany, EAA – European Aluminium, Eco-Emballages – Packaging Recovery Organisation, France, EDANA - The International Association Serving the Nonwovens and Related Industries, Elipso - French Plastic and Flexible Packaging Association, EPRO - European Association of Plastics Recycling and Recovery Organisations, European Bioplastics e.V., EUROPEN - The European Organization for Packaging and the Environment, EXPRA - Extended Producer Responsibility Alliance aisbl, FEA – European Aerosol Federation, FEVE – the European Container Glass Federation, FPE – Flexible Packaging Europe, IK Industrievereinigung Kunststoffverpackungen e.V., INCPEN – The Industry Council for Research on Packaging and the Environment, INTERGRAF - European Federation for Print and Digital Communication, MPE - Metal Packaging Europe, Pack2Go Europe – Europe’s Convenience Food Packaging Association, PlasticsEurope - Association of Plastics Manufacturers, REKOPOL – Recovery Organisation S.A., Poland, Repak – Packaging Recovery Organisation, Ireland, SERVING EUROPE - Branded Food and Beverage Service Chains Association, Sociedade Ponto Verde, S.A. – Packaging Recovery Organisation, Portugal, TIE - Toy Industries of Europe, UNESDA - Union of European Soft Drinks Associations, Valpak - Environmental Compliance, Recycling and Sustainability Solutions, UK