Issue Papers

In this section you will find EUROPEN’s issue papers on EU policy developments in relation to packaging and the environment. These papers reflect the consensus views of its members and present the opinion of the packaging supply chain in Europe, without favouring any specific material or system.

  • EUROPEN’s recommendation for a growth- and innovation-oriented Circular Economy

June 2020 - EUROPEN position on the New Circular Economy Action Plan 

Packaging is an integral and essential part of the product supply chain, from the production to the consumption stage. The packaging supply chain, represented by EUROPEN, plays a central role in contributing to a resource efficient and circular economy by optimising resource use, minimising product (and food) waste and protecting products all along the value chains. Our members are continuously innovating to deliver on their sustainability commitments, while preserving the integrity and safety of the products for citizens and businesses.

By putting the accent on the combined goal of increasing sustainability and economic growth, the new Circular Economy Action Plan (CEAP 2.0) sets the basis for an innovation-driven policy agenda, which must encourage both ambitious and economically viable solutions to scale up the circularity of the EU economy.

To enable the packaging supply-chain making bigger leaps towards a more circular economy, any new packaging-related policies and regulations must be guided by the following general principles:

  • Preserve the integrity of the Internal Market, to strengthen the implementation of packaging and packaging waste targets across the EU and avoid competitive distortions that risk undermining those same targets.
  • Protect the functionality of packaging ensuring its intended use is fulfilled, thus preserving product integrity and safety, and reduce product waste.
  • Embrace a life-cycle approach to circularity, where climate and environmental performance is assessed throughout the entire life cycle of packaging and product. 
  • Support innovation and investments in circularity through the deployment of incentive schemes and financing tools that are adequately funded, better streamlined and more easily accessible.
  • EUROPEN position on the Proposal for a Directive on the Reduction of the impact of certain plastic products on the environment

June 2018- EUROPEN position on the Proposal for a Directive on the Reduction of the impact of certain plastic products on the environment.

  • Circular Economy: EUROPEN recommendations on the EU legislative proposals for the Packaging and Packaging Waste Directive and Waste Framework Directive

February 2016 - EUROPEN recommendations on the EU legislative proposals for the Packaging and Packaging Waste Directive and Waste Framework Directive

  • EUROPEN Policy Recommendations for the EU’s Circular Economy Package

April 2015 – EUROPEN policy recommendations for a competitive, resource-efficient and growth-oriented Circular Economy. 

  • Guidance on how to consistently address packaging in the context of the European Commission Product Environmental Footprint methodology (PEF)

23 March 2015 - EUROPEN recommends using the Global Protocol on Packaging and Sustainability (GPPS), in line with the other existing guidance for packaging in life cycle approaches listed in this document, to address packaging in the PEF methodology and its ongoing pilots to develop potential future PEFCRs.

  • Factsheet on Extended Producer Responsibility (EPR) for used packaging

20 January 2015 - EUROPEN’s factsheet aims to address the frequently asked questions on Extended Producer Responsibility (EPR) for used packaging and explains why EPR is a key policy tool in the context of the EU Waste Review.

EUROPEN_Factsheet on EPR for used packaging (530.65KB)

  • Joint Statement by Packaging Value Chain Industries on the EU Waste Package

12 December 2014 - In view of the presentation of the European Commission’s work programme 2015 on 16 December 2014, a coalition of industries active in the packaging value chain has sent a joint statement on the EU Waste Package to President Juncker, First Vice-President Timmerman, other relevant Commissioners, Member States, Members of European Parliament and media.

Our industries support the objective of further transitioning to a circular economy and see the review of the Waste Acquis as an opportunity, subject to further improvements, to ensure better regulation and implementation of the Packaging and Packaging Waste Directive and Waste Framework Directive.

  • EUROPEN issue paper on the EU Waste Targets Review

4 December 2014 - In July 2014, the European Commission published a proposal to revise recycling and other waste-related targets in the EU, including in the Packaging and Packaging Waste Directive (PPWD). The aim of the overall package is to encourage the transition towards a Circular Economy and sustainable growth through the use of waste as a resource. Whilst EUROPEN supports the overall aims of the Circular Economy package, it is unlikely that certain proposed measures in the reviewed PPWD and Waste Framework Directive will effectively favour sustainable growth and cost-effectiveness. The proposed measures require revision if they are to truly promote a Circular Economy, preserve the Internal Market for packaged goods and ensure sustainable growth within a competitive Europe.

EUROPEN urges the European Parliament and the Council to make the following improvements:
1.    Remove potentially unlimited costs on producers
2.    Set a clear and enforceable method for measuring and reporting packaging recycling rates
3.    Refrain from setting mandatory national packaging design requirements which undermine the Internal Market
4.    Ensure delegated acts are used only for non-essential elements

  • EUROPEN Issue papers on EPR for post-consumer packaging in EU

September - December 2013 - EPR schemes have been instrumental in meeting and often exceeding targets set in the PPWD, as well as facilitating its implementation. In the process, the successes of the PPWD and of EPR have become interlinked if not inseparable. In this respect, it is critical that EPR schemes are expanded and improved, a view also supported by the European Resource Efficiency Platform. 

EUROPEN’s views on EPR and related contributions to European Commission’s public consultations can be found below.

  • EUROPEN Guidance on how to address packaging and packaging waste in the context of the EC PEF methodology

January 2014 - EUROPEN supports the European Commission’s objective and efforts to achieve harmonized and clear environmental information for consumers to make better informed choices, based on a life-cycle approach, in line with the objectives of the Resource Efficiency Roadmap. Packaging is one of the focus areas since the very early days of life-cycle assessments (LCA). The packaging supply chain has strived to develop harmonized life-cycle approaches and agreed on a common basis to assess packaging in a consistent and holistic manner in LCAs. Based on the experience and expertise of its membership, EUROPEN has developed key recommendations on how to address packaging for packaged products in the future development of all PEFCRs by the European Commission.

Please find below the full issue paper.