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 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.

  • EUROPEN input to the EC consultation on marine litter

December 2013 - EUROPEN welcomes the European Commission’s (EC) public consultation to tackle marine litter, in line with the objectives set in the 7th Environment Action Programme (7EAP) and the Resource Efficiency Roadmap. EUROPEN supports the targeted multi-stakeholder approach to address the complexities of marine litter. While the packaging supply chain is not one of the key stakeholders addressed in the public consultation, EUROPEN wishes to raise three key points in this separate note for the Commission’s consideration. Please find below the full issue paper.

  • EUROPEN rationale on PPWD and its targets

November 2013 - This is a non-exhaustive list intending to provide sound argumentation why the packaging supply chain, represented by EUROPEN, continues to support the Packaging and Packaging Waste Directive (PPWD) as a separate product and waste stream directive, including its separate packaging targets.

  • Free circulation of packaging and packaged goods compromised in Commission’s proposal on lightweight plastic bags

November 2013 - The free movement of packaged goods in the Internal Market is a fundamental principle of the European Union, benefiting citizens and businesses alike. For this fundamental reason, EUROPEN would strongly advise against the proposed derogation to article 18 of the PPWD, considering the proportionality, effectiveness of such a marketing restrictive measure and the implications of the proposal vis-à-vis the potential far-reaching disruption to the internal market principle.

  • EUROPEN issue paper on EU Waste Management Targets Review

October 2013 - EUROPEN shares the European Commission’s views as expressed in its Roadmap for a Resource Efficient Europe, on the importance of ensuring the full implementation of existing EU waste legislation. The PPWD is key for the effective functioning of the Single Market and also aims to optimise the environmental performance of packaging and packaged products, which provides economic, environmental and societal gains for European citizens and industry. A revised PPWD will allow the Directive to remain relevant and effective in a changed regulatory and market setting, and will support the EU in meeting its aspirational objectives as set in the EU Resource Efficiency Roadmap. Please find below the full issue paper.

  • Fitness check - EUROPEN preliminary response to DG Environment study on the ex-post evaluation of the PPWD

July 2013 - EUROPEN’s responses to the fitness check workshop questions were intended for the European Commission’s consultants as additional input for their study on the ex-post evaluation of the 5 waste stream directives. EUROPEN’s input focuses only on the PPWD in line with its remit and based on 20 years of experience with the PPWD. Please read below the full EUROPEN replies.