The undersigned organisations represent a wide range of packaging materials, including plastics, and sectors at different stages of the packaging value chain in Europe. We wish to express our reservations about the unprecedented pace at which this proposal has been developed and intends to be adopted, which may impact the overall quality of the adopted Directive. We are also concerned that fundamental policy principles for Better Regulation, which ensure an efficient transition to a Circular Economy are not reflected in the Commission’s proposal, as illustrated in the below recommendations. We acknowledge the problem of plastic pollution and are committed to finding solutions. To this end, our common overarching objectives as value chain partners are to ensure that:

• A coherent EU policy framework for packaging is maintained, and the Internal Market for packaged goods is safeguarded by avoiding various differing legal interpretations at EU and national level.
• The Directive addresses the root causes of marine litter holistically, incentivises meaningful innovation and interventions and allows sufficient development time from R&D to commercialisation.
• Policies and legislation contain clear definitions and are based on a complete, evidence-based impact assessment of the implications, to avoid possible unintended consequences.
• Policy measures are non-discriminatory and proportionate to the challenges addressed.

You can download the statement below.