EUROPEN comments on circular economy package

The European Organization for Packaging and the Environment(EUROPEN) has made some recommendations on the EU legislative proposals for the Packaging and Packaging Waste Directive and Waste Framework Directive.

Safeguard the free movement of packaging and packaged goods in the Internal Market
The ambition of a Circular Economy in Europe would be fatally undermined if the Internal Market does not function properly. The Packaging and Packaging Waste Directive (PPWD) has the EU Internal Market as its legal base and includes a notification procedure under Article 16. This requirement safeguards against national protectionist or discriminatory measures and thus against barriers to the free movement of packaging and packaged goods in the EU Internal Market. Therefore, the PPWD remains fundamental for this Internal Market guarantee. Given the differences in legal base between the Waste Framework Directive (WFD) and the PPWD and the specific sector policy needs of packaging (versus products), EUROPEN maintains the need for explicit provisions within the PPWD. For instance, the impact of national EPR schemes modulating fees for packaging risks fragmenting the Internal Market due to different criteria used but also due to the divergent impacts of similar criteria for fee modulation per EPR scheme, Member State and related packaging waste management infrastructures.


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