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.

Harmonise EU waste legislation where relevant, while keeping the sectoral policy approach for packaging and packaging waste (packaging is not a product)

Packaging optimises resource use, helps to minimise (product and food) waste, protects products along different value chains and provides consumers with varied uses, choices and benefits of the products it contains. Packaging is a product facilitator, as part of a packaged product.

Unlike pure EU waste stream directives that only address the end-of-life of certain products, the PPWD covers the full life cycle of packaging. As packaging is not a product, policy harmonisation between the WFD and the PPWD needs to be carefully assessed case-by-case. For instance, EUROPEN welcomes the harmonisation of definitions in the PPWD with the WFD, but requiring EPR schemes to “gather data on products placed on the Union market by producers subject to EPR” (WFD proposal Article 8a (1) third indent would create a disproportionate and onerous administrative burden if EPR schemes for packaging waste are required to collect data about individual packaged products. This is just one example of the potential misinterpretation of the proposed harmonised EPR minimum requirements in the WFD, applicable to all waste streams. EUROPEN maintains the need for explicit provisions in the PPWD for EPR minimum requirements for packaging waste. This will also facilitate the update and accurate transposition in national packaging laws.

A specific sectoral policy approach for packaging remains essential. Targeted measures are necessary to ensure that packaging, including post-consumer packaging3, gets collected separately for recycling in those Member States where recycling capacities are in place. Legislation in some Member States permits heavy reliance on the collection and recycling/recovery of industrial, commercial and institutional (IC&I) packaging waste to meet legal targets. Although it is easier and cheaper to collect, focus on IC&I packaging waste only weakens both Member States’ and industry’s ability to achieve higher recycling and recovery rates.

The Commission should continue to be assisted by the Committee for the Adaptation to Scientific and Technical Progress, composed of the representatives of the Member States and chaired by the representative of the Commission as stated in the initial PPWD Article 21 Committee. However, this Article 21 Committee has been modified in the new PPWD so that it now refers only to “a” Committee which composition is no longer specified. EUROPEN would like the composition of this Committee to explicitly include national environmental/waste and industry experts in order to mirror the PPWD’s legal base and dual objectives.


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