The proposal is based on a poor risk assessment of the possible environmental consequences and will lead to serious barriers to the free circulation of goods in the Single Market.
Additionally, no cost-benefit analysis has been conducted for the alternatives that will most likely replace the items that are to be banned or restricted. Therefore, the possible environmental and health and safety aspects have not been considered. Alternative packaging is not necessarily better from an end-of-life point of view. Furthermore, many jobs and production lines for local SMEs will be destroyed. Eventually, this will also result in increased costs for consumers.
This Directive is missing a great opportunity to educate our future generations, without going to the root of the problems that Europe has in terms of littering behaviours and controlled waste management. If not plastics, other single use materials will be littered. In this regard, EuPC Director, Alexandre Dangis shares: “The Packaging and Packaging Waste Directive diverts from its core purpose; and the desired harmonisation of all EU Member States is slowly but inevitably disappearing. It started with the Plastics Carrier Bags Directive in 2015 and it continues with another discrimination for only one material: plastics. SMEs in Europe are being penalized and jobs will be lost even though everybody knows the pollution is the highest in other parts of the world where more action is needed to combat littering. It will be difficult for politicians in the next years to show the added value of the EU institutions towards many of these affected companies and consumers. However we live in a political world which will hopefully learn from its mistakes but where education is taking for granted as the internet is taking over from our institutions.”
Against this scenario, EuPC will continue to work with policymakers and NPAs to ensure that environmental sustainability as well as health and safety of products are guaranteed. For the above-mentioned reasons, EuPC still urges the Members of the European Parliament and representatives of the Member States to take the time to understand the true implications of such a proposal, that is far from ensuring the desired environmental benefits.