ZWE is particularly troubled by the deletion of key tools and clauses, as well as the announcement of potential further deregulation in the months to come.
“Europe aspires to lead the world in circularity, yet the European Commission seems to be opening doors to weaken key files that form the backbone of the European circular economy ,” states Aline Maigret, Head of Policy at Zero Waste Europe.
ZWE stressed the importance of simplification being strictly limited to genuine administrative improvements, in order to ensure that core policy objectives continue to be fully pursued. These measures should not open the door to removing targets or diluting essential environmental requirements.
Key concerns for the Circular Economy:
Packaging regulation (PPWR)
While we welcome the Commission’s commitment to enforcing the much-needed ban on PFAS in food contact packaging under the PPWR, this ban must however apply to both intentionally added and unintentionally present PFAS. We support a “guidance document” that would help both Member State authorities and industry stakeholders in enforcement and achieving compliance with the rules and limits set in the regulation. The current lack of standardised methods for measuring the vast number of PFAS in packaging creates some enforcement challenges, but this definitely should not be an excuse to delay or change the scope of the ban.
We are concerned however about the presence of PPWR in the omnibus process as this risks creating confusion about reopening or further weakening its provisions, such as those already referred to by the Commission for the food and beverage sector. The reuse and recycling sectors urgently need regulatory certainty and stronger data transparency to guide future-proof public and private investment — especially for developing and upgrading infrastructure that supports the achievement of the reuse targets (binding or not).
We are also worried about the potential “additional flexibilities” for:
- other packaging formats, “particularly where hygiene and food safety concerns may hinder compliance with the targets”. Claims related to safety and hygiene are frequently used to delay or weaken measures such as reusable packaging, despite limited evidence to support such concerns.
- the use of un-recycled plastics” backtracks on ensuring that packaging is designed for recycling and actually recycled. At a moment when the industry is seeking support from the Commission, this message delivers the opposite.
Repeal the obligation to report SCIP-related data
ZWE regrets the decision to repeal the SCIP database. The lack of its effectiveness in informing users about the presence of hazardous substances is a result of issues with availability and data quality – challenges that reflect insufficient compliance and engagement from industry and businesses. Instead of working towards increasing transparency along the supply chain by simplifying and streamlining the existing system and data, and securing access to information until “the use of digital product passports in the future”, the decision appears to respond to concerns raised by some producers who have opposed the database from the outset. Importantly, industry associations are already raising significant concerns concerning the reporting of chemicals in the Digital Product Passport.
Extended Producer Responsibility (EPR) schemes
The CEA is also supposed to reduce reporting obligations for producers on the products placed on the market, collection and treatment, which could lead to insufficient granularity. Simplification should not remove essential reporting requirements that are key for the environmental performance of national systems. Transparency will also be essential to improve systems moving forward.
Landfill target
Zero Waste Europe regrets that the 10% landfill target was not addressed in the Environmental Omnibus, despite lacking support from the Commission’s own impact assessment and having no scientific basis. Instead of delivering environmental benefits, it has become an arbitrary and burdensome provision in EU waste law. In practice, its main effect has been to drive new incineration capacity, locking in carbon-intensive infrastructure that undermines the circular economy and increases fossil CO₂ emissions.
Zero Waste Europe calls on the European Commission to ensure that simplification measures genuinely support the transition to a circular economy. We stand ready to collaborate with decision-makers and stakeholders to look into meaningful simplification while maintaining high circularity standards.
