EUROPEN, The European Organization for Packaging and the Environment, has sent a letter to the European Commissioner for the Environment, Janez Potocnik, in relation to the upcoming EC proposals on its Waste Targets review.
In the letter, EUROPEN managing director Virginia Janssens calls on the European Commission for greater “legal clarity” to bring the various different schemes operated at national level within the EU closer together.
Janssens states: “The Commission’s forthcoming legislative proposal on EU waste targets is a key opportunity to transition towards a resource efficient and competitive Europe and to drive further recycling and recovery of packaging waste, away from landfills.
“To this end, clarified roles and responsibilities for Extended Producer Responsibility (EPR) with binding minimum performance criteria for EPR compliance schemes in the Packaging and Packaging Waste Directive are crucial for industries obliged to implement EPR for packaging at national level.
“Amid current market distortions and vague European and national laws on EPR for packaging waste, EUROPEN calls upon the Commission for more legal clarity, which will ensure a much needed and urgent level playing field and more transparency among the various national compliance scheme models, which are set up to transpose the legal obligation of the obliged industry.”
The text of the EUROPEN letter reads as follows:
Dear Commissioner Potocnik,
On behalf of EUROPEN – The European Organization for Packaging and the Environment – a cross-sectoral industry body representing the packaging supply chain in Europe, we would like to reiterate the importance of transitioning to a competitive and resource efficient economy. Transforming waste into a resource is at the heart of achieving a circular economy.
We believe that full implementation and enforcement of EU waste legislation in all Member States – in order to drive more recycling and recovery and to divert waste from landfill – are necessary to ensure this transition to a resource efficient Europe.
The forthcoming review of the targets in the different waste directives (Waste Framework Directive (WFD), Landfill Directive and Packaging and Packaging Waste Directive (PPWD)) will play a critical role in this respect. EUROPEN sees the review of EU waste management targets as an opportunity to ensure the continued relevance and effectiveness of the PPWD in a changed regulatory and market setting.
We hence call on the European Commission to take the following remarks into consideration:
1. EUROPEN wishes to reiterate that the PPWD is a harmonisation measure, i.e. it establishes common rules that help enable packaging and packaged goods to trade freely and easily throughout the EU, safeguarded by the Internal Market legal base. It defines minimum (‘essential’) requirements for packaging design together with overall and material specific targets for used packaging that must be recycled or recovered in the Member States. This intrinsic link reflects life-cycle thinking, and should remain so, also accurately reflected in the Directive’s title, i.e the Packaging and Packaging Waste Directive.
2. Recycling and recovery targets for packaging waste should remain in the PPWD. The PPWD remains the appropriate legislative framework for driving recycling and recovery of all packaging waste, irrespective of the waste stream in which it arises. The packaging targets need to be structured differently from those in the WFD. It ensures that the investments in infrastructure and systems for the separate collection of used packaging for recycling/recovery remain in place and in some cases are developed further.
3. Packaging waste targets should be achievable and realistic, taking into account different Member State levels of performance, consumption rates and infrastructure capacities, and should be based on harmonised rules for calculating and reporting packaging recycling and recovery rates, as well as packaging placed on the market. The definitions of recycling and recovery should be harmonised with those in the WFD.
4. Post-consumer packaging* collection should be encouraged in the PPWD. Collection of post-consumer packaging separately from organic or industrial, commercial and institutional packaging waste is essential to ensure sufficiently high levels of both quality and quantity to meet existing and future recycling targets and to make recycling and recovery economically viable and environmentally beneficial.
5. Binding minimum requirements on Extended Producer Responsibility (EPR) for used packaging should be enshrined in the PPWD along with clearly assigned roles and responsibilities for Member States, municipalities and economic operators. These should be codified, along with a requirement for Member States to implement and enforce national authorisation procedures for EPR compliance schemes. A waste stream-specific regulatory approach for EPR in the PPWD is essential because the roles and responsibilities and challenges for packaging and packaging waste are different to those for other waste streams where EPR exists, in terms of volume, consumer visibility, recycling value and market structure.
The implementation of EPR for used packaging has a proven track record for organising the recovery of materials and closing the loop. EUROPEN members reiterate the European Resource Efficiency Platform’s call to use the opportunity of the Waste Policy Review to make EPR compliance schemes more efficient and effective in order to support the transition to a circular economy. EUROPEN and its members look forward to providing continued support to this important review process.
*'Post-consumer packaging': Primary and secondary packaging generated by households, away-from-home and at closed surroundings (e.g. small businesses, bars, restaurants, public events, schools) insofar as the type of packaging/volumes consumed are similar to households.
The letter is signed by Virginia Janssens, and copied to a number of other EC Commissioners and personnel.
(Annex, ‘Minimum Requirements on Extended Producer Responsibility (EPR) for used packaging in the PPWD’ not included)
For further information, visit: www.europen-packaging.eu
