In November 2022, a pivotal step was taken by the European Commission as it unveiled a comprehensive revision proposal for the existing Packaging and Packaging Waste Directive. The key aim of this proposal was to foster harmonization of packaging requirements across the European Union (EU) through a transformation of this legislative instrument into a Regulation.
The Legislative proposal aims to achieve the European Commission’s Circular Economy objectives for packaging, with the goal to make all packaging placed on the EU market either reusable or recyclable by 2030. In this regard, the proposed regulation introduces recycled content targets for plastic packaging, reuse targets for different packaging formats and sectors, additional EPR requirements, introduction of Deposit-Return Schemes for Member States, as well as recyclability definitions and requirements for packaging.
As of now, the draft legislation continues to undergo discussions within the European Parliament and the Council. Once these institutions establish their negotiating mandates, the stage will be set for inter-institutional dialogues that will pave the way for official adoption. The significance of achieving a consensus ahead of the impending European elections in May 2024 has been highlighted by Environment Commissioner Virginijus Sinkevičius.
In the European Parliament, the Environment (ENVI) Committee is at the forefront of steering discussions concerning the proposal. Concurrently, the Industry (ITRE), Internal Market (IMCO), and Agriculture (AGRI) Committees contribute their perspectives with overall submitted 5000+ proposals or amendments. The final report of Rapporteur MEP Frédérique Ries (Renew, Belgium) is expected later this autumn.
As the proposal traverses through these deliberations, it signifies a significant stride toward a more ecologically balanced future, one where packaging aligns harmoniously with environmental objectives. The outcomes of these discussions are poised to shape Europe’s packaging landscape for years to come.
The Extended Producer Responsibility Alliance (EXPRA), representing 32 non-profit national EPR organizations across Europe and beyond, supports the Commission’s proposal to review the current packaging and packaging waste directive (PPWD). We believe that it is of crucial importance to set up a forward-looking and ambitious regulatory framework for packaging waste management enabling national and local entities to implement effective and efficient packaging and packaging waste management systems.
The adoption of realistic and holistic policies is necessary to ensure packaging functionality is safeguarded whilst contributing to reducing the climate and environmental impact of packaging. Not all circular policies have an equally positive effect on the climate, and a scientifically robust approach based on life-cycle assessments should be favored. Regulatory predictability is key to ensuring investment security, especially in waste management infrastructures.
Therefore, we would like to offer a series of recommendations to enhance the proposal, based on the extensive expertise of our members in EPR, waste management, and data collection throughout Europe.
Our estimated analysis showed that EXPRA members’ recycling practices save the CO2 equivalent of an annual car trip from Paris to Amsterdam per capita. Efficient waste management systems thus make a key contribution to limiting climate warming, which could be drastically improved by implementing best practices across all EU Member States. Producer Responsibility Organizations (PROs) are currently the only actors in a neutral position to enable, facilitate, and assess full circularity. Where PROs have a say in the design of waste management systems, they are key in helping the industry to improve packaging sustainability, establish state-of-the-art treatment infrastructures, collect data, and ensure public awareness of the benefits of recycling for consumers. Therefore, EPR plays an essential role in ensuring that the circular economy measures have a positive impact on the climate under the right enabling conditions, which should be strengthened by any new legislation.
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