The European Organisation for Packaging and the Environment

Review of the Packaging and Packaging Waste Directive EUROPEN accompanying document to the Public Consultation questionnaire December 2020 Striving for an ambitious and coherent legislative review Packaging of the future will have to be reusable or recyclable in an economically viable way, support the EU climate goals and, at the same time, continue to provide safe and sustainable products to consumers. The review of the Packaging and Packaging Waste Directive (PPWD) can represent a real milestone in the process of moving towards a sustainable packaging value chain in Europe. The regulatory framework must be fit for purpose to effectively prevent packaging from becoming waste, by boosting recyclable and reusable solutions while preserving packaging functionalities.

…from becoming waste, by boosting recyclable and reusable solutions while preserving packaging functionalities. • Recognising the purpose of packaging There are good reasons for products to be packaged: to protect products’ integrity and consumers’ health and safety, to increase products’ shelf-life, to reduce product losses, to facilitate transport, efficient handling and distribution, to promote the packaged product and to provide information and convenience to consumers. The policy measures to further drive the sustainability of the packaging value chain must ensure these functionalities are not undermined. • Coherence with the EU environmental and climate objectives Pursuing the EU Green Deal’s objectives requires embracing a life-cycle approach to circularity, where climate and environmental performance is assessed throughout the entire life-cycle of packaging and product.

…where climate and environmental performance is assessed throughout the entire life-cycle of packaging and product. A thorough impact assessment of unavoidable and potential trade-offs, resulting in unintended consequences or negative impacts (environmental, economic and social impacts), will be necessary to ensure that these are minimized or prevented. • Future-proofing of legislation to support innovation Future targets, definitions and design requirements need to provide sufficient visibility to drive investments into new packaging solutions, reuse schemes and waste management technologies. Rather than imposing bans or restrictions on specific packaging materials or formats, policies should strive to ensure that they can become reusable and recyclable in the immediate future. • Single Market for packaging and for secondary raw materials.

…become reusable and recyclable in the immediate future. • Single Market for packaging and for secondary raw materials. The review must address barriers and bottlenecks resulting from insufficient harmonisation and weak enforcement of existing EU provisions at national level. Key provisions must be clearly defined in the legislative text for maximum harmonisation across the Member States and enforcement mechanisms must be strengthened to oversee their effective implementation. Ref. Ares(2020)7779836 - 19/12/2020 1. WASTE PREVENTION The overarching goal of any future policy measures addressing packaging waste prevention must be threefold: 1. Optimise the amount of packaging put on the market without undermining packaging functionalities and avoiding undesired trade-offs in other life-cycle stages (e.g. climate impact, food waste).

…functionalities and avoiding undesired trade-offs in other life-cycle stages (e.g. climate impact, food waste). 2. Prevent waste generation and loss of resources due to landfilling, and incineration by maximising packaging reuse and recycling;

…generation and loss of resources due to landfilling, and incineration by maximising packaging reuse and recycling; 3. Reduce the overall EU environmental footprint, with a particular focus on resource use, GHGs emissions. Defining overpackaging and underpackaging Both overpackaging and underpackaging need to be clearly defined to effectively address waste prevention by eliminating unnecessary (i.e. not functional) packaging whilst preventing negative consequences on product safety and integrity. Overpackaging should be defined as packaging which is not functional, i.e. it is not essential to fulfil the functionalities of packaging foreseen by the Essential Requirements. Underpackaging should be defined as packaging which is sub-optimal, i.e. it does not guarantee the fulfilment of packaging functionalities foreseen by the Essential Requirements. Reduce the overall EU climate and…

…and the savings guaranteed through packaging use. The same consideration applies for other environmental impacts. 2. REUSE Reusable packaging systems have an important role to play in a circular economy. Well-designed systems can concretely contribute to resources and material savings while reducing the climate and overall environmental impact of packaging. Upscaling reuse models needs a systemic change of business models and supply chain transformation. Reuse targets alone will not drive such systemic change. Reuse models’ design and management Careful management and design are essential to reap the environmental benefits (including GHG emissions reductions) linked to an increase in reusable packaging, while avoiding unintended consequences such as increased GHG emissions, energy and water consumption, complex logistics, cleaning, food and health safety, and others.

…increased GHG emissions, energy and water consumption, complex logistics, cleaning, food and health safety, and others. Accurate science-based impact assessments, including from a life-cycle perspective, need to accompany the introduction of reuse systems. In this context it is crucial to compare benefits and impacts of single-use and multiple use packaging for the same product categories. Societal and demographic developments also have implications for the effective deployment of reuse systems, which should be part of feasibility assessments. A major issue to assess the environmental impact of business-to-consumer (B2C) reuse systems is data availability/quality. Without digital traceability of number of refills and transport distances, this is very hard to evaluate.

Without digital traceability of number of refills and transport distances, this is very hard to evaluate. Unique coding/serialization for packaging that enables complete track and tracing, including refill cycles, would be necessary to assess the climate and environmental footprint of reuse systems. Reuse must include refill/recharge done both at home and in the shops. This will allow developing refill practices, which contributes to the reduction of material used, and ultimately to the reduction of GHG emissions and other environmental impacts. Requirements for reuse and refill Reuse and refill should comply with the same regulatory requirements that exist for the introduction on the market of any packaged product. The number of rotations of the packaging is not infinite, hence also reusable packaging should be recyclable at the end of its life cycle.

…of the packaging is not infinite, hence also reusable packaging should be recyclable at the end of its life cycle. As the environmental benefits of reuse are strongly dependent on the number of times that the packaging is actually reused, appropriate consideration must be given to the minimum number of rotations that reusable packaging can endure. For example, a pragmatic approach could be envisaged to test the minimum number of rotations per packaging type. From niche to large scale reuse models To bring significant positive environmental outcomes, B2C reusable packaging should be designed to be deployable at the level of the large distribution. This requires convenient collection infrastructure, including for on-the-go- consumption, something which is missing largely from today’s Extended Producer Responsibility (EPR) and Deposit- Refund Schemes (DRS) systems.

…which is missing largely from today’s Extended Producer Responsibility (EPR) and Deposit- Refund Schemes (DRS) systems. Besides the thorough assessment of overall environmental impact, the financial and logistics implications of establishing a take-back infrastructure and storage of empties need to be factored in. For beverages in particular, reuse models (through refillable bottles) in a B2C setting must rely on a DRS. When these are considered, they should fulfill a number of conditions: - Efficient, cost-effective and accountable, - Strong environmental outcomes, - Shared financial responsibility, - Convenient for consumers, - Long-term financial sustainability, - Allow producers to secure material for closed loop recycling. 3. ESSENTIAL REQUIREMENTS The Essential Requirements (ER) for packaging must be strengthened, harmonised and properly enforced across the EU.

Essential Requirements (ER) for packaging must be strengthened, harmonised and properly enforced across the EU. They need to be ambitious to enable the transition towards the policy goals of the New Circular Economy Action Plan and the 2050 EU climate neutrality objective of the European Green Deal. While helping advance packaging sustainability, changes to the ER must preserve packaging’s functionalities, enable innovation and prevent restrictions to the free circulation of packaging and packaged goods in the Single Market. Defining recyclability A clear, harmonised and actionable definition of recyclability is key for the successful revision of the ER and implementation of the PPWD. It must be forward looking and not be based only on what is feasible today.

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January 2023 www.europen-packaging.eu 1 EUROPEN Feedback on the EU Commission Proposal for a Regulation on Packaging and Packaging Waste Key messages > EUROPEN, the European Organisation for Packaging and the Environment, fully supports the objective of the Packaging and Packaging Waste Regulation (PPWR) proposal to contribute to the efficient functioning of the internal market for packaged goods, while preventing or reducing the adverse impacts of packaging waste on the environment and on human health. > EUROPEN welcomes the proposal for a Regulation with a full internal market legal basis as a way to increase the potential for harmonisation across Member States. However, we remain concerned that many provisions in the text would allow Member States to introduce specific and divergent national requirements.

…that many provisions in the text would allow Member States to introduce specific and divergent national requirements. > In addition to sustainability requirements, the proposal should incorporate measures for the development of collection, sorting, recycling and reuse infrastructure. Requirements on packaging recyclability or reusability alone will not suffice unless backed up by a system capable of triggering investments in infrastructure across Europe. > The proposal contemplates the adoption of numerous implementing and delegated acts without providing for a system for the inclusion of packaging experts in the development of highly technical secondary legislation.

…for a system for the inclusion of packaging experts in the development of highly technical secondary legislation. We encourage the creation, at EU level, of a Technical Committee managed by the EU Commission and composed of representatives from national authorities and the entire packaging value chain to enable the involvement of such experts. > While a clear timeframe for the adoption of secondary legislation is missing in many instances, a number of requirements will have to be implemented 12 months after the entry into force of the Regulation. We call on the establishment of exemptions for products that have already been packaged before the entry into force of the requirements (e.g. transitional periods and rules on exhaustion of stocks), as well as to ensure legal certainty for economic operators, including clear timeline for the adoption of secondary legislation.

…to ensure legal certainty for economic operators, including clear timeline for the adoption of secondary legislation. > The proposed targets on packaging minimisation, recycled content, reuse, and packaging formats restrictions should be assessed on their ability to deliver the best environmental outcome and with respect to hygiene, health and food safety requirements. We strongly call on the co-legislators to strengthen the Commission’s proposal on the basis of robust data and life cycle analyses. General remarks • Legal instrument and legal basis A stronger harmonisation of EU rules on packaging and packaging waste is key to create a true EU circular economy. The choice of a Regulation as legal instrument and an internal market legal basis (Article 114 TFEU), is therefore a welcome step forward.

…as legal instrument and an internal market legal basis (Article 114 TFEU), is therefore a welcome step forward. As the file moves into the co-decision process, EUROPEN calls for preserving a full internal market legal basis, thus increasing the potential for harmonisation across Member States; putting an end to the plethora of divergent Ref. Ares(2023)1675774 - 08/03/2023 www.europen-packaging.eu 2 national measures that are disrupting the EU single market and undermining the transition of the European packaging value chain to greater circularity. In relation to this, we would like to express our concern about the presence in the text of provisions allowing Member States to maintain or introduce specific requirements at national level (e.g. Art. 4 and Art. 45).

…allowing Member States to maintain or introduce specific requirements at national level (e.g. Art. 4 and Art. 45). • Measures aimed at supporting packaging sustainability As currently proposed by the Commission, the Regulation formulates mandatory requirements on economic operators but fails to address the need for a step change in public authorities’ waste management obligations. The establishment of sustainability requirements on packaging recyclability or reusability alone will not suffice unless backed up by a system capable of triggering investments in collection, sorting, recycling and reuse infrastructure across Europe. Not incorporating requirements for the development of collection, sorting and recycling infrastructure in the PPWR would be a serious missed opportunity on delivering the EU Green Deal goals.

…and recycling infrastructure in the PPWR would be a serious missed opportunity on delivering the EU Green Deal goals. We therefore strongly recommend the introduction in the legislative proposal of mandatory collection requirements and targets, as well as obligations for Member States to significantly invest in sorting and recycling infrastructures. The governance and transparency of Extended Producers Responsibilities (EPR) schemes should also be improved to ensure better oversight of EPR fees and their utilisation. To support the creation of a Union market for secondary raw materials, the PPWR should also introduce a clear obligation on Member States to ensure that, when they lack adequate waste sorting and/or recycling infrastructure, they would be required to ship their waste to another EU country to ensure that packaging waste is effectively recycled.

…would be required to ship their waste to another EU country to ensure that packaging waste is effectively recycled. • Impact assessment of the proposed measures From a preliminary analysis of the Commission’s impact assessment, it appears that several of the proposed measures have not been assessed against packaging functionalities, for example in ensuring consumer health, product safety and waste prevention. Furthermore, the Regulatory Scrutiny Board’s opinion on the Commission’s draft impact assessment noted several flaws in the calculation of the measures’ estimated costs and benefits. In light of the above, we strongly call on the co-legislators to strengthen the Commission’s proposal on the basis of robust data and life cycle analyses.

…call on the co-legislators to strengthen the Commission’s proposal on the basis of robust data and life cycle analyses. An assessment of the proposed targets on packaging minimisation, recycled content, reuse, and packaging formats restrictions should be carried out against available feasibility studies, real life conditions, logistic scenarios, possible impacts on health and safety of consumers, as well as food waste reduction targets and safety requirements. • Secondary legislation and implementation timelines The Regulation proposal contemplates the adoption by the Commission of numerous implementing and delegated acts, within certain deadlines.

…contemplates the adoption by the Commission of numerous implementing and delegated acts, within certain deadlines. A general safeguard rule is needed to ensure that any delays in the publication of such acts - as experienced in the past with other legislative files - are translated into equivalent transitional periods for the application of different requirements, ensuring legal certainty and predictability for economic operators. We also recommend the inclusion of clear timeframes for all those secondary acts for which a deadline for adoption has not been specified in the legislative proposal, as in the case of Article 6 (4). Furthermore, many proposed requirements will have to be implemented 12 months after the entry into force of the Regulation.

…many proposed requirements will have to be implemented 12 months after the entry into force of the Regulation. Unless industry is granted sufficient time to design and produce compliant packaging, and exemptions are established for products that have already been packaged before the entry into force of the requirements (e.g. transitional periods and rules on exhaustion of stocks), additional packaging will be generated to repack products, undermining the objective of the Commission to reduce packaging and packaging waste. Finally, industry involvement should be ensured when drafting secondary legislation, especially given the importance of technical and practical understanding of packaging and packaging processes. We detail below our proposal for a Technical Committee.

…practical understanding of packaging and packaging processes. We detail below our proposal for a Technical Committee. www.europen-packaging.eu 3 Remarks on specific measures • Packaging recyclability - Article 6 We welcome the introduction in the text of an EU-wide definition of ‘recyclable packaging’ and the proposal to assess packaging recyclability against Design for Recycling (DfR) criteria, which the EU packaging industry has been developing and applying for some years now. However, we consider that the Commission turnaround on the proposal to establish a Packaging Forum is a missed opportunity to involve packaging experts in the development of highly technical secondary legislation.

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February 2025 www.europen-packaging.eu 1 EUROPEN position on PPWR Articles 29.2 and 29.3 - Contribution for delegated act on single-use pallet wrappings and straps 1. Background Articles 29.2 and 29.3 of the Packaging and Packaging Waste Regulation (PPWR) introduce, as of 1 January 2030, a 100% reuse target for economic operators that use transport packaging or sales packaging used for transporting products under specific conditions1. Notably, this measure is also set to apply to pallet wrappings or straps for stabilisation and protection of products put on pallets during transport, introducing a de facto ban on the use of these flexible packaging formats2. Considering possible limitations and expected unintended consequences of the above-mentioned targets in relation to feasibility, transport efficiency, workers’ safety, and potential disruption of supply chains, the EU Commission…

…in support of an exemption for all single-use pallet wrappings and straps for stabilisation and protection of products. 2. Pallet wrappings and straps in the EU value chain Functionality and implications of a possible ban Single-use pallet wrappings and straps, made of different materials3, are currently the most widely used options among economic operators to wrap and transport products. These packaging formats play an essential role in different EU supply chains by, for instance: > Protecting the product quality and integrity by preventing damage, stains and exposure to pests or the environment, e.g. to water, oil or humidity.

…and integrity by preventing damage, stains and exposure to pests or the environment, e.g. to water, oil or humidity. As an example, shrink wraps protect the interior of any outer packaging and stabilise humidity, allowing the transportation of packaged products across differing temperatures and humidity areas for longer periods, and stabilising humidity at an equilibrium relative humidity (eHR) level4, when external temperatures are much lower. This is fundamental to preserve products’ features, such as colour, physical properties or enzyme stability, which could otherwise be altered. > Acting as a secondary packaging layer that reduces the likelihood of tears or punctures to the primary packaging, thus providing an important barrier against, for instance, pests and other contaminants.

…to the primary packaging, thus providing an important barrier against, for instance, pests and other contaminants. 1 The mentioned reuse target applies to pallet wrappings or straps for stabilisation and protection of products put on pallets during transport, when used by economic operators within the territory of the Union, between different sites on which the operator performs its activity, or between any of the sites on which the operator performs its activity and the sites of any other linked enterprise or partner enterprise; as well as to deliver products to another economic operator within the same Member State. 2 As described in greater detail below, pallets wrappings and straps made of different materials are non-reusable as they loose elasticity properties after use or are cut at the right length (plastic, paper) or embossed (metal) based on the products they are used for.

…use or are cut at the right length (plastic, paper) or embossed (metal) based on the products they are used for. 3 Single-use pallet wrappings and straps are made of different materials, such as plastic, where wraps are predominantly made of PE, but also LDPE and LLDPE; paper, consisting of twice folded paper, glued and coated on one side with hotmelt; and metal straps, normally embossed around products. For a visual overview of available transport packaging plastic films for shipment and storage, see a recent document from EuPC, IK and Elipso, available here. 4 Equilibrium relative humidity of a product is achieved when the relative humidity of the air surrounding the product that is in equilibrium with its environment. Ref.

…when the relative humidity of the air surrounding the product that is in equilibrium with its environment. Ref. Ares(2026)164190 - 08/01/2026 February 2025 www.europen-packaging.eu 2 > Providing a flexible solution, adaptable to different production lines, operations and product’s shapes (e.g. irregular shapes, multi-pack configurations). > Consolidating the individual packaging and the pallet into a single packaging unit, while only adding minimal weight5, thus ensuring the safety of loads and workers during transport, handling and storage, and improving load securement practices. Indeed, the stretching and tightening properties ensured by current solutions provide additional stability, avoiding pallet content movement during transportation, damage to bottom layers or pallet collapse. > Preventing fraud and theft of packaged products in transit.

…damage to bottom layers or pallet collapse. > Preventing fraud and theft of packaged products in transit. The application of a 100% reuse target to these applications is technically not feasible due to the intrinsic properties of these flexible formats, which loose tensile strength after use. For instance: > The plastic films used for wrapping are stretched or shrunk so that they stick to the elements on the pallet that need to be stacked and kept tightly together. Re-stretching or re-shrinking a film that has already been stretched or shrunk is technically not possible6. > Similarly, paper pallet wrappings and metal straps are also not re-usable as they are either cut at the right length (plastic, paper) or embossed (metal). The re-use of such straps would not allow the right safety and robustness of the stack on another pallet.

(metal). The re-use of such straps would not allow the right safety and robustness of the stack on another pallet. Overall, should the ban of these single-use solutions be retained, it would not be possible for economic operators to use the currently existing technologies for pallets wrapping and strapping, and alternative methods would be needed to fulfil these functions, with expected negative environmental and economic impacts. Data regarding the collection and recycling rates and recyclability of currently used pallet wraps and straps Although non-reusable, pallet wrappings and straps made of different materials are technically recyclable and largely collected and sorted via voluntary industry-led systems or through dedicated Extended Producer Responsibility schemes, such as the Valipac in Belgium.

…industry-led systems or through dedicated Extended Producer Responsibility schemes, such as the Valipac in Belgium. Granular data regarding the collection and recyclability of specific packaging material categories are currently limited, but figures are available for plastics, paper and metal. > With regards to plastic pallet wrappings and straps, according to a study by Plastics Recyclers Europe (PRE)7, the Commercial and Industrial waste stream accounted in 2020 for 3.6 million tonnes of collected volumes consisting of secondary and tertiary film waste such as shrink wraps and stretch films from logistics firms, supermarkets and other B2B activities.

…tertiary film waste such as shrink wraps and stretch films from logistics firms, supermarkets and other B2B activities. According to the study, this waste stream has higher collection and recycling rates compared to, for instance, household or agriculture packaging, due to better quality driven by mono-material films and limited contamination owing to the nature of applications as well as separation at source8. This is why recyclates produced from this stream tend to go into higher value applications and the demand for such recyclates is expected to continue growing in light of the recycled content targets set by the PPWR and other pieces of EU legislation. Finally, it should also be noted that some plastic pallet wrappings and straps, such as for instance stretch foils, have already been tested and validated to incorporate up to 30% recycled content.

…such as for instance stretch foils, have already been tested and validated to incorporate up to 30% recycled content. > In relation to paper wrappings and straps, available solutions consist of twice folded paper, glued and coated on one side with hotmelt, which are designed to be recyclable and present high recycling rates (in the range of 83%). > With regards to metal straps, available solutions are highly recyclable and can be easily sorted and recycled without any loss of quality due to the inherent properties of steel and its magnetic properties. As industrial 5 The stretching and tightening properties of currently used single-use solutions ensure pallets stability while adding minimum weight to loads and consignments.

…of currently used single-use solutions ensure pallets stability while adding minimum weight to loads and consignments. In the case of single-use plastic stretch foils made of virgin material, for instance, further efficiency can be achieved by reducing the thickness of the foils for manual applications, replacing a 23µm thickness to a 6µm thickness foil and achieving significant reduction in material usage (up to 74%). 6 The performance of stretch film is linked to its tensile strength, which is significantly reduced once used.

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…1 Review of the Packaging and Packaging Waste Directive EUROPEN’s feedback on the Inception Impact Assessment July 2020 Objective EUROPEN supports the general objective for the revision of the Packaging and Packaging Waste Directive (PPWD), which is a well-functioning Internal Market through fully harmonised rules on packaging while tackling the environmental impact of packaging and packaging waste. The review must be carried out in line with the policy objectives of the European Green Deal and the new Circular Economy Action Plan, which set the basis for an innovation-driven policy agenda to pursue sustainable growth and encourage both ambitious and economically viable solutions to scale-up circularity and contribute to climate neutrality.

…both ambitious and economically viable solutions to scale-up circularity and contribute to climate neutrality. 1. The PPWD review must ensure the integrity of the Internal Market by establishing harmonised EU requirements and legislation for packaging, in line with the legal basis of the Directive (art. 114 of TFEU). • As rightly pointed out by the Commission’s analysis, “It is necessary to strive for full harmonisation of rules on packaging and packaged goods. Uncoordinated national measures to address sustainability aspects of packaging result in obstacles to the free movement of goods and hinder the development of markets for secondary raw materials”. • The review of the PPWD must address existing barriers, with focus on delays and incoherence in national implementation of existing legislation as well as insufficient enforcement of EU provisions at national level. • Waste collection…

EPR systems should ensure accountability for all actors to ensure efficiency and transparency in the use of EPR fees. 2. Packaging functionality should be protected and recognised to ensure that packaging intended use is fulfilled. • Packaging exists to fulfil a number of key functions, including: protecting products’ integrity and consumers’ health and safety, increasing products’ shelf-life, contributing to waste reduction, facilitating transport, efficient handling and distribution, promoting the packaged product and providing information and convenience to consumers (e.g. in relation to health or dietary requirements). • Policy options should strive for an enabling policy framework that allows industry to innovate, while equally considering climate protection, packaging optimisation and recycling objectives. Measures to increase recyclability cannot jeopardize product safety and…

…on emissions and resource efficiency, must be duly assessed from an environmental, climate and economic standpoint. 3. The review must ensure coherence of policy objectives to avoid the risk of undermining the sustainability goals and to support investments in innovation. • A coherent EU policy framework for packaging and packaging waste is essential to provide the packaging supply chain with a clear direction and the necessary legal certainty and economic predictability to continue investing in sustainable and circular economy solutions. • Striking the right balance between policy goals (e.g. waste prevention, waste reduction, recycling, food waste prevention, emissions reduction...) is key to ensure coherence with the overall aim of tackling Ref.

…food waste prevention, emissions reduction...) is key to ensure coherence with the overall aim of tackling Ref. Ares(2020)4001123 - 29/07/2020 2 environmental and climate impacts, thus avoiding the risk of undermining the overarching sustainability goals. • Pursuing the EU Green Deal’s objectives requires embracing a life-cycle approach to circularity, where climate and environmental performance is assessed throughout the entire life-cycle of packaging and product and where the role and the functionality of packaging are properly taken into account. The best recycling and disposal options should also be evaluated with a life-cycle approach of products and systems.

The best recycling and disposal options should also be evaluated with a life-cycle approach of products and systems. Problem definition With regards to packaging waste, the real issue that needs to be tackled is the generation of packaging waste that goes to final disposal or that is littered into the environment, not what is collected for recycling or reuse. In contrast to packaging that is reused or recycled and brought back to the market in the form of secondary raw materials, packaging waste going to final disposal represents a loss of resources. With regards to recycling, focusing only on packaging design will not solve the structural issues currently hindering effective competition between recycled and virgin materials, notably inadequate sorting, collection and recycling infrastructures as well as lack of enforcement and uneven implementation of existing EU legislation.

…and recycling infrastructures as well as lack of enforcement and uneven implementation of existing EU legislation. 1. Before looking at specific policy measures to further reduce packaging waste it is essential to start with an accurate baseline. • The figure mentioned in the Inception Impact Assessment of 173 kg of packaging placed on the market yearly per inhabitant includes packaging that is reused, recycled and recovered. It does not reflect the amount of used packaging that is sent to final disposal (i.e. incinerated or landfilled). Only the packaging waste sent to final disposal does not create further value from a circular economy standpoint and should, therefore, be used as baseline for considering further waste prevention measures. • A sole focus on packaging consumption reduction or on specific packaging formats (single use versus multiple use, single portion or multiple)…

…to the Green Deal ambitions on climate, circular economy and resilient food supply chains (i.e. food waste avoidance). 2. The lack of implementation of already existing legislation and inadequate recycling infrastructures are major obstacles to the achievement of waste recycling objectives. • Effective implementation of existing legislation and investments in infrastructure and innovation are key preconditions to the development of strong markets for secondary raw materials. Policy options cannot be focused solely on packaging design. • While packaging design can contribute to increased packaging recyclability, this depends first and foremost on the existing waste management and recycling infrastructures. Minimum requirements on harmonised end-of-life infrastructure are needed to boost recyclability.

…infrastructures. Minimum requirements on harmonised end-of-life infrastructure are needed to boost recyclability. 3. A narrow focus on end-of-life undermines the overall climate and environmental performance of packaging. • Product waste (including food) prevention is the most efficient way to improve resource efficiency and to reduce the environmental impact of packaging, as recognized by the EU waste hierarchy. • Packaging’s contribution to resource efficiency and product waste prevention should not be overlooked when looking at measures to further improve its overall environmental impacts. • Used packaging which is properly disposed, collected and recycled will become a resource and save carbon emissions. Policy options EUROPEN fully supports strengthening the Essential Requirements to strive for better enforcement of the existing provisions across the EU, while continuing to enable…

…so as to optimise its environmental performance and resource efficiency contribution from conception to end-of-life. 1. The Essential Requirements should continue to constitute the legal minimum requirement that all packaging must meet in order to be allowed to enter and freely circulate throughout the EU market. • The overarching principles underpinning the Essential Requirements (ER) need to be relevant for any type of packaging. Packaging materials shall be treated equally, in a non-discriminative way. • The requirement of all packaging to be reusable or recyclable by 2030 is fully supported by EUROPEN. For this purpose, Member States and the EU should refrain from restricting packaging that is already, or that will be recyclable, by that date. • The necessary return/separate collection, sorting and recycling infrastructure need to be in place in each EU Member State by 2030. • To…

…due consideration to the packaged products, such targets would also risk increasing product damage and hence its waste. 2. Packaging eco-design must remain industry-led, framed by enabling EU legislation. • Overly prescriptive requirements, including restrictions of specific packaging materials or formats, risk hindering much needed innovation and investments in eco-design and fail to deliver the right compromise between packaging functionalities and recyclability. They also risk to run counter to the goal of preventing product and resources waste. • Any new requirements need to be consistent with existing health and food regulations and should not jeopardise existing best practices linked to health and dietary considerations. • Producers need to remain free to choose the most appropriate packaging formats and materials for their products and its distribution systems (i.e.

…to choose the most appropriate packaging formats and materials for their products and its distribution systems (i.e. single use or reuse, single portion or multiple). • Policy objectives have to be achieved in a cost-effective way to avoid diverting resources away from industrial innovation processes. • Packaging functionality is particularly important for sensitive applications such as packaging in contact with food and beverages. The safety of food products and consumers is the first priority for the packaging supply chain and it is also what drives the search of the best sustainable solutions, e.g. for the further uptake of recycled content. The initiative by the Commission to establish rules for the safe recycling of used packaging into food contact materials is an important step to support this effort. 3.

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