PLASTALLIANCE "The European Plastics Alliance"

…68 Avenue du Général Leclerc [email protected] 09 63 58 62 94 www.plastalliance.org 72000 Le Mans www.plastalliance.info 1 Positions of Alliance Plasturgie et Composites du Futur PLASTALLIANCE on the PPWR Présentation of Alliance Plasturgie et Composites du Futur PLASTALLIANCE Alliance Plasturgie et Composites du Futur PLASTALLIANCE is a professional organisation created in the form of a trade union which brings together and defends the interests of the French plastics converters. It is the oldest representative organisation of the plastics sector (created on 01 May 2005).

…plastics converters. It is the oldest representative organisation of the plastics sector (created on 01 May 2005). PLASTALLIANCE is the only French representative organisation of the plastics industry to be a member of both the Circular Plastics Alliance (CPA) and the European Plastics Pact. Plastalliance works at the French and European level for the eco-responsibility of the sector: circular economy, eco-design, improvement of waste treatment, collection and sorting, fight against incivility and defend a plastic industry in a strictly European framework. Plastalliance is working for the harmonisation of European policy on the regulation of plastics and in particular plastic packaging.

…is working for the harmonisation of European policy on the regulation of plastics and in particular plastic packaging. Introductory remarks The stated objective of this PPWR, which is fully shared by Plastalliance, is to achieve a true circular economy for packaging (all materials and especially plastic) with two axes: Preventing waste and making packaging sustainable. This Proposal is taken in the framework of the European Green Deal and the new action plan for the circular economy. Ref.

Proposal is taken in the framework of the European Green Deal and the new action plan for the circular economy. Ref. Ares(2023)2864028 - 23/04/2023 68 Avenue du Général Leclerc [email protected] 09 63 58 62 94 www.plastalliance.org 72000 Le Mans www.plastalliance.info 2 The 5 main issues that have rightly pushed for the development of this draft PPWR regulation are the following: 1. Strong growth in waste quantities 2. Barriers to packaging circularity (with recycling rates for plastics too low in some member states, packaging labelling confusing for consumers and too many multi- materials)

…for plastics too low in some member states, packaging labelling confusing for consumers and too many multi- materials) 3. Upstream problem with weak circularity and downstream problem with poor quality and quantity of sorting. 4. Low levels of recycled material in packaging 5. Fragmentation of rules between different countries leading to a lack of profitability of recycling and a distortion of the internal market (the 1994 Directive, less binding than a Regulation, has proved to be particularly ineffective) The packaging is one of the main user sector of virgin materials (40% of plastics and 50% of paper are used in packaging), so there is pressure on resources, especially natural resources, and an impact on the trade deficit (oil/wood imports).

…so there is pressure on resources, especially natural resources, and an impact on the trade deficit (oil/wood imports). Waste management is currently considered inefficient with too much incineration, often avoidable for certain types of packaging, and scandalous landfill/burial, which in some countries are easy solutions and generate substantial revenues at the expense of the environment. Recycling is very important but it is necessary to reduce waste production where possible. The proposed new rules aim to curb these trends: Ensuring reusablepackaging options, avoiding unnecessary packaging and over- packaging, providing new clear rules (standardised labelling) to improve sorting as well as a framework for compostable bio-based plastic.

…new clear rules (standardised labelling) to improve sorting as well as a framework for compostable bio-based plastic. 68 Avenue du Général Leclerc [email protected] 09 63 58 62 94 www.plastalliance.org 72000 Le Mans www.plastalliance.info 3 The aim is to achieve zero waste to landfill and effective recycling or composting of single-use or reusable packaging at the end of its life cycle. Plastic is a key issue and there is much room for improvement in terms of recycling. Ecodesign criteria for recycled packaging to become quality secondary materials through return to packaging will give value to packaging waste.

…packaging to become quality secondary materials through return to packaging will give value to packaging waste. For this PPWR to be successful, it is necessary to: - That the obligations of the PPWR are subject to all member states in a non- differentiated and discriminatory manner (I) - Increased market surveillance (II) - A mass implementation of the deposit, with rules that allow access for all to the material and close involvement for a virtuous implementation of local authorities. (III) - Close involvement of stakeholders in consultations on the implementation of delegated acts (IV) There are of course technical points on which questions remain, but overall, the PPWR as presented, which is the result of undeniable work by the Commission services, is heading in the right direction.

…as presented, which is the result of undeniable work by the Commission services, is heading in the right direction. Europe will become the global hub for eco-designed plastics and a model for other countries around the world for plastics circularity and the fight against non- recycled waste. 68 Avenue du Général Leclerc [email protected] 09 63 58 62 94 www.plastalliance.org 72000 Le Mans www.plastalliance.info 4 I) The legal framework The legal basis of the draft Regulation is the internal market (Article 114 of the Treaty on the Functioning of the European Union, TFEU).

…the draft Regulation is the internal market (Article 114 of the Treaty on the Functioning of the European Union, TFEU). This is the right framework to have effective harmonisation and to avoid detrimental individual measures. To ask, as some do, that the Regulation should allow Member States to maintain or introduce national sustainability requirements other than those laid down in the Regulation is only a way to devitalise the Regulation and turn it into a hidden Directive with an “à la carte” application. The same causes will produce the same effects and the ineffective application of the 1994 Directive is already sufficient reason not to start again in the same direction.

…ineffective application of the 1994 Directive is already sufficient reason not to start again in the same direction. Furthermore, a Regulation that would be applied differently from one country to another would create a dangerous precedent in terms of European standards and would be a Pandora's box that would be used by the opponents of the common market. Finally, it should be remembered that identical rules on packaging throughout the EU will not only provide better visibility for European manufacturers but also for importers outside the EU and, in the end, it is the consumer who will be guaranteed the same level of requirements on his packaging from one EU country to another. Finally, the economies of scale in terms of standardisation of requirements will be a positive point to counteract the not inconsiderable cost of the circular transition requested from European manufacturers.

…point to counteract the not inconsiderable cost of the circular transition requested from European manufacturers. 68 Avenue du Général Leclerc [email protected] 09 63 58 62 94 www.plastalliance.org 72000 Le Mans www.plastalliance.info 5 II) Strong monitoring of the internal market In our view, this monitoring should be twofold: On the one hand, ensuring that importers outside the EU are effectively monitored, as it would be unacceptable to find that non-EU manufacturers continue to import and distribute packaging that does not comply with the new standards set by the PPWR, packaging manufactured at low cost and in questionable social conditions, while at the same time European manufacturers have made the effort to invest massively in a genuine circular economy for packaging, and they will ultimately be the only ones monitored.

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