European Insulation Manufacturers Association

Eurima welcomes the opportunity to provide feedback on the calculation and verification of recycled content under the Packaging and Packaging Waste Regulation. We support a robust methodology grounded in verified physical material flows that protects fair competition and rewards investment in recycling. Please find our detailed recommendations attached.

Eurima welcomes the Commissions ambition to simplify environmental legislation and acknowledges the need to reduce unnecessary administrative burdens. Please refer to our Position Paper with Annex for a complete overview of our recommendation. It is attached to the consultation and focuses on 4 clusters of topics: 1) EPR Simplification: >align EPR with harmonised definitions established at EU level, while ensuring a pragmatic approach considering the existing national reporting experiences >gradually phase in EPR schemes and avoid hindering a level playing field in the European single market >align exemptions identified under the PPWR with national EPR systems to avoid discrepancies, and/or…

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Eurima (European Mineral Wool Insulation Manufacturers) supports the efforts of the European Commission on the revision of the requirements for packaging and packaging waste. Our industry is committed to constantly improve the packaging of our products by reducing the use of “fossil based/virgin plastic” and increase the recycle content when it is technically feasible and economically viable. From our point of view, it is important to take into account the expected and necessary technical performance of certain packaging when considering the recycled content of such packaging (tensile strength, resistance to UV radiation, etc.). For example, in our specific case, MW products are highly…

EU Green Deal, Fit-for-55% Package, Energy Efficiency Directive, Energy Performance of Buildings Directive, EU Climate Law, EU-ETS, EU-ETS for Buildings, EU Renovation Wave, EU Climate & Energy Policy, EU Sustainable Finance/Taxonomy, Circular Economy, Sustainability Assessment of the built environment, CPR & CEN-standardisation, Sustainable Construction, Occupational and Product Health & Safety, Chemicals (REACH, CLP), Energy taxation, Industrial Emissions Directive / BREF.