Packaging and packaging waste

TOMRA, the leading solutions provider for the collection and sorting of waste for reuse and recycling, welcomes the Packaging and Packaging Waste Regulation proposal by the European Commission, which sets ambitious but achievable goals during a timeframe to enable investment.

About Trioworld Trioworld has been a leader in plastic packaging solutions for more than 50 years and we are producing transport-, consumer- and industrial packaging. We are also producing high-performance plastic film for other uses. Trioworld consists of 16 companies with more than 1,800 employees.

Reloop welcomes the possibility to provide feedback on the recently proposed revision of the Packaging and Packaging Waste Directive. We commend the Commission's efforts and the level of ambition introduced in the new proposal, which will help reduce the ever-increasing amount of packaging waste and facilitate the development of a circular economy.

Introduction: The Brewers of Europe is the trade confederation uniting 28 national brewers' associations to promote and represent the interests of Europe's ten thousand beer breweries. The elimination of waste and the creation of a truly circular economy have been on the agenda of European brewers since well before the European Union defined this as one of its flagship initiatives.

Eurochambres generally welcomes the European Commission's proposal for a packaging and packaging waste regulation, which aims to advance a circular economy. This regulation offers an important opportunity to reduce waste, minimize environmental degradation, and lower processing and transportation costs.

Women Engage for a Common Future, WECF, welcomes the EU Commission's proposal to revise the EU Packaging & Packaging Waste Regulation (PPWR). The European Commission's proposal for a new PPWR contains good approaches, but it is not yet ambitious enough and leaves out several important points. WECF calls on EU authorities to tighten up rules on harmful chemicals in packaging.

EPAL supports the European Commission's proposal for the EU Packaging & Packaging Waste Regulation (PPWR), which was published on 30.11.2022. The objectives of preventing and reducing packaging and promoting the sustainability of packaging by introducing and harmonising provisions for the reuse and recycling of packaging are identical to the objectives that EPAL has been pursuing since 1991 in the open EPAL Euro…

Sappi, a leading provider of renewable fibre-based products, supports the goals of the Packaging and Packaging Waste Regulation (PPWR) proposal. However, we offer the following suggestions to improve the proposal: - We recommend that the proposal be evaluated against the Innovation Principle to increase the role of innovation.

OceanCare welcomes the Commissions proposal for the revision of EU rules on packaging and packaging waste. The proposed conversion from a Directive to a Regulation is a welcome signal that the EU is willing to streamline and strengthen its actions on packaging and packaging waste.

April 24, 2023 European Commission Brussels, Belgium Re: PLASTICS Industry Association Response: Proposal for a Regulation on Packaging and Packaging Waste Dear Sir or Madam: The Plastics Industry Association (PLASTICS), through its Food, Drug, and Cosmetic Packaging Materials Committee (FDCPMC), 1 is responding to the European Commission’s public consultation “reducing packaging waste – review of rules,” including…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The International Fresh Produce Association (IFPA) welcomes the opportunity to provide feedback on the European Commissions initiative to review the requirements for packaging and other measures to prevent packaging waste.

Women Engage for a Common Future, WECF, welcomes the Commission’s proposal for a revision of the EU Packaging Regulation, Packaging Waste Regulation (PPWR). The European Commission’s proposal for a new PPWR contains good approaches but is not yet ambitious enough and ignores some important points. WECF calls on EU authorities to introduce stricter rules on harmful chemicals in packaging.

Filed in German · English published by the European Commission

The European Commission's goal of reducing packaging and packaging waste is welcomed by the VOA - Association of Public Waste Management Companies. It is questionable whether a regulation is an appropriate instrument to achieve the desired goals. From the waste management sector's point of view, many points of regulation could be implemented in already existing legal frameworks.

Grow international, the European organisation of wooden packaging manufacturers,welcomes the PPWR proposal but would like to highlight the following specific topics and we hope these elements will be considered. 1- Overall, we think that it is crucial to recognise the packaging renewable and circular materials contribution to climate neutrality.

Following the submission of the proposal for a Regulation on Packaging and Packaging Waste, ZERO has submitted its opinion. While the proposal generally reinforces obligations at different levels and presents, for the first time, concrete targets in key areas such as prevention and re-use, its lack of ambition in multiple areas, as well as its current unique justification based on justifications linked to the single…

Filed in Portuguese · English published by the European Commission

McDonald’s feedback submission to the consultation on the PPWR Executive Summary McDonald’s supports the overall goals of the European Green Deal- in particular that of achieving a circular economy. It is for this reason that we have grown increasingly concerned over the last few months about the proposal on the Packaging and Packaging Waste Regulation (PPWR).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Economic Association of Non-Alcohol-Free Drinks (wafg) supports the Commission’s fundamental objectives of improving the environmental prospects of packaging by means of this proposal and of strengthening the common market by means of a single regulation at European level.

Filed in German · English published by the European Commission

IFF, an innovator in sustainable solutions in the food, beverage, health, biosciences and fragrances industries welcomes the publication of the proposal on PPWR and its ambition to make packaging more sustainable by reducing overpackaging, and increasing recycling rates and re-use.

The Spanish Cosmetics, Toiletry and Perfumery Association (STANPA) Position Paper on the Packaging and Packaging Waste Regulation (PPWR) Proposal. April 2023. SPECIFIC REMARKS AND RECOMMENDATIONS 1. GENERAL PROVISIONS • Legal Basis and harmonization The Spanish Cosmetics, Toiletry and Perfumery Association (STANPA) was founded in 1952.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ecommerce Europe welcomes the publication of the proposal for a Regulation on Packaging and Packaging Waste. We are supportive of the European Commissions ambition to clarify and harmonise packaging rules across the EU, while proposing to raise ambition to improve the sustainability of packaging and the reduction of packaging waste.

The German Biogas Association (GBA) welcomes the opportunity to comment on the Commissions public consultation on the revision of the packaging and packaging waste directive. The GBA supports the efforts of revising this directive as it contributes to a circular economy and helps reaching some of the goals outlined in the EU Green Deal and the Zero Pollution Action Plan.

Filière Française du Cuir wishes to clarify Annex I to the European Regulation on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC, which lists items falling within the definition of packaging and items not constituting packaging.

Filed in French · English published by the European Commission

The Product Responsibility Industry Initiative (Brancheninitiative Produktverantwortung, BIPV) is a community of interest of manufacturer-supported take-back systems, which includes RIGK GmbH, GVÖ Gebinde-Verwertungsgesellschaft der Mineralölwirtschaft mbH and KBS Kreislaufsystem Blechverpackung und Stahl GmbH.

Environmentalists in Action welcomes the European Commission’s proposal for a Regulation on Packaging and Packaging Waste. However, Ecologistas en Acción is concerned about the lack of effective and decisive measures to remove chemicals of concern from packaging, and considers the proposed labelling measures insufficient.

Filed in Spanish · English published by the European Commission

The European Footwear Confederation (CEC), the voice of the European Footwear industry, welcomes the efforts of the European Union to reach the sustainability goals set in the EU Green Deal and continues committed to contribute to the green and digital transitions.

Comentarios de la Asociación de Aguas Minerales de España (ANEABE) a la consulta pública de la Comisión Europea sobre la propuesta de Reglamento sobre envases y residuos de envases La Asociación de Aguas Minerales de España (ANEABE) considera necesaria la revisión de la Directiva de la UE sobre envases y residuos de envases como una forma de avanzar hacia la eficiencia de los recursos, en consonancia con el Pacto…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The associations of Spains paper and board (P&B) value chain - AFCO, ASPACK, ASPAPEL y REPACAR - acknowledge the European Commissions proposal for a Packaging and Packaging Waste Regulation, and look forward to supporting an evidence-based regulatory approach during the next stages of the legislative process. Both recyclable and reusable items have a role in the transition to a circular economy.

April 24th, Madrid Position of AFCO-ASPACK-ASPAPEL-REPACAR on the proposal for a Packaging and Packaging Waste Regulation (PPWR) The associations of Spain’s paper and board (P&B) value chain - AFCO, ASPACK, ASPAPEL y REPACAR - acknowledge the European Commission’s proposal for a Packaging and Packaging Waste Regulation, and look forward to supporting an evidence-based regulatory approach during the next stages of…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

This feedback is based on the position paper presented by the Rethink Plastic Alliance (RPA) and includes some extra points conferred by Sciaena an ocean conservation NGO from Portugal to be considered as improvements for the Packaging and Packaging Waste Regulation (PPWR) proposed by the European Commission.

1 TomatoEurope represents the tomato processing industry covering more than 95% of the European business. Active since 1979, it acts as an umbrella organization for national associations, indirectly representing more than 200 tomato processing entities. TomatoEurope welcomes the initiative from the Commission to further combat packaging waste and increase packaging circularity across the European Union.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Wood packaging products and pallets are an indispensable part of all supply chains, as they are essential for the functioning of the internal and global markets, as well as for the supply of food, medicines and everyday consumer goods, as well as for the needs of the domestic and export industries, as tertiary transport packaging. A single market rather than national opening clauses is essential.

Filed in German · English published by the European Commission

PCEP welcomes the proposal from the European Commission on the revision of packaging rules in the EU. PCEP embraces the EU Green deal and agrees and welcomes the overall approach to reduce the environmental impact of packaging, without forgetting the importance of the internal market for the EUs competitiveness and prosperity.

The Bundesverband Naturkost Naturwaren (BNN) e.V. represents manufacturers, wholesalers and retailers of the organic industry in Germany, Austria, Switzerland and the Netherlands. Many of the organic products manufacturing and trading companies have been working for years to make the packaging used more sustainable and have in some cases also triggered and driven developments, for example in the reusable or…

Filed in German · English published by the European Commission

The Spanish Association of Pulp and Paper Manufacturers - ASPAPEL acknowledges the European Commissions proposal for a Packaging and Packaging Waste Regulation, and looks forward to supporting an evidence-based regulatory approach during the next stages of the legislative process. Both recyclable and reusable items have a role in the transition to a circular economy.

AIM, the European Brands Association, welcomes the European Commissions proposal on the Packaging and Packaging Waste Regulation (PPWR). The branded consumer goods industry acknowledges the need for change and wants to be a driving force in the transition to a clean, circular and climate-neutral economy.

Metal Packaging Europe (MPE), the European association representing rigid metal packaging (steel and aluminium), supports the European Commissions objective that all packaging on the EU market be reusable or recyclable in an economically viable way by 2030 as mentioned in the Green Deal and the Circular Economy Action Plan (CEAP) 2.0 and supported by the European Parliament in its resolution on 28 February 2021.

DuPont position on the draft Packaging and Packaging Waste Regulation Key messages: 1. Keep Regulation as the legal basis for the packaging legislation 2. Extend exemption of medical packaging from the recycled content targets in Art. 7 to the supply chain to include critical raw materials, parts, and components delivered to the medical and pharmaceutical industries. 3. Add digital label in Art.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ball Beverage Packaging welcomes the European Commission's Packaging and Packaging Waste Regulation (PPWR) published on November 30th 2022 and recognizes the effort to help make Europe less dependent on primary resources and external suppliers and put the packaging sector on track for climate neutrality by 2050. In this position paper, Ball wants to highlight some remarks on the proposed legislation. 1.

The Finnish Biocycle and Biogas Association promotes nutrient recycling and the use and development of Biogas technology and its knowledge in the society. We welcome the Circular Economy Action Plan and the aim to contribute to the circular economy through the review of the requirements for packaging and packaging waste.

Filed in Finnish · English published by the European Commission

1 EPBA Position Paper on the PPWR The European Portable Battery Association (EPBA) is the leading organisation representing the interests of primary and rechargeable portable battery manufacturers, industries using portable batteries in their products and distributors of portable batteries active within the European Union and beyond.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Representing more than 100 suppliers of fertilisers and innovative inputs of sustainable plant crops, AFAla is the French trade union of operators in the cultivation media, mulching, organic soil improvers, organic and organo-mineral fertilisers and biostimulants sector.

Filed in French · English published by the European Commission

Lassociation of the ATLA dairy processing represents the private and cooperative French dairy processing companies. We thank the European Commission for this opportunity to participate in the discussions on this legislative proposal.

Filed in French · English published by the European Commission

DEAR Sir or Madam, The German Fruit Trade Association represents the interests of companies from all trade sectors in the supply chains for fresh fruit and vegetables. We would like to thank you for the opportunity to comment on the draft regulation on packaging and packaging waste amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC. Please find attached our comments.

Filed in German · English published by the European Commission

AMETIC welcomes the harmonization efforts in the Proposal Regulation for packaging and packaging waste and a more circular economy. However, some measures in the PPWR proposal raise concerns regarding their technical feasibility and practicality. A well-designed regulation is key to support the transition to a circular economy.

SUEZ welcomes the European Commissions proposal on the packaging and packaging waste regulation. In this position paper SUEZ wants to highlight some remarks on the proposed legislation. There should be an obligation to extend a minimum of recycled content in packaging for all kinds of materials (paper, cardboard, and glass) and not only to plastic.

Artikel 7 (Minimum recycled content in plastic packaging): Ten German and international business associations from the entire value chain as well as the Wuppertal Institute for Climate, Environment and Energy support a more flexible use of recyclates without weakening the intended security of demand for recyclates.

April 24th, Madrid Repsol’s position on the revision of the Packaging and Packaging Waste Regulation (PPWR) Repsol welcomes the opportunity to provide feedback on the European Commission’s initiative to review the Packaging and Packaging Waste Regulation (PPWR) aiming to support the circular economy by boosting the use of recycled materials instead of primary raw materials, reducing our dependencies on raw materials…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Berlin, 24. April 2023 Bundesverband Großhandel, Außenhandel, Dienstleistungen e.V. Am Weidendamm 1A 10117 Berlin Telefon [phone removed] Telefax 030 590099-519 www.bga.de [email removed] Autor: Dr. [name removed] Umwelt- und Energiepolitik [email removed] Vorschlag für eine Verordnung über Verpackungen und Verpackungsabfälle, zur Änderung der Verordnung (EU) 2019/1020 und der Richtlinie (EU) 2019/904 sowie zur…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Viatris is a global healthcare company, supplying 36.8 billion doses of medicine annually in Europe. Our portfolio comprises more than 1,400 approved molecules across a wide range of therapeutic areas, spanning generics, complex generics, and branded medicines.

Malta is the smallest EU member in both size and population. the issue of a regulation , as in this case, with a one size fits all places Maltese producers represented by Authorised Packaging Organizations under undue duress when it relates to full compliance of the Articles outlined to this regulation, more and more when these producers are in a majority importers only and not manufacturers.

The Reusable Alliance considers the draft Packaging and Packaging Waste Regulation (PPWR) as an important step towards reducing unnecessary packaging waste. The Alliance welcomes the setting of mandatory reusable quotas at EU level for the first time.

Filed in German · English published by the European Commission

Unijus, the Union nationale interprofessionnel des juices de fruits, supports the position of its European trade union (AIJN) on the PPWR, in particular on issues relating to the reuse of packaging. Unijus represents French manufacturers and processors of fruit juices and nectars, and other ‘similar products’ covered by the EU Fruit Juices Directive.

Filed in French · English published by the European Commission

EU Domestic Glass Position on the proposal for a revision of the Packaging and Packaging Waste Directive The current exemption granted to lead crystal glass in the current Directive is removed. It seems that it is left to be potentially re-enacted via a delegated act.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eastman is pleased with the ambitious targets in the proposal that are in line with the waste hierarchy, namely reduce, reuse, and recycle (3R), in particular, the ambition for all packaging to be recyclable and the introduction of the recycled content targets. Compostable or biodegradable plastics may provide a sustainable solution where 3R concept is not applicable.

SERRED, the European association representing, defending and promoting the interests of industrial packaging reconditioners, welcomes the European Commissions ambitions to reduce packaging waste via its proposal for a Packaging and Packaging Waste Regulation (PPWR). We agree with the proposals objective to reduce waste by promoting reuse and refill of packaging on the EU market.

Why we need a PVC ban in packaging. The packaging of the future needs to be circular and material healthy. To do so, we need to start directly with design: When designing the product, the use scenario must be taken into account to allow the product to be either fully disassembled and recyclable, so that it can circulate in the technosphere or enter the biosphere as a biodegradable product.

Filed in German · English published by the European Commission

The proposed Packaging and Packaging Waste Regulation offers an important opportunity for implementing the EUs ambitious goals as laid out in its Farm To Fork Startegy (F2F), Chemical Strategy for Sustainability (CSS) and its Circular Economy Action Plan (CEAP) regarding the reduction of adverse environmental and human health impacts from packaging.

Kimberly-Clark is a global leader in the development and production of Absorbent Hygiene Products (AHPs), including baby nappies, period products, adult diapers, and tissue paper for private and professional use.

EuromContact strongly supports the general objective for the revision of Directive 94/62/EC on Packaging and Packaging Waste to transform it into a regulation and tackle the environmental impact of packaging and packaging waste. The contact lens and lens care manufacturers have substantially minimized the packaging for their products.

L'Union des Maisons et Marques de Vin (UMVIN) supports the efforts to tackle packaging waste, plastic pollution and to reduce the environmental impact of packaging across the EU. We welcome the choice of the regulatory instrument Regulation rather than a Directive allowing for better harmonisation and preventing circularity obstacles for the wine industry within the EU market.

FruitVegetablesEUROPE and its members are committed to achieve the EU's climate neutrality target by 2050, advocating that the new EU packaging law should maintain the competitiveness of the European agri-food market with science-based solutions and an economic and social impact assessment with real results for sustainability.

Innocent drinks Position paper on the proposal for a Regulation on Packaging and Packaging Waste (PPWR) About innocent Drinks • • innocent drinks have been on a mission to make it easy for people to do themselves some good. We get our hands on the tastiest fruit and veg we can find, stick it in a bottle and never add any nonsense like sugar. We sell our tasty little drinks in 18 markets, mainly in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

4evergreen is an alliance of 100 manufacturers, designers, brand owners, researchers and recyclers who want to contribute to a climate neutral society by perfecting the circularity and sustainability of fibre-based packaging. The goal is to reach a 90% recycling rate for fibre-based packaging by 2030.

FoodDrinkEurope supports the general objectives set in the new Packaging and Packaging Waste Regulation (PPWR) of ensuring a well-functioning Internal Market through fully harmonised rules on packaging while tackling the packaging environmental impact.

Orgalim represents Europes technology industries, providing innovative technology solutions which are underpinning the twin green and digital transitions and can unlock a greener, healthier and more prosperous future for the European Union and its citizens. Here is the executive summary of Orgalim recommendations on the Commission proposal for a new Regulation on Packaging and Packaging Waste.

ANAIP Proposed Amendments to Regulation EU on packaging and packaging waste - April 24th, 2023 Kindly note the following important instructions when completing the table: • • • • Do not delete any lines or squares from the table; Do not insert any new lines or squares; Insert your comments into the 2nd and 3rd columns of the table only, in the line/square corresponding the provision concerned.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

COLEAD RESPONSE TO PUBLIC CONSULTATION ON THE EU PROPOSAL FOR A REGULATION: “REDUCING PACKAGING WASTE – REVIEW OF RULES” April 2023 The Committee Linking Entrepreneurship-Agriculture-Development (COLEAD) thanks the European Commission for the opportunity to contribute to this consultation process on behalf of our members.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Environmental Action Germany (DUH) welcomes the revision proposal for the Directive on packaging and packaging waste (94/62/EC), which has been in force since 1994, and its conversion into a Regulation, as an important step towards true and sustainable change in the packaging industry.

Position du MEDEF relative au projet de règlement sur les emballages et déchets d’emballages Un cadre législatif mature à réformer dans la continuité Cela fera bientôt 30 ans que l’Union européenne a adopté sa première législation relative aux emballages et déchets d’emballages.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

APRIL 2023 Proposal for a Regulation Of The European Parliament And Of The Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC Position paper Summary of policy asks Article 5: requirements for substances in packaging • Amend Article 5 to void duplication with existing chemicals and food safety EU legislation by referencing…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

At Teva Pharmaceuticals, our mission is to improve the lives of patients across the globe. In Europe, Teva is a strategic partner of healthcare systems, producing 96 % of its European generic, biosimilar and innovative portfolio in plants across 15 European countries. As a company focused on improving the health of patients, the environment has always been central to Teva.

The California Cherry Board (CCB) is writing to provide comments regarding the Proposal for a Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. Thank you for the opportunity to provide input in this process.

The Reuse Alliance (Mehrweg-Allianz) is a coalition of Deutsche Umwelthilfe e.V. (DUH), the Association of German Beverage Wholesalers (BV GFGH), Private Breweries in Germany (Private Brauereien Deutschland), the Association of German Retail of Beverages(VDGE), Foundation for Reuse (SIM) and the Initiative for the promotion of reusable packaging (Pro Mehrweg).

EsPlásticos Proposed Amendments to the Packaging and Packaging Waste Regulation (PPWR) European Commission Proposal (6) Plastic packaging is the most carbon-intensive material and, in terms of fossil fuel use, recycling of plastic waste is approximately five-times better than incineration with energy recovery.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The LEGO Group aims to make a positive impact on the planet our children will inherit and is committed to creating more sustainable and circular products and packaging, reducing our environmental footprint and inspiring children to learn about sustainability while co-creating solutions with and for them.

Independent Retail Europe membership supports the stated objectives of the European Green Deal, the Circular Economy Action Plan, as well as the global objectives of the new Packaging and Packaging Waste Regulation (PPWR). We therefore welcome the Commissions objective to gradually harmonise packaging rules across the EU.

Ecoteca, one of Romania’s oldest environmental NGOs (active since 2010) and among the few NGOs specialising in waste management, circular economy and climate impact, welcomes the proposal to revise the EU rules on packaging and packaging waste. In particular, we support the proposed targets on waste prevention and reuse, increase recycled content in packaging and reduce over-packaging.

Filed in Romanian · English published by the European Commission

Statement 24 April 2023 Feedback regarding the proposal for a regulation on packaging and packaging waste We thank the Commission for the opportunity to provide feedback concerning the proposal for a regulation on packaging and packaging waste. This paper is the EuroCommerce feedback for the consultation about the adopted act.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Bioenergia ry, the Bioenergy Association of Finland, believes that favouring reusable packaging at the expense of recyclable alternatives risks promoting fossil-based material cycles vs. bio-based material cycles.Such an approach fails to identify the benefits of replacing fossil materials.

AVEC, CLITRAVI and UECBV welcome the opportunity to get consulted on the European Commission's proposal for a regulation on packaging and packaging waste, amending regulation (EU) 2019/1020 and directive (EU) 2019/904, and repealing directive 94/62/EC. Our joint feedback is available in attachment.

The Federation of European Manufacturers of Cookware and Cutlery (FEC) supports the Packaging and Packaging Waste Regulation (PPWR) proposal, which aims to ensure the efficient functioning of the internal market for packaged goods while reducing the impact of packaging waste on the environment and human health.

Arnika's mission is to promote environmental health, prevent toxic pollution within the European and global context. Arnika aims to eliminate the use and releases of POPs and other toxic chemicals in the Czech Republic as well as globally.

AESGP, the Association of the European Self-Care Industry, represents the manufacturers of non-prescription medicines, food supplements, and self-care medical devices in Europe, an area also referred to as self-care or consumer healthcare products. Please find AESGPs detailed comments in the attached file.

Norway welcomes and support the EU Commissionss proposal for a regulation on packaging and packaging waste. We appreciate the opportunity to share our view concerning the following two aspects of the proposal, namely the proposal oncompostable very lightweight plastic carrier bags and harmonised symbols.

Our company is heavily involved in reducing packaging and packaging waste, and in particular has contributed to several developments in the Bag in Box in recent years to ensure that: packaging as a whole requires fewer raw materials for its manufacture, the cardboard part is easily separable from the plastic pocket; these 2 elements are recyclable at the best level separately after use by the consumer; the inner…

Filed in French · English published by the European Commission

Dear Sir/Madam, please find enclosed the position paper of the French Confederation of Small and Medium-sized Enterprises (CPME) on the proposal for a Regulation on packaging and packaging waste. Best wishes, Mr [name removed]

Filed in French · English published by the European Commission

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe, welcomes the Commissions legislative proposal on Packaging and Packaging Waste, as it reaffirms recycling as the core element of circularity.

Position on the Packaging and Packaging Waste Regulation (PPWR) by the Confederation of Swedish Enterprise This document contains the Confederation of Swedish Enterprise’s (hereafter Swedish Enterprise) position on the Packaging and Packaging Waste Regulation. Swedish Enterprise is Sweden’s largest business federation, representing over 60 000 member companies in all sectors with almost two million employees.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EPPA would like to highlight that: The current PPWR proposal on reuse targets is not achieving the best environmental, economic, and hygiene outcomes. To achieve the Green Deal objectives, the PPWR must be refined to include single-use paper packaging as a central pillar to achieve the EUs circular economy goals. Disposable paper packaging is a renewable and recyclable solution to food packaging.

Le 24 avril 2023 Position de la FEBEA dans le cadre de la consultation publique sur la proposition de Règlement relative aux emballages et aux déchets d'emballages La FEBEA rassemble et représente plus de 300 entreprises fabricantes vendant en France et à l’international des produits cosmétiques au sens du règlement CE n°1223/2009 (parfums, maquillage, produits pour la coiffure, produits de soins et produits…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Proposition de réglementation - révision de la réglementation relative à la réduction des déchets d’emballage - EU La Commission est en cours de révision des exigences relatives aux emballages et aux déchets d’emballages dans l’UE et notamment en évaluant comment : • améliorer la conception des emballages afin de favoriser le réemploi et le recyclage, • accroître la teneur en matière recyclée des emballages, •…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Comments by Sociedade Ponto Verde on the Proposal for a Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC – (PPWR)

Filed in Portuguese · English published by the European Commission

The Austrian Federal Economic Chamber would like to thank you for the opportunity to comment on the draft Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC. Please find attached a detailed opinion on the proposal. Yours sincerely, [name removed]

Filed in German · English published by the European Commission

CONTRIBUTION DU COMITE CHAMPAGNE A LA CONSULTATION PUBLIQUE DE LA COMMISSION EUROPEENNE SUR LA PROPOSITION DE REGLEMENT RELATIF AUX EMBALLAGES ET AUX DECHETS D’EMBALLAGES Le Comité Champagne est l’interprofession représentative des vignerons et maisons de Champagne. Il travaille quotidiennement en faveur de 16 200 vignerons, 130 coopératives et 370 maisons de Champagne, dont il représente les intérêts.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PRE, the association representing the plastic recycling industry at the EU level, welcomes the European Commissions (EC) proposal for a Regulation on Packaging and Packaging Waste (PPWR) as an effective instrument to reinforce the essential requirements for packaging materials, address packaging waste generation, and increase the circularity of materials used in packaging.

We welcome the Circular Economy Action Plan and the aim to contribute to the circular economy through the review of the requirements for packaging and packaging waste. Fibre-based packaging supports circular economy, European resilience and climate change mitigation.

The Association of Management Undertakings of Waste and Special Resources ASEGRE, as a representative of industrial waste management activities in general and industrial packaging waste in particular, considers that the regulation on packaging and packaging waste provides that reusable packaging is to be kept in use after conditioning until it loses the conditions for re-use, without at any time being waste.

Filed in Spanish · English published by the European Commission

IKEA supports the efforts of the proposed Regulation for Packaging and Packaging Waste (PPWR), published by the European Commission on 30 November 2022. We applaud the decision to change the Directive to a Regulation and anchor the proposal under the Internal Market legal base, which will bring increased harmonization, support further strengthening of the EU Single Market, and decrease complexity for European…

We welcome the Commissions proposed renovation of PPWD with open hands, especially the explicit reuse and prevention targets that are so rarely proposed yet key for a successful move towards more circular packaging. They should be higher though, as for example a 5 % decrease will only undo a few years' worth of growth of packaging waste amounts.

European Power Tool Association (EPTA) statement on the European Commissions proposal for a Regulation on packaging and packaging waste EPTA, the European Power Tool Association, represents 25 European power tool manufacturers and 90% of all corded and cordless power tools sold in Europe. Power tools are used by professionals, skilled tradesmen and DIY consumers.

This submission is made by the European Specialist Sports Nutrition Alliance (ESSNA), the trade association representing the voice of the active and sports nutrition sector in Europe. ESSNA and its members are already taking a leading role in accelerating the industry's transition to sustainability, as manifested in the industry's Sustainability Pledge: Lifting the Planet.

Farmindustria, the Italian Association of Pharmaceutical Companies representing about 200 member companies operating in Italy, welcomes the opportunity to share our feedback on the Commission Proposal on the Packaging and Packaging Waste Regulation. Farmindustria supports the European Green Deal and the EU circular economy, one of its building blocks.

Vorschlag für eine Verordnung des Europäischen Parlaments und des Rates über Verpackungen und Verpackungsabfälle, zur Änderung der Verordnung (EU) 2019/1020 und der Richtlinie (EU) 2019/04 sowie zur Aufhebung der Richtlinie 94/62/EG COM(2022) 677 final : I. Grundsätzliche Bewertung Der Verband Private Brauereien Deutschland e.V.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

This is a submission on behalf of the German NGO Alliance Exit Plastik. Members of Exit Plastik, who developed this paper are: a tip: tap e.V., Bund für Umwelt und Naturschutz Deutschland e.V., Forum Umwelt und Entwicklung, Greenpeace e.V., HEJSupport e.V., Küste gegen Plastik e.V., Surfrider Foundation Germany e.V., Women Engage for a Common Future e.V. (WECF), Zero Waste Germany e.V. und Zero Waste Kiel e.V.

The Packaging and Packaging Waste Regulation (PPWR) is an opportunity to make waste a resource in the EUs circular economy. Ambitious recycled content targets in the PPWR will ensure that waste has value enabling the further scale-up of recycling in the EU. This benefits the environment, the economy and reduces the EUs reliance on imports of virgin fossil raw materials to produce plastics.

Please find attached ASOBIOCOM’s comments on the Commission proposal for a Regulation on Packaging and Packaging Waste. We are grateful for the possibility to send them. The Spanish Association of Biodegradable and Compostable Plastics (ASOBIOCOM) targets biodegradable and compostable plastics and their transforms, mainly in packaging applications and agricultural applications.

Filed in Spanish · English published by the European Commission

Feedback on the Packaging and Packaging Waste Regulation proposal from Plastic Change (Denmark) Plastic Change warmly welcomes the proposal from the EU Commission on the Packaging and Packaging Waste Regulation (PPWR). The proposal takes important steps towards ambitious waste prevention by setting specific targets on waste prevention as well as targets for reuse.

We welcome the European Commission's suggestion to promote reuse and refill of packaging. However, the approach requires clarification and strengthening to ensure that they can deliver their full potential for waste prevention.

The Global Organization for Polyhydroxyalkanoates (GO!PHA) is a non-profit science, advocacy, and networking platform promoting the proliferation of PHA biopolymers. PHA Biopolymers are renewable and biodegradable, home and industrially compostable, and an excellent replacement for many plastic materials.

APEAL, representing the steel for packaging sector, fully supports Commissions objective that all packaging on the EU market be reusable or recyclable in an economically viable way by 2030, as stipulated by the Green Deal and the Circular Economy Action Plan (CEAP) 2.0. Our sector welcomes the general approach taken by the Commission but believes that more is to be done to fully close the circular loop.

SCS fully supports the objectives of the PPWR proposal, including preventing or reducing adverse impacts on the environment, and in particular increasing recycling and the use of recycled materials while reducing other forms of recovery and disposal after all options to prevent waste have been exhausted.

24 April 2023 Submission of Energy Drinks Europe (EDE) on the proposal for a Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC (Packaging and Packaging Waste Regulation, PPWR) KEY SUMMARY • • • • • • • • Energy Drinks Europe (EDE) is the leading representative trade association of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

F.E.E.D.M. Statement EU proposal for a revision of the EU legislation on Packaging and Packaging Waste F.E.E.D.M. welcomes this public consultation and the opportunity to provide comments on the Commissions proposal for a revision of the EU legislation on Packaging and Packaging Waste. F.E.E.D.M. represents the interests of the European honey packers and distributors, mainly small and medium-sized enterprises (SME).

The Polish Union of the Cosmetics Industry welcomes the change of the legal act from a directive to a regulation, while maintaining the legal basis of the single market. The proposed amendment will make it possible to harmonize packaging rules in the Member States and avoid fragmentation of the single market, proliferation of systems and national rules.

Input BVNL on the Proposal for the Packaging and Packaging Waste regula on of the European Commission The Business packaging founda on of the Netherlands, BVNL, represents the companies that supply packaged products to other companies (Business-to-Business). The industrial packaging of these companies follows a different path compared with consumer packaging.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Brussels, 23 March 2023 CEEV POSITION ON PACKAGING AND PACKAGING WASTE (PPW) PROPOSAL OF REGULATION DIRECTIVE (PPWD) REVIEW The Comité Européen des Entreprises Vins (CEEV – www.ceev.eu) represents the wine companies in the industry and trade in the European Union: still wines, aromatised wines, sparkling wines, liqueur wines and other vine products.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Waren-Verein der Hamburger Börse e.V. Honig-Verband e.V. Große [address removed] Telefon [phone removed] Telefax [phone removed] [email removed] www.waren-verein.de [email removed] www.honig-verband.de JG/zk/hs 24. April 2023 Positionspapier des Waren-Vereins der Hamburger Börse e.V. und des HonigVerbandes e.V.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

please find enclosed the position of the Association of National Software Producers (KUPS) on the draft Regulation on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC (COM(2022) 677 final), and we would also like to inform you that we support the position of the European Fruit Juice Associaton (AIJN), which we attach as supporting material.

Filed in Polish · English published by the European Commission

Tackling the global packaging waste crisis requires cross-sector collaboration and alignment on common principles and targets. Coca-Colas global packaging strategy called World Without Waste, is anchored by three fundamental goals: collection, design and partnerships, that are being delivered together with the bottling companies in Europe, Coca-Cola Europacific Partners and Coca-Cola Hellenic Bottling Company…

Návrh nařízení o obalech a obalových odpadech, o změně nařízení (EU) 2019/1020 a směrnice (EU) 2019/904 a o zrušení směrnice 94/62/ES – připomínky Hospodářské komory ČR Návrh revize evropské obalové legislativy se zaměřuje na snížení množství obalů dostupných na trhu a předcházení vzniku obalového odpadu pomocí nových opatření, která zvýší míru opakovaného použití a opětovného plnění, zaved minimalizaci obalů a…

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

2023-04-24 European Commission Submitted via feedback portal RE: Reducing Packaging Waste - Review of Rules erthos inc., is an advanced material science company that provides innovative alternatives to traditional single-use plastics.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Die Papierindustrie e.V. and its members strongly support the European Commission’s ambition to contribute to a climate-neutral and circular economy through a regulation on packaging and packaging waste. At the same time, there is a need for improvement in some areas.

Filed in German · English published by the European Commission

Federación española de asociaciones de productores exportadores de frutas, hortalizas, flores y plantas vivas OBSERVACIONES DE FEPEX A LA CONSULTA PÚBLICA DE LA COMISIÓN RELATIVA A LA PROPUESTA DE REGLAMENTO DE ENVASES Y RESIDUOS DE ENVASES.

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Industry Association Fachvereinigung Hartpapierwaren und Rundgefäße (FHR) welcomes the overarching goals of the proposed regulation to contribute to a climateneutral recycling economy with a regulation on packaging and packaging waste (PPWR). Please find attached our detailed feedback.

The Hellenic Cosmetic, Toiletry and Perfumery Association is the Greek Association for Cosmetics, founded in 1964, with 72 members cosmetic producers and distributors, mainly SMEs and member of the Cosmetics Europe Association. We welcome the European Commissions proposal on the Packaging and Packaging Waste Regulation (PPWR) and we fully support its overarching goals.

The European Waste Management and Recycling Forum (EWMRF) was initiated in 2019. The background to its foundation was the beginning debate on chemical recycling. The Forum is staffed with C-level executives from the waste and recycling industry from all over Europe and open to companies active in the sector. The Forums member companies represent a significant part of the entire European waste market.

The Foreign Investors Council position document on the European Commissions proposal for a Regulation on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC The Foreign Investors Council (FIC) is the association of the most important foreign investors in Romania, gathering around 120 member companies.

The Industry Association Gemeinschaft Papiersackindustrie (GemPSI) welcomes the overarching goals of the proposed regulation to contribute to a climate-neutral recycling economy with a regulation on packaging and packaging waste (PPWR). Please find attached our detailed feedback.

EUROFER supports the position of the steel for packaging sector represented by APEAL, the Association of European Producers of Steel for Packaging, regarding the Packaging and Packaging Waste Regulation (PPWR) proposal, as it suggests much needed improvements to the new EU legislation in order to contribute to a sustainable and resource-efficient solution for a green and resilient EU economy.

FEDEMCO – The Federación Española del Envase de Madera and its Components welcomes the possibility to comment on the Proposal for a Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC. A sectoral position paper is attached.

Filed in Spanish · English published by the European Commission

The European Core and Tube Association (ECTA) welcomes the overarching goals of the proposed regulation to contribute to a climate-neutral recycling economy with a regulation on packaging and packaging waste (PPWR). Please find attached our detailed feedback.

Ladies and Gentlemen, please find attached the opinion of the association of the corrugated board industry. In summary, we would like to comment as follows: Scientific studies show that reusable packaging in transport and mail order does not offer blanket environmental benefits over circular corrugated board packaging.

Filed in German · English published by the European Commission

ProFood shares the objective of improving the sustainability of food packaging, distribution and use systems, in which packaging plays a key role. ProFood shares a lien on the prevention of waste, the use of over-packaging and the dispersal of packaging waste.

Filed in Italian · English published by the European Commission

The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) supports the Commission's proposal to repeal the existing EU Packaging Waste Directive and to renew the regulation on packaging and packaging waste as a legislative act.

The German steel industry supports the European Commission's initiative to standardize the regulatory environment for packaging and packaging waste. The transition from a directive to a regulation can unify framework conditions and requirements between EU member states, promoting the sustainable handling of recyclable material.

We believe that, in order for companies to achieve environmental objectives, whether legal or voluntary, it is essential to have a harmonized regulatory framework that guarantees the necessary legal certainty to make the adaptations required in all the Member States of the European Union.

POSITION ON THE PROPOSAL FOR A REGULATION AMENDING DIRECTIVE 94/62/EC ON PACKAGING AND PACKAGING WASTE (PPWR) On 30 November 2022, the European Commission presented the proposal for a Regulation on a new regulatory framework for packaging and packaging waste (PPWR).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Faerch supports the revision of the Packaging and Packaging Waste Directive to harmonise packaging rules across the EU to ensure the free movement of packaging and packaged goods. We are supportive of the goals of increasing recycling and reuse of packaging on the European Market and avoid the use of unnecessary packaging.

FRUCOM represents European Union importers, and growers, processors, and traders, of edible nuts, dried and processed fruit and vegetables, and processed fish and seafood products. FRUCOM welcomes the publication of the Proposed Regulation on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC, on 30 November 2022.

ITENE considers that the Regulation should mention the desirability of using harmonised standards, developed on the basis of the request for Directive 94/62/EC, as a mechanism to demonstrate alignment with the requirements on packaging sustainability (reduction, reuse, recyclability, compostability).

Filed in Spanish · English published by the European Commission

ASSUC is the voice of European sugar traders, representing over sixty sugar trading companies across Europe through its membership. ASSUC strongly calls on the European Commission to remove sugar from the list of products under point four Annex V, banning single-use portion packaging for consumption in HORECA.

Sulapac welcomes the EUs efforts to both combat packaging waste and accelerate the EU transition to a circular economy. This will not only require strong recycling, re-use and recycled content targets but also measures to reduce the harmfulness of packaging waste.

Natural Mineral Waters Europe’s contribution to European Commission’s public consultation on the Proposal for a Regulation on Packaging and Packaging Waste April 2023 Natural Mineral Waters Europe (NMWE) welcomes the ongoing public consultation on the proposed Regulation on Packaging and Packaging Waste (PPWR).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Association of Alcoholic Beverage Suppliers in Finland (SAJK) considers it important that attention is paid to the environmental impact of packaging and packaging waste throughout the EU. Common regulation helps Member States develop the recycling of packaging towards a green transition.

Technology Industries of Finland (TIF) supports the objectives of the proposed new Regulation on Packaging and Packaging Waste (henceforth PPWR) as an effective tool in the transition towards a circular economy. Aside from learning new ways of consuming less and more sustainably, it is commendable that attention is also paid on packaging to avoid unnecessary use of resources.

The European Safety Federation welcomes the European Commission’s effort to reduce packaging waste and the foreseen requirements for increasing circularity of packaging materials. Packaging has an important role to play to deliver the Green Deal through resource efficiency and waste reduction. Our industry is committed to improve the packaging of our products, while protecting its users.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Sir/Madam, We kindly ask you to find attached our contribution to the draft Regulation of the European Parliament and of the Council on packaging and packaging waste. We would like you to receive it and remain at your disposal for any further information, Interfel – Interprofession des Fruits Et Légumes Frais (France)

Filed in French · English published by the European Commission

The project goes in the right direction in terms of reducing packaging, but needs to be more ambitious taking into account the health and environmental risks of plastic, the huge environmental impact of single-use glass, and therefore consider pollution in the broad sense rather than being limited to the technical issue of waste treatment.

Filed in French · English published by the European Commission

Delivery Platforms Europe represents the leading delivery platforms in Europe. We aim to work with policymakers to develop policy solutions that benefit the sustainable development of the platform economy in Europe including ensuring a better use of packaging and reducing waste.

Cooperativas Agro-alimentarias de España position on the Commission's proposal on the Packaging and Packaging Waste Regulation. Cooperativas Agro-alimentarias de España, points out that, in general, it is in favour of this Commission initiative to reduce the use of packaging and packaging waste, but also to optimise packaging and move towards the circularity of packaging materials.

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Health Care Without Harm (HCWH) Europe welcomes the European Commission's proposed Packaging and Packaging Waste Regulation (PPWR). We cannot afford more delays and need strong and binding legislation on packaging and packaging waste that prioritises prevention and reuse. The targets must be ambitious and the legislation must be enacted without delay during the current parliamentary term.

Position on the Packaging and Packaging Waste Regulation (PPWR) by IKEM - Innovation and Chemical Industries in Sweden This document contains IKEM - Innovation and Chemical Industries in Sweden´s (hereafter IKEM) position on the Packaging and Packaging Waste Regulation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Industry Association for Paper and Film Packaging (IPV) welcomes the overarching goals of the proposed regulation to contribute to a climate-neutral recycling economy with a regulation on packaging and packaging waste (PPWR). Please find attached our detailed feedback.

ECOZEMA welcomes this opportunity to get consulted on the European Commission's proposal for a Regulation on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC. Our contribution is available in the attachment.

Being a cross-sector association with member companies operating in different industries and stages in the supply chain, JBCE welcomes the opportunity to contribute to the call for feedback on the proposal for a Packaging and Packaging Waste Regulation (PPWR). JBCE welcomes and supports the overall aim of the European Commission to strive for more sustainable packaging and subsequently reducing its waste.

Kurzstellungnahme zum Entwurf der Packaging and Packaging Waste Regulation Stand 03. April 2023 Die Verbände entlang der Wertschöpfungskette von Papier, Pappe und Karton (PPK) unterstützen ausdrücklich das Bestreben der EU-Kommission, mit einer Verordnung über Verpackungen und Verpackungsabfälle (PPWR) zu einer klimaneutralen Kreislaufwirtschaft beizutragen.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Spanish Soft Drinks Association appreciates the opportunity to share our observations to the draft Packaging and Packaging Waste Regulation (PPWR), since the provisions contained in it have a direct impact on the activity of the sector. Please find attached our feedback on the proposal for a PPWR.

VDMA welcomes the objectives of the proposed EU Packaging Regulation and the change from a directive to a regulation. EU-wide harmonised and thus uniform packaging law requirements contribute significantly to a sustainable circular economy and the efficient functioning of the EU internal market.

The proposed Packaging and Packaging Waste Regulation (PPWR) presents a significant opportunity to improve the Single Market, align EU packaging regulations and decrease market fragmentation. If well designed, this regulation can be a crucial driver for circularity by promoting economies of scale and ensuring a climate-neutral and circular Europe.

Japan Cosmetic Industry Association (JCIA) appreciates the opportunity to provide the following comments in response to a proposal of Revision of Packaging and Packaging Waste Regulation (PPWR). JCIA supports the EU's efforts toward the circular economy society.

Smart Planet Technologies acknowledges the efforts made by the Packaging and Packaging Waste Directive (PPWD) to increase recycling rates of paper packaging. However, we would like to point out one area in the current draft that we feel should be reviewed and reconsidered, namely the Recycling Performance Grades of A-E for % of fiber content, as found in COM(2022) 677 Annex II for paper packaging.

Submission Packaging and Packaging Waste Regulation (PPWR) Proposal To ENZ.B3 – Waste management and Secondary Materials. By: Cosmetic Toiletry and Fragrance Association of New Zealand Inc. operating as Cosmetics New Zealand Submitted on: 21 April 2023 Contents: 1. Contact Details 2. Position Statement 3. Background Details 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FINAT is the European association for the self-adhesive label industry. We welcome the opportunity to provide feedback on the European Commissions proposal to revise the Packaging and Packaging Waste Directive. FINAT represents over 500 member companies established in more than 50 countries, covering the complete value chain of self-adhesive label industry.

Positions of Alliance Plasturgie et Composites du Futur PLASTALLIANCE on the PPWR 1 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.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CELAB-Europe fully supports the objectives of the revision of the Packaging and Packaging Waste Directive to contribute to the effective functioning of the internal market while reducing the impacts of packaging and packaging waste on the environment and on human health. We welcome the opportunity to give feedback on the proposal presented by the European Commission.

FINAT is the European association for the self-adhesive label industry. We welcome the opportunity to provide feedback on the European Commissions proposal to revise the Packaging and Packaging Waste Directive. FINAT represents over 500 member companies established in more than 50 countries, covering the complete value chain of self-adhesive label industry.

Afera, the European Adhesive Tape Association, welcomes the opportunity to provide feedback on the European Commissions proposal to revise the Packaging and Packaging Waste Directive. Afera counts 120 members in 20 countries covering the complete value chain of the adhesive tape industry and representing more than 80% of the European tape volume produced.

The National Association of Juice and Gazpacho Manufacturers - Zumos y Gazpachos de España - is the business organization that integrates the main producers of fruit juices and gazpachos of our country representing them and being their voice.

The European Beer Consumers Union is a non-political and non-religious organization that represents over 175,000 beer consumers across 18 organizations in 16 countries. The primary mission of EBCU is to advocate for a diverse beer sector, promote high-quality beer, and ensure consumers are well-informed by engaging in dialogue with various stakeholders, such as beer organizations, small and regional brewers…

Schreiner Group GmbH & Co. KG is a manufacturer of high-tech functional labels and self-adhesive functional parts, which make life a bit healthier, more mobile and safer. We are an internationally active family-owned company with over 1,200 employees and annual sales of approx. 200 million euros. We welcome the opportunity to provide feedback to the Proposal for a Packaging and Packaging Waste Regulation (PPWR).

Personal Care Products Council Input to the EU’s Public Consultation on the Proposal for a Packaging and Packaging Waste Regulation On behalf of the Personal Care Products Council (PCPC),1 we are pleased to provide our input to the Public Consultation on the Proposal for a Packaging and Packaging Waste Regulation (PPWR).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In view of the high volume of packaging and the associated use of resources, the Garten Industry Association (IVG) e.V. welcomes the Commission’s efforts to set binding targets for the reduction of waste. We also share the intention to lay down uniform packaging labelling in the light of the current differences in labelling requirements and the associated problems that manufacturers are currently facing.

Filed in German · English published by the European Commission

VOICE of Irish Concern for the Environment (VOICE) supports the revision of the Packaging and Packaging Waste Direction to become a regulation. We support many of the revisions, especially waste prevention and reuse targets. However, we believe that the prevention targets are too low, giving the exponential increase in packaging over the past decade.

EXPRA POSITION PAPER ON PPWR The Extended Producer Responsibility Alliance (EXPRA), representing 32 non-profit national EPR organizations across Europe and beyond, supports the Commissions proposal to review the current packaging and packaging waste directive (PPWD).

EDANA, the international association serving the nonwovens and related industries, supports the ambition of the Commission Proposal on Packaging and Packaging Waste Regulation (PPWR) to ensure packaging is designed for circularity, including through the promotion of recycled content uptake. At the same time, we would like to provide our view on some of the provisions of the proposal, namely: I.

Assomet welcomes the objectives of the proposal for a Regulation on Packaging and Packaging Waste (PPWR) of increasing the sustainability and circularity of packing products. As a permanent material, aluminium may be a key contributor to these objectives based on the material properties and the excellent results achieved in recycling and waste reduction in the EU and in particular in Italy.

Saica considers as a very important topic the minimisation of the impact of the packaging in our environment. Thus, we acknowledge the European Commission's proposal for a Packaging and Packaging Waste Regulation.

In line with the spirit of the European Green Deal and Circular Economy Action Plan, Lavazza Group is fully committed to reducing packaging waste and ensuring that Single Serve Units (SSUs) meet a proper end of life that enables circularity and maximization of resource efficiency for the category.

The American Peanut Council (APC) appreciates the opportunity to provide comments on the European Commission's proposal for an EU Regulation on packaging and packaging waste amending Regulation (EU) 2019/1020 and Directive (EU 2019/904, and repealing Directive 94/62/EC (COM(2022) 677 final).

MIWA welcomes the European Commission's Packaging and Packaging Waste Regulation proposal and its aim to transition the packaging sector and waste towards a circular economy system. This position addresses key concerns and offers the following recommendations for co-legislators to consider during the legislative process. A.

Pro Mehrweg e.V. (Association Pro Reuse) consists of and represents associations and companies of the German beverage industry, beverage wholesalers and retailers, their supplier industries, as well as environmental associations and individuals.

IBIPLAST welcomes this opportunity to get consulted on the European Commission's proposal for a Regulation on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC. Our contribution is available in the attachment.

Fresh Produce Centre is an industry body with members who are important players in the production, producer organisations trade, export of fruit and vegetables. They supply a complete assortment to the European retailers and food service, EU consumers. We represent 80% of the Dutch business, we react on behalf of them.

Medicines for Europe the European Association representing generic, biosimilar and value added medicines across the EU and supplying 70% of dispensed medicines in Europe, supports the European Green Deal and the new EU circular economy and the introduction of rules which will reduce packaging waste and harmonise the requirements across the single market to address environmental concerns.

General comments: The excessive use of delegated acts (power conferred on the Commission on the basis of Article 58 of the proposed Regulation) is a source of certainty for economic operators (additional constraints and restrictions, etc.). In particular, it is difficult to take a full position on the proposal for a regulation and its impact, as its content is not yet fully determined and can evolve rapidly.

Filed in French · English published by the European Commission

Loop welcomes the Commissions push for improved circularity of packaging. Loop, as a reuse system allowing consumers to buy anywhere and return anywhere products in reusable packaging, can facilitate the achievement of the reuse goals proposed by the Commission.

The attached file represents the views of the membership of the International Release Liner Association (IRLA) in respect of the consideration of release liners, particularly in the context industrial and professional uses, as non-packaging items and the Association calls upon the Commission, Parliament and Council to clarify that point in any further development of this proposed text, especially as an example in…

Cummins is working towards our PLANET 2050 goal of using natural resources in the most sustainable way possible. By 2030, we have committed to generating 25% less waste related to packaging as a percentage of revenue in facilities and operations.

Plastics Europe is the pan-European association of plastics manufacturers with offices across Europe. With close to 100 members producing over 90% of all polymers across Europe, we are the catalyst for the industry with a responsibility to openly engage with stakeholders and deliver solutions which are safe, circular and sustainable.

Minderoo welcomes the Commission's proposal for a revision of EU legislation for regulation on Packaging and Packaging Waste (PPWR proposal), to prevent negative environmental impacts of packaging and bolster reuse and recycling. The European Union has shown a commitment to transitioning towards a circular economy and production and use of safe and sustainable chemicals.

Freshfel Europe, the European fresh produce association, supports the efforts to increase sustainable packaging solutions and the harmonisation the proposed regulation would bring to the packaging market in Europe.

AIJN The European Fruit Juice Association, thanks the EU Commission for the opportunity to react to its Proposal on a Packaging and Packaging Waste Regulation. Since 1962, AIJN represents manufacturers and processors of fruit juices, fruit nectars and other similar products falling under the EU Fruit Juice Directive.

The BOVH welcomes the EU’s intention to harmonise the rules on packaging throughout the EU, thereby promoting the European internal market, and that further harmonisation would be absolutely necessary, in particular as regards registration requirements in the various Member States. From a sustainability point of view, the EU’s proposals are also very welcome and are supported by us.

Filed in German · English published by the European Commission

Verband Metallverpackungen e.V. (VMV) is the German Metal Packaging Association representing the manufacturers of rigid metal packaging. The product range represented includes, for example, food cans and closures, promotional packaging, aerosol cans, tinplate packaging for paints and coatings and other chemical goods, steel drums, but also intermediate bulk containers made of stainless steel.

- SEE FULL TEXT IN THE ATTACHED EDA POSITION - EDA supports the Commissions ambition to further harmonize the EU internal market for packaging and packaging waste and continue the transition to a more circular economy for packaging. These rules should be aligned with legislation on hygiene and food contact materials, green claims, and the framework for a sustainable food system.

The European Coffee Federation (ECF) welcomes the European Commissions proposal to update the EU legislative framework for packaging and packaging waste (PPWR) by giving Member States and businesses adequate support to achieve waste reduction targets to diminish the environmental impact of packaging.

The Commission’s proposal to reduce packaging, although acceptable in the waste limitation objectives, will have opposing and negative effects on Italian and European production chains and on consumers. While the proposal for a regulation can be said to be consistent with the objectives of the circular economy of ensuring the prevention of packaging waste, by encouraging reuse, it risks hampering the investments…

Filed in Italian · English published by the European Commission

Tobacco Europe welcomes the opportunity to provide feedback to the review of rules on reducing packaging waste. Tobacco Europe is fully committed to the EU Green Deal objectives and the respective efforts striving for the reduction of waste in general and packaging waste in particular.

The virtues and value of corrugated cardboard packaging in two key statements EU corrugated leads the world in all-round performance. Fully recyclable and massively recycled in the EU today, corrugated packaging made from renewable resources is safe and sustainable, fit-for-purpose and already delivers the circular economy, notably (but not only) in the food chain, where it helps avoid food waste because of its…

The proposed regulation risks creating considerable difficulty for the fruit and vegetable sector if it is not approached with the necessary nuance. Packaging for fruit and vegetables is not accessory; it serves a series of purposes, and most significantly helps maintain freshness, allowing the produce to be sold and consumed in a safe manner for longer.

European Recycling Platform (ERP) appreciates the opportunity to provide feedback on the European Commission's proposal for a new Regulation on Packaging and Packaging Waste (PPWR). We support the proposal's ambition to further harmonise the European internal market and to create a level playing field for all actors involved in the pre- and post-consumer phase of packaging.

Agoria position on the proposed Packaging and Packaging Waste Regulation Agoria welcomes the possibility given by the Commission to provide feedback on the proposed legislation. Packaging and packaging waste are topics that are important for the Belgian technology sector represented by Agoria, and therefore we have some observations to make on certain articles of the proposed regulation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Date 21. april 2023 Page 1 of 3 Danish Dairy Board Brussels statement on the proposal for a regulation on Packaging and Packaging Waste Danish Dairy Board, Brussels s.a. We welcome the European Commission’s proposal and in particular the ambition to further harmonize the Rue du Luxembourg 47-51.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Projet de Règlement relatif aux Emballages et Déchets d’Emballages Groupe industriel familial créé en 1972, coté en bourse, le Groupe Guillin est devenu en cinq décennies, grâce à une stratégie d’innovation majeure dans le domaine des solutions d’emballage alimentaire, une ETI leader et référente européenne avec plus de 3000 collaborateurs et 740 M€ de chiffre d’affaires.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

LAIB is the Association Interprofessionnel de la Banane, founded in 2012 on the initiative of professional organisations representing the sector (producers, importers, ripeners, wholesalers, early leavers and distributors). LAIB was recognised by the public authorities as an agricultural interbranch in September 2016.

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Cosmetics Europe, the European trade association for the cosmetics and personal care industry, welcomes the European Commissions proposal for a Packaging and Packaging Waste Regulation (PPWR) and supports its overarching goals. In particular, we welcome the proposal for a Regulation with a full internal market legal basis as a way to increase the harmonisation across Member States.

The Commission proposal includes some derogations for packaging used in medicines. AnimalhealthEurope welcome this recognition that the medicines and other health products sectors are of the most regulated in Europe and the world, and that our packaging (primary and secondary) plays a critical role in supporting the stability and storage and ensuring that animal patient safety and product effectiveness are not…

Position of Fibre Packaging Europe on the proposal for a Packaging and Packaging Waste Regulation (PPWR) Fibre Packaging Europe (FPE) is an informal coalition of seven trade associations representing industries involved in forestry, pulp, cardboard (paper, board and carton packaging) production and recycling in Europe, coming together to speak with one voice on the policy issues central to the fibre-packaging value…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Comments on the Proposal for a Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC [COM/2022/677 final] Biorepack is the National Consortium for Organic Packaging in Biodegradable and compostable Plastics and is the first extended producer responsibility system in Europe specifically…

Filed in Italian · English published by the European Commission

Recyclable packaging must be an equal alternative to reuse. This is in contradiction with the objective of the EU Circular Economy Action Plan that all packaging must be either reusable or recyclable by 2030. In the proposal for a regulation, the demonstration of the environmental benefits of reusable packaging remains unclear.

Filed in Finnish · English published by the European Commission

The Confederation of European Paper Industries - Cepi acknowledges the European Commissions proposal for a Packaging and Packaging Waste Regulation, and looks forward to supporting an evidence-based regulatory approach during the next stages of the legislative process. Both recyclable and reusable items have a role in the transition to a circular economy.

Würth assessment and positioning on the proposal for a new regulation of the Packaging Ordinance. The growing generation of packaging waste through new consumption patterns and barriers to the reuse of packaging have led to a number of actions in the EU under the Circular Economy Action Plan to further decouple resource use from economic growth.

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Brussels, 21 April 2023 EuPC Position paper on the proposal for a new Packaging and Packaging Waste Regulation European Plastics Converters welcome the proposal of the European Commission for a new Packaging and Packaging Waste Regulation and are thankful for this opportunity to share some detailed comments.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

COSMED, the French cosmetic association for SMEs, thanks the Commission for the possibility to comment the proposal for a regulation on packaging and packaging waste. First of all, COSMED support this proposal for a regulation on packaging and packaging waste to harmonize rules in European Union and to move towards a more circular economy.

Afvalfonds Verpakkingen, the Dutch EPR system for packaging, welcomes the proposal to introduce a Packaging Regulation in order to serve the internal market, and hence to repeal the PPWD. Also, we welcome the main goals of the regulation as mentioned in article 1, with the remark that the internal market for the combination of the product and its packaging should be harmonised.

Position zum Entwurf einer europäischen Verordnung über Verpackungen und Verpackungsabfälle (PPWR) Hintergrund Die EU-Kommission hat am 30. November 2022 einen Entwurf für eine neue europäische Regelung für Verpackungen und Verpackungsabfälle (PPWR) vorgelegt.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CEPI Eurokraft, the European Association for Producers of Sack Kraft Paper for the Paper Sack Industry and Kraft Paper for the Packaging Industry, acknowledges the European Commissions proposal for the Packaging and Packaging Waste Regulation. However, the Regulation should aim to make packaging more circular in a holistic way without giving certain materials a disproportionate market advantage.

Our context: GALIA represents automotive supply chain professionals. Members of our Association include Renault Group, Renault Trucks, Stellantis and automotive suppliers. Our Association, involved in developing sustainable solutions, works consistently with many packaging suppliers. Within a geographical area such as Europe, the automotive industry has heavily invested in reusable (returnable) packaging.

The European Association of E-Pharmacies (EAEP), as the organisation representing the voice of the e-pharmacy sector on the European continent, welcomes the opportunity to provide feedback on the initiative Packaging and Packaging Waste Regulation (PPWR) proposal. The EAEP's feedback is attached to this response.

On 30 November 2022, the European Commission presented the proposal for a Regulation on a new regulatory framework for packaging and packaging waste (PPWR). Though the proposal goes in the right direction by acknowledging that compostable applications have a beneficial role to play in the circular economy (see in particular art.

The German Association of the Automotive Industry (VDA) consolidates about 650 manufac-turers and suppliers under one roof. The members develop and produce cars and trucks, software, trailers, superstructures, buses, parts and accessories as well as new mobility of-fers. We represent the interests of the automotive industry and stand for modern, future-oriented multimodal mobility on the way to climate neutrality.

The Wirtschaftsverband Papierverarbeitung (WPV) e.V. welcomes the overarching objectives of the proposal for a regulation to contribute to a climate-neutral and circular economy. Targets on the recyclability of packaging and a reduction in the use of materials in packaging can contribute positively to the further development of the circular economy. However, the proposal also contains very problematic aspects.

Filed in German · English published by the European Commission

The Italian Compost and Biogas Association (CIC) welcomes the possibility to comment on the draft document revising the packaging and packaging waste directive released by the EU Commission on November 30th 2023.

Assobioplasia welcomes this option to get consulted on the European Commission’s proposal for a Regulation on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC. Our contribution is available in the attachment.

Filed in Italian · English published by the European Commission

The European Commission’s draft Regulation of the European Parliament and of the Council amending Regulation 2019/1020 and repealing Directive 94/62/EC on packaging and packaging waste, presented by the European Commission, aims to reduce the total amount of packaging placed on the EU market and related packaging waste.

Filed in Polish · English published by the European Commission

The European Federation of Paper & Board Converters (CITPA) and its member associations welcome the Commissions ambition to contribute to a climate neutral circular economy through the proposal for a Packaging and Packaging Waste Regulation (PPWR).

Position WWF Germany on draft proposal of the PPWR Ref. Ares(2023)2829809 - 21/04/2023 20. April 2023 Thank you for the opportunity to comment on the EU COM proposal for a Regulation on packaging and packaging waste. WWF Germany welcomes the basic direction of the proposal of the new EU regulation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Projet de règlement européen sur les emballages et déchets d’emballages Note de positionnement Paris, le 14/03/23 Un projet de règlement sur les emballages et déchets d’emballages a été présenté officiellement par la Commission européenne le 30 novembre 2022. Le présent document indique les remarques, commentaires et positions de l’ANIA sur ce projet de texte, à la date indiquée ci-avant.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

AGVU Position on the draft PPWR Despite being a very positive and constructive step towards the EU circular packaging economy, the EU Commissions proposal also contains problematic aspects: key decisions will be moved to the level of delegated and implementing acts.

FEFCO acknowledges the European Commissions proposal for the Packaging and Packaging Waste Regulation. We support maintain the internal market legal basis and introducing harmonised labelling requirements for packaging across EU. Additionally, FEFCO welcomes the packaging minimisation measures and proposed empty space ratio as they will help to reduce packaging waste.

Environment Unit Proposal for a Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC (n.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Cultural and Creative Industries Alliance (ECCIA) supports the European Commissions Green Deal and its global ambition towards a more sustainable and circular economy. We recognize that minimizing the environmental impact of packaging and packaging waste is one of the key alleys for the achievement of the Green Deal, and therefore wish to contribute to the impactful, meaningful, and enforceable revision…

Ladies and gentlemen, in Germany about 80 % of beer is sold in reusable beverage packaging. If cask beer is taken into account in this analysis, this value is again considerably increased. It is the largest and most successful multi-use system in Europe. The existence of this system would be jeopardised should the draft EU Packaging Regulation be implemented in the current version.

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We support the objetives for the revision of the Packaging and Packaging Waste Regulation (PPWR) exposed by the Commission. But, like our partners Smurfit Kappa Bag-in-Box, we support the ideas in the files you could find attached about the Bag-in-Box Market, and we hope that they will be considered by the Commission

Japanese 4EE industrial associations (JP4EE) Comments - Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC 21st April, 2023 The Japanese electric and electronic (E&E) industrial associations (JP4EE*), namely: JEITA (Japan Electronics and Information Technology…

Ahlstrom welcomes the European Commissions ambitious proposal for a Regulation on Packaging and Packaging Waste. We wish to highlight further improvements to ensure all targets and measures are science based. Reuse and recyclability should be complementary alternatives to choose from to achieve the greatest environmental benefits The full life cycle impact of all packaging products should serve as the basis when…

Japanese 4EE industrial associations (JP4EE) Comments - Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC 21st April, 2023 The Japanese electric and electronic (E&E) industrial associations (JP4EE*), namely: JEITA (Japan Electronics and Information Technology…

The European Federation of Pharmaceutical Industries and Associations (EFPIA) represents the biopharmaceutical industry operating in Europe. EFPIA welcomes the opportunity to share our feedback on the Proposal by the Commission on the Packaging and Packaging Waste Regulation (COM(2022) 677 final) (PPWR). The Commission proposal includes some derogations for packaging used in pharmaceuticals.

We would like to submit the following comments in order to implement it in line with the policy objectives of the European Green Deal and the new Circular Economy Action Plan. 1. Article 2(Scope) Packaging for B2B products is often different for each customer, according to the equipment and handling procedures in the customers facility and is not uniformly designed.

The beverage carton industry acknowledges the need to revise the rules on packaging and packaging waste management to align them with the overall objective of the EU Green Deal. We believe that the current PPWR draft contains positive developments, but that additional consideration is needed for some elements.

As it stands, the text is not ambitious enough and puts a risk of backsliding on legislation in some countries with more advanced policies in terms of waste management hierarchy. It is important: to ban any text and legal framework which would mean a step backwards for the most advanced countries on waste prevention, reduction and re-employment.

Filed in French · English published by the European Commission

As enterprise that works with Smurfit Kappa Group, welcoming the option to provide feedback in reviewing the Packaging and Packaging Waste Directive. We support the arguments that Smurfit Kappa has presented. The attested statement to add key points from the manufacturer and collaborator in using Bag in Box packaging.

Filed in Spanish · English published by the European Commission

As European federation of glass recyclers, we support the ambitious initiative of the Commission to revise the Packaging and Packaging Waste Directive and to opt for a future Regulation. In the document annexed, please find specific comments related to the specific properties of glass and to our capacity to contribute in the development of recyclability criteria for glass packaging.

TotalEnergies Corbion supports the overall objective of recycled content targets in packaging. However, the proposed Regulation despite the initial announcements fails to tackle the most urgent matter of reducing GHG emission in the packaging (and material) sector, which is relevant if the EU wants to reach the climate neutrality goal by 2050.

A VAT advantage for reusable packaged products which are part of a pooled system and which can circulate in the market without major barriers. The reuse of packaging is a significant lever for reducing packaging waste. The TO GO sector in particular benefits from a reduced VAT rate in Germany in the case of food supplies or sales in the food retail sector. I am not aware of the situation for other EU Member States.

Filed in German · English published by the European Commission

We submit our comments on the European Commission's proposal for an EU Regulation on packaging and packaging waste (COM(2022) 677). About SEFFI Founded in 1991, SEFFI (Syndicat Européen de lindustrie des Fûts Fibre / European Association of Fibre Drum Manufacturers) is the European organisation of fibre drum packaging manufacturers.

Polish Glass Manufacturers Federation, supports the objectives of the proposal for a PPWR to promote the circularity of packaging while ensuring well-functioning internal EU- market. We believe that some of the measures proposed in the draft Regulation might have strong negative impact on EU industry and consumers, while not helping to achieve the objectives.

Assomela, the Italian association of apple producers, supports the efforts to harmonize the packaging market in Europe and supports the will to increase sustainable packaging solutions. The Italian apples sector is highly concerned about the discriminative targeting of the fresh produce sector in Article 22, Annex V, point 2 and the possible consequences this could have in terms of food safety, information…

The European Aluminium Foil Association (EAFA) welcomes the Commission proposal for a Regulation on Packaging and Packaging Waste (PPWR) repealing Directive 94/62/EC. We welcome the retention of the internal market legal basis (Article 114 TFEU) and the choice of a Regulation as the legal instrument.

- Flexible Packaging Europe (FPE) fully supports the objectives of the proposal for a regulation on Packaging and Packaging Waste (PPWR) which is aligned with our vision2 for packing products more sustainably. We embrace the objective to lower the total environmental impacts of production and consumption of packaging and packaged goods, in the line with the EU Green Deal goals.