2022/0396(COD) · In Force
530 submissions from 469 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 629 submissions on this file. Shown here: the 530 from organizations. Not shown: 66 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 33 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
443 submissions from industry — companies and their trade associations — against 60 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 7.4 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 24 Apr 2023 — it ran from 1 Dec 2022.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned.
Showing 25 of 250 submissions on this page · page 2 of 3 · 530 across the file. Search the whole file
The Packaging and Packaging Waste Regulation (PPWR), the proposal of which has been published by the European Commission, will have a very significant impact on the functioning of the companies represented by the Polish Cosmetics and Detergent Industry Association (PSPKD).
Filed in Polish · English published by the European Commission
The European Recycling Industry welcomes the ECs proposal for the new Regulation on Packaging and Packaging Waste [COM (2022) 677] and acknowledges the Commissions commitment to set ambitious measures to boost packaging circularity.
Finnish Forest Industries Federation (FFIF) supports the European Commissions objective in Packaging and Packaging Waste Regulation proposal to reduce packaging waste and increase the reuse, recyclability, and recycling of packaging materials.
Flexible Packaging Initiative’s POSITION PAPER ON PPWR Members of the Flexible Packaging Initiative call for the Packaging and Packaging Waste Regulation to set the right regulatory framework to enable flexible packaging circularity. Flexible packaging is a highly efficient material providing the right level of safety, quality, product protection and preservation, thereby avoiding food waste.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
FEVE, the European Container Glass Federation, supports the objectives of the proposal for a Packaging & Packaging Waste Regulation (PPWR) to ensure a well-functioning internal market, tackle the negative environmental and health impacts from packaging and packaging waste and promote the circularity of packaging.
Stora Enso is a renewable materials company. We are one of the largest suppliers of renewable materials used in fiber-based packaging (e.g., cereal boxes, milk cartons, transport packaging, food trays, etc.). We are also amongst the largest recyclers of fiber-based packaging in Europe, and thus produce packaging materials and solutions based on both fresh and recycled fiber.
Our ambition in the ALDI Nord Group of Companies (ALDI Nord), one of the leading pan-European discount retailers, is to make sustainable products affordable. This includes initiatives to make all kinds of packaging reusable, recyclable and containing recycled content.
KTF supports the Commission's intentions to increase circularity and to reduce resource consumption of packaging materials. We would like to make the following comments on the Commission proposal: Harmonisation We are concerned that several of the provisions contained in the PPWR proposal - such as Articles 4(4), 4(5), 11(7) and 45(2) (c) -allow Member States to require or introduce additional national requirements…
· · filed 20 Apr 2023 · source
Apofruit Italia is a fruit and vegetable cooperative of about 3000 members producing fruit and vegetables throughout Italy. It packages different types of products for a volume sold to the market of around 150,000 tonnes of fresh fruit and vegetables for the large-scale retail trade and markets all over the world, using significant quantities of primary and secondary packaging.
Dato Side 20. april 2023 1 af 7 European Commission Proposal for a regulation on packaging and packaging waste regulation Commission adoption feedback Landbrug & Fødevarers høringssvar til udkast til Europa-Kommissionens forslag om regulering af emballage og emballageaffald. Kommissionen har udbedt kommentarer til et fremlagt forslag til regulering af emballage og emballageaffald.
Filed in Danish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 19 Apr 2023 · source
Mondi supports Commission proposal, but it still requires key improvements to reach full potential Mondi is a global manufacturer of a wide range of fibre-based and flexible packaging solutions, employing approximately 21.000 colleagues globally. Improvements in recycling infrastructure The main hurdle to boosting recycling is better sorting and collection of materials.
Otto Group’s statement on the Proposal for a revision of EU legislation on Packaging and Packaging Waste The Otto Group supports the EU initiative to make an important contribution to resource and climate protection through ambitious sustainability goals. We also welcome the approach of standardizing packaging regulations across the EU.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 19 Apr 2023 · source
Graine de Malice’s position on the Packaging and Packaging Waste Regulation (PPWR) We welcome the introduction of reduction and re-use targets but stress that progress is not decisive enough: 1. Recent scientific studies on the environmental and health risks of packaging materials, in particular plastic 2.
Filed in French · English published by the European Commission
· · filed 19 Apr 2023 · source
FNADE, the French association for waste management and environmental services welcomes the proposal of the European Commission for a revision of the packaging and packaging waste directive. Overall, the new regulation on packaging and packaging waste represents a step forward for the waste management sector and FNADE globally supports its objectives.
The proposed revision is interesting but not ambitious enough, in particular with regard to re-use. Some obligations are even less ambitious than certain laws in France (AGEC law with a minimum reuse of 10 % from 2027).
Filed in French · English published by the European Commission
Please find attached the position of the European Vending & Coffee Service Association (EVA) on the proposal for a Packaging & Packaging Waste Regulation (PPWR). Please also fine in the link below a joint letter signed by more than 120 European Associations calling for the internal market legal basis to be maintained…
GENERAL COMMENTS It would be worth challenging whether primary packaging components (Bottles, Blisters, Vials, etc) are excluded from this Directive as appears so in the details outlined below. Gilead currently requires 100% virgin materials for primary packaging and changing this would be a significant challenge.
The Verband der Chemische Industrie e.V. (VCI) brings together companies in the chemical and pharmaceutical industry that sell their products to business and private customers worldwide. We welcome the European Commission’s efforts to promote, through the Packaging and Packaging Waste Regulation (PPWR), as part of the new Circular Economy Action Plan under the Green Deal, a unified framework for the sustainable use…
Filed in German · English published by the European Commission
European Bioplastics (EUBP), the association representing the interests of around 80 member companies from the entire bioplastics value chain, welcomes the Commissions proposal for a revised Regulation on Packaging and Packaging Waste (PPWR).
Thank you for the opportunity to comment on the PPWR draft. Please find attached NABU's feedback. Information on NABU: Founded in 1899, NABU (Nature And Biodiversity Conservation Union) is the oldest and largest environment association in Germany.
· · filed 19 Apr 2023 · source
EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide.
Lassociation No Plastic In My Sea welcomes the introduction of the dobjectives for reduction and reuse, but would like this text to be more decisive in terms of: — the latest scientific studies which refer to the environmental and health risks posed by packaging materials, in particular plastic, and the most ambitious approaches currently under way concerning plastic pollution, in particular through the principle of…
Filed in French · English published by the European Commission
The GEPC, European mushrooms growers' group, representing 90% of the European production of cultivated mushrooms, would like to pinpoint the difficulty to comply with the draft regulation proposal regarding the measure of restriction of use of packaging for single use in the fresh fruit an vegetables sector. (see the note attached).
Proposal for a Regulation on packaging and packaging waste (PPWR) The French Federation for Beauty Companies, the Union des fabricants and the Comité Colbert support the European Commission’s Green Deal and its global ambition towards a more sustainable economy. High-end and luxury industries are renowned for the excellence and exceptional creativity of their products.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 19 Apr 2023 · source
Fass-Frisch GmbH’s comments on the draft European Regulation on packaging and packaging waste, we thank us for the opportunity to comment as an undertaking on the draft Regulation on packaging and packaging waste. In particular, we would like to provide feedback on the aspects of Article 7, the minimum recycled content in plastic packaging.
Filed in German · English published by the European Commission
Please accept the following comments from the U.S. Hop Industry Plant Protection Committee (USHIPPC) 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.
14 April 2023 ECMA feedback on the Packaging & Packaging Waste Regulation proposal The European Carton Makers Association (ECMA) welcome the Commission’s ambition to contribute to a climate neutral circular economy through 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)
2107 Wilson Boulevard Suite 600 Arlington, Virginia 22201-3061 USA Tel [phone removed] Fax [phone removed] www.usdec.org April 18, 2023 The U.S. Dairy Export Council (USDEC) appreciates the opportunity to comment on the e European Union’s (EU) proposed Packaging and Packaging Waste Regulation (PPWR). 1 USDEC is a non-profit, independent membership organization representing the global trade interests of U.S.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Wing is an Alphabet company that delivers food, medicine, and other supplies by drone. It conducts commercial drone deliveries on three continents, with hundreds of thousands of flights directly to homes across Finland and Ireland in Europe, Australia, and the United States.
SEFA is the Association representing the steel drum industry in Europe. Our members produce steel drums and other types of industrial sales packaging for various industries such as the lubricant and chemical industry, or the agrochemical and food sectors. Steel is a permanent material which means it has the potential to be recovered and recycled endlessly, without losing its essential properties.
Infinitum is the owner and operator of the Norwegian DRS (Deposit Return System) for beverage containers. We handle containers made of plastic, mostly PET bottles but also some HDPE; and aluminium cans. Infinitum has through an efficient system and good marketing achieved world-class collection- and recycling results.
DerGrünePunkt – Duales System Deutschland GmbH | D-51170 Cologne Your reference and date: Our reference: European Commission DSD 04/23 Your contact person: Phone: [phone removed] Fax: [phone removed] E-Mail: [email removed] Date: April 18, 2023 Position of Der Grüne Punkt – Duales System Deutschland GmbH (DerGrünePunkt) on the draft PPWR (Packaging and Packaging Waste Regulation) DerGrünePunkt fully endorses the EU…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Huelva (España), 18 de abril de 2023 Desde Freshuelva, entidad que representa a los productores y exportadores de fresas y frutos rojos de Huelva (España) y que engloba al 90% de los productores queremos hacer hincapié en el artículo 22.1 y el apartado 2 del Anexo V del citado Reglamento, según el cual quedará restringida la comercialización de frutas y hortalizas frescas en lotes inferiores a 1,5 kilogramos en…
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)
At Amazon we support the European Commissions goal to tackle excessive packaging in online sales. We believe the Packaging and Packaging Waste Directive review, as well as the upcoming review of the Waste Framework Directive, and their further implementation at national level, offer a unique opportunity to properly take into consideration the growing reality of online trade and encourage its benefits when setting…
Syctom is a French local public authority and a public service. It is the leading European public operator in municipal waste management. With its 6 sorting centres and 3 waste-to-energy units, Syctom processes 2.3 million tonnes of municipal waste (namely 10% of French municipal waste) from six million inhabitants of the Île-de-France region, including Paris.
Please find attached in English the contribution of Smurfit Kappa Bag-in-Box regarding the PPWR. We also want to stress the importance of evaluating the components of the Bag-in-Box each in its recycling stream (if the instructions are given to separate) and not in the stream of the dominant element.
The bag in box is made up of a cardboard box (75%) and a flexible bag (25%) These two elements are easily separable and recyclable after use by the consumer In my opinion, the European Regulation must review the Bag in Box product by considering it as separate and not integrated elements.
Please find enclosed our opinion 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, COM(2022) 677 final. Yours faithfully, [name removed]
Filed in German · English published by the European Commission
PepsiCos vision is a world where plastic never becomes waste and hence aligned with the intention of the proposed PPWR. We have similar ambitions in reducing the amount of virgin fossil-based plastic that we use by increasing reuse and driving more use of recycled content, all actions that will curb the amount of packaging waste resulting from the consumption of our products.
Stockholm, 14. April 2023 Nordic Ecolabelling feedback on the EU Commissions proposal for a regulation on packaging and packaging waste Thank you for the proposal for a regulation on packaging and packaging waste and the possibility to give feedback.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Visita position Visita welcomes common rules for packaging and packaging waste in the EU as it is a basis for a well-functioning internal market as well as it protects an effective environmental and climate policy. Visita supports the proposal that the economic operators who put reusable packaging on the market are responsible for the existence of systems for reuse.
FIAB POSITION ON PACKAGING AND PACKAGING WASTE REGULATION COMMISSION PROPOSAL INTRODUCTION The Spanish Federation of Food and Drink Industries welcomes the European Commission's proposal for a Regulation on packaging and packaging waste (PPWR).
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)
(formerly the European Circular Bioeconomy Policy Initiative) [phone removed] Rue d’Oultremont 34, 1040 Bruxelles www.bioeconomybureau.eu April 14th 2023 The European Bioeconomy Bureau represents industries, academics and consultancies whose activities are related to the development of the circular bioeconomy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
MAKE SUSTAINABLE PLASTICS THE NORM IN THE EUS PACKAGING REGULATION: The Packaging and Packaging Waste Regulation (PPWR) is an opportunity to make a major leap towards more sustainable production and consumption of plastics in the EUs circular economy. Tackling sustainability of plastic packaging is critical as it is the single biggest use of plastics in the EU representing 40% of the market.
The purpose of our statement is to highlight key concerns about the PPWR and to provide background information that we would like to discuss in more detail. In addition, we propose certain changes to the text of the regulation in the appendix to the statement in order to address some of the points raised.
Fibre Packaging Europe (FPE) 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. FPE recognises that recyclable and reusable options are complementary towards a common goal of achieving a circular economy in the EU.
Ladies and gentlemen, the basis of this opinion is the statements of the CCIs received by the DIHK up to the date of the opinion, as well as the economic/European policy positions of the DIHK. Should the DIHK receive further relevant comments not yet taken into account in this opinion, the DIHK will supplement this opinion accordingly.
Filed in German · English published by the European Commission
Feedback on the EU Packaging Regulation revision Recommendations for an ambitious revision of the Packaging and Packaging Waste Regulation (PPWR) Position Paper April 2023 zerowasteeurope.eu Contents 2 General Recommendations 2 4 Material neutrality approach needed Sustainability without safety?
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 6 Apr 2023 · source
As an advocate for the circular economy, Henkel has been for a long time actively working on further improving the recyclability and sortability of its consumer goods packaging by setting concrete sustainable packaging targets until 2025, and by integrating circularity into its production processes.
ELIPSO is the professional union representing packaging manufacturers in the plastics sector, located in France. Our 112 members, firmly rooted in the territories, are resolute towards the circular economy: this is demonstrated by the actions carried out over the last ten years with regard to reduction, the increasing incorporation of recycled materials in their packaging, the setting up of additional industrial…
Filed in French · English published by the European Commission
The BPI e.V., representing more than 270 members, comprises the whole spectrum of the pharmaceutical industry, ranging from multinational corporations to SMEs, Mid-Caps as well as Start-ups. These companies ensure timely and safe drug supply for all patients across the EU and globally.
The European Snacks Association asbl (ESA) is Europes only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers, as well as national trade organisations.
Bund Getränkeverpackungen der Zukunft (BGVZ) is an association of beverage producers, retailers, packaging and recycling companies. The majority of BGVZ's shareholders are operating on the market in Germany as well as in other European member states. In summary, we would like to comment as follows on the draft proposal of the EU Commission: 1.
· · filed 6 Apr 2023 · source
The German Association for Reusable Packaging (Reusable Packaging) is non-profit organisation founded in 2022 and consists of 70 members, mainly companies and organisations that – are system operators of reusable packaging solutions for food, E-commerce, take-away or body- and homecare articles, – fill food, body- and Homecare and other products in reusable packaging, – investigate or research and/or consult the…
Filed in German · English published by the European Commission
We, the Polish Zero Waste Association support ambitious measures to be further reinforces during the decision making process at the EU level. We recognise that Member States take little to no action if not obliged by the legislation at comunity level in which decision making they alos particiapte and we as citizens require governments to align with the highest amibitiosn and implement then in due time.
The proposed Packaging and Packaging Waste Regulation (PPWR) is vital to substantially reduce the ever increasing resource consumption and waste production related to the use of packaging in the European Union, as well as to align packaging policies with the ambition and goals of the new Circular Economy Action Plan (CEAP) and the European Green Deal (EGD).
MedTech Europe - the European trade association for the medical technology industry, including diagnostics, medical devices, and digital health - supports the objective of the Packaging and Packaging Waste Regulation (PPWR) proposal to prevent or reduce the adverse impacts of packaging waste on the environment and human health.
Citeo, the French EPR organisation for households packaging and graphic paper, would like to share its analysis on the Packaging and Packaging Waste Regulation proposal, built together with Citeos experts on prevention, reuse, Recyclability and environmental claims. We welcome the harmonisation supported by the proposal.
Filed in French · English published by the European Commission
The German mineral wells welcome the fact that the European Union has sought to improve the environmental performance of packaging by initiating a comprehensive revision of the regulation of packaging and packaging waste. It also supports the transformation of the current Directive into a single regulation across Europe.
Filed in German · English published by the European Commission
With the proposal for the revision of the Packaging and Packaging Waste Regulation (PPWR), the European Commission aims to harmonize national measures on packaging and the management of packaging waste, provide a high level of environmental protection and ensure the good functioning of the internal market.
As the Belgian Federation for Chemicals, Life Sciences and Polymers, we have the unique distinction of covering both very demanding users as well as manufacturers of plastics packaging, along the entire value chain, from basic substances to recycling. Our coverage is therefore very broad with a particular attention to the services delivered to society and to public health.
Please find MWE's position and proposed amendments to the revised Packaging and Packaging Waste Regulation. Municipal Waste Europe is the European umbrella association representing public responsibility for waste.Our members are national public waste associations and similar national or regional associations. We promote the waste hierarchy, resource efficiency and best practices on municipal solid waste management.
· · filed 31 Mar 2023 · source
1. The proposal should deliver on the Green Deal and Circular Economy Action Plan The PPWR proposal runs counter to these policies and will not ensure a just transition. It should focus on resource efficiency; setting up at scale recycling infrastructures to drive reuse of packaging materials; and incentivizing innovation in materials and infrastructure.
EGMF the European Garden Machinery industry Federation represents the major garden, landscaping, forestry and turf equipment manufacturers, and is a strong supporter of the European environmental policy for improving the impact of products in the society.
FEP the European Parquet Federation is welcoming the European Commission proposal to revise the Packaging and Packaging Waste Directive, and the possibility to comment it. FEP is viewing this revision of the Packaging and Packaging Waste Directive as a unique opportunity to set common requirements on which information should be shared with consumers for sorting instructions and how this should be done in an…
We would like to thank you for the opportunity, as a BDSI and thus for the German confectionery industry, to comment on the draft EU Regulation on packaging and packaging waste. The German confectionery industry is committed to a forward-looking and efficient use of the necessary resources and welcomes and supports the move towards a well-functioning circular economy.
Filed in German · English published by the European Commission
A.I.S.E., the European association for detergents and cleaning products, welcomes the European Commissions proposal for a Regulation on Packaging and Packaging Waste. Our industry has an ambitious agenda of activities to address the challenges involved and has already undertaken concrete actions to reduce the impact of packaging and packaging waste across the sector.
CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 85 members along the CCU value chain, from CO2 producers, converters and users of CCU products to researchers and project developers.
Europatat is the European Potato Trade Association, comprising both national associations and individual companies involved in the trade of seed, ware and early potatoes throughout Europe. Its members include a wide range of traders (including breeders, distributors, storers, packers, importers and exporters) delivering seed potatoes to farmers, raw material to the food industry, and packed potatoes to the retailers…
In respect to the revision of the packaging and packaging waste directive, we are delighted to see the proposal of the EU Commission to regulate compostable packagings across Europe, according to well-defined criteria to ensure the environmental benefits of these innovative materials.
FESI, the Federation of the European Sporting Goods Industry, welcomes the opportunity to provide feedback on the Inception impact assessment on the review of the requirements for packaging and other measures to prevent packaging waste.
To: European Commission Public consultation website Reducing packaging waste – review of rules 27th March 2023 Re: The European Commission's proposal for a regulation on packaging and packaging waste. In November 2022, the European Commission presented its proposal for a new regulation on packaging and packaging waste. The proposal must now be negotiated between the EU member states and the European Parliament.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Statement by Schumacher Packaging on the EU Commission's proposal on the Packaging and Packaging Waste Regulation, published on November 30th 2022 Schumacher Packaging is a Europe-wide manufacturer of customised corrugated board and cardboard packaging. With 29 locations in Germany, Poland, the Czech Republic, Italy, the Netherlands and the UK, we are one of the largest family-run companies in the industry.
· · filed 24 Mar 2023 · source
BDE Federation of the German Waste, Water and Circular Economy Management Industry and VOEB Association of Austrian Waste Management Companies welcome the Commission's Proposal for a Regulation on Packaging and Packaging Waste as a committed step towards a comprehensive circular economy in Europe.
Ref. CCC(23)[phone removed].3.2023 Copa-Cogeca feedback: Packaging and Packaging Waste Regulation 2022/0396(COD) Introduction In view of the publication of the Commission’s proposal for the Packaging and Packaging Waste Regulation, Copa and Cogeca – who represent 22 million farmers and their families, and over 22,000 cooperatives – would like to express their concerns as regards some of the extremely ambitious…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Ref. CCC(23)[phone removed].3.2023 Copa-Cogeca feedback: Packaging and Packaging Waste Regulation 2022/0396(COD) Introduction In view of the publication of the Commission’s proposal for the Packaging and Packaging Waste Regulation, Copa and Cogeca – who represent 22 million farmers and their families, and over 22,000 cooperatives – would like to express their concerns as regards some of the extremely ambitious…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Valmet thanks for the opportunity to comment in the Commission's proposal to update the EU packaging and packaging waste directive. Our first messages on the proposal are: Accuracy and Origin of Data In the Impact Assessment (Part 1/2, page 6), the greenhouse gas emissions (GHG-emissions) of paper & board production are reported as 809 kg/ton. The figure is not given any source reference.
We support the European Commissions intention to ensure that all packaging become reusable and refillable. As a French SME engaged in the protection against microbial contamination and infection risks, we are also concerned by the issue of microbial risk for reusable or refillable products. The benefits brought by the use of recycled or refillable packaging should be without compromises on human health.
17 MARCH 2023 DIGITALEUROPE position paper on the proposed Packaging and Packaging Waste Regulation Executive summary DIGITALEUROPE welcomes the revision of the EU Packaging and Packaging Waste Directive 94/62/EC and notes with appreciation the ambition and significant innovative thinking in the proposed revision which sets the direction to minimise the adverse impacts of packaging and packaging waste on the…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The ALPLA Group, with its 190 locations and 23,300 employees in 46 countries worldwide, is one of the leading global plastic converters and a growing recycler. We develop and produce innovative rigid plastic packaging solutions, while ensuring that our products become lighter, more durable and by 2025 fully recyclable.
European Commission DG ENV Unit B3 Brussels, 21 March 2023 EPF feedback on the Proposal for a revision of EU legislation on Packaging and Packaging waste COM(2022) 677 The European Panel Federation (EPF) welcomes the possibility to provide feedback on following the publication of the Proposal for a Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU)…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Sterile Barrier Association (SBA), the European trade association for companies, who produce Sterile Barrier Systems (SBS) and associated equipment and accessories for the healthcare industry, strongly supports global efforts to minimise the negative environmental impact caused by packaging.
Position on the proposal for a Packaging and Packaging Waste (PPWR) Regulation. we are Van Oordt, The Portion Company. Our history dates back to 1734. This is why we have enormous experience in producing and marketing portions in the food service segment. Own printing works, an arsenal of repackaging machines and a large dose of healthy entrepreneurship have made this happen.
Filed in Dutch · English published by the European Commission
ANEC welcomes the proposed regulation on packaging and packaging waste, as it will provide consumers with more convenient options for reducing their packaging waste. ANEC agrees with the choice of a regulation as the legal instrument as it will ensure equal implementation across Member States, unlike a directive.
The Packaging and Packaging Waste Regulation should drive recycling and the uptake of recycled and compostable packaging. CEFS approves of the general objective to reduce fossil carbon demand for plastic production. As modest users of plastics, CEFS members are all in the process of reducing their use of plastics for packaging their products.
Duni Group’s Submission to the European Commission (EC) public consultation on Packaging and Packaging Waste Regulation (PPWR) Overview Duni Group appreciates the opportunity to comment on the proposed Packaging and Packaging Waste Regulation (PPWR). We strongly support the PPWR’s objectives to reduce waste and drive circularity.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Comments of the bvse e.V. on the European Commission's proposal for a Regulation on packaging and packaging waste COM (2022) 677 final We hereby comment on the European Commission's proposal for a Regulation on packaging and packaging waste, COM (2022) 677 final.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Proposal for a Regulation on packaging and packaging waste Feedback March 2023 On 30 November, the European Commission presented a proposal for a regulation to revise the European legislative framework on packaging and packaging waste. This proposal raises a lot of concern among the economic actors involved.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We welcome 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. We particularly support the free movement within the EU of all types of packaging materials and harmonised criteria for sorting packaging waste.
REVISION OF THE PACKAGING AND PACKAGING WASTE DIRECTIVE; STATEMENT FROM THE NORWEGIAN PACKAGING ASSOCIATION OSLO MARCH 13 2023 The Norwegian Packaging Association supports the main intention of the PPWD draft and sees the necessity of tightening compliance with goals and goal achievement in the directives that the draft is intended to replace.
All aerosol dispensers independently of the container material should be covered by the same legal provisions. In the Annex II Table 1, the format aerosols is correctly included in the categories No 5 Metal / Steel and No 7 Metal / Aluminium. However the format aerosols is missing in the categories No 2 Glass / Composite packaging, of which the majority is glass and No 12 Plastic / PET rigid.
The European Environmental Bureau welcomes the proposal for the revision of EU rules on packaging and packaging waste. Notably, we support the proposed waste prevention and reuse targets, as well as the strengthened measures for tackling packaging waste.
Position Paper - Packaging and Packaging Waste Regulation The Association of Deposit and Return Systems welcomes 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).
The Rethink Plastic alliance welcomes the European Commission proposal for the Packaging and Packaging Waste Regulation (PPWR). Notably, we welcome the proposed waste prevention and reuse targets, as well as the strengthened measures for tackling packaging waste.
EUROPEN, the European Organisation for Packaging and the Environment, fully supports the objective of the Packaging and Packaging Waste Regulation (PPWR) proposal to contribute to the efficient functioning of the internal market for packaged goods, while preventing or reducing the adverse impacts of packaging waste on the environment and on human health. Please find our feedback on the proposal for a PPWR attached.
When done right, the revision of the EUs packaging rules can lead to less waste, boost the use of more sustainable materials in packaging and help companies to benefit from the Single Market. To ensure that the revision achieves this, we recommend that the new rules: 1. Restore the Single Market and avoid any further fragmentation. An EU-wide label for sorting will benefit the Single Market and lead to less waste.
Opinion on the Proposal for a Regulation on Packaging and Packaging Waste for Hellma Gastronomical Service Prague, spol. s r.o., Cukrovarská 982, 196 00 Prague 9 ID: [phone removed] TIN: CZ00674508 Established by: 1991 Number of employees: 93 hereinafter referred to as Hellma Prague
Filed in Czech · English published by the European Commission
CO.N.I.P. – Consorzio Nazionale Imballaggi Plastica is the first independent collective packaging management system set up in 1998 pursuant to Article 38 (3) (a) of Legislative Decree No 22 of 5 February 1997 (implementing Directives 91/156/EEC, 91/689/EEC and 94/62/EC on packaging and packaging waste) and then Article 221 (3) (a) of Legislative Decree No 152 of 3 April 2006. CO.N.I.P.
Filed in Italian · English published by the European Commission
Packaging is necessary to protect home appliances in the factory warehouses and during shipping, ensuring that the product is in good working order when it arrives at consumers homes, and consumer safety is ensured while using the equipment. The EUs proposed Packaging and Packaging Waste Regulation (PPWR) marks a landmark step to combat the over-packaging of products and growing amounts of waste.
· · filed 3 Mar 2023 · source
The MICROPAP Groupement brings together the main producers of coated paper food packaging intended mainly for the cheese industry but also for the confectionery industry and craftsmen in the lalimentation sectors. The cheesemakers market is a large European market in which food products are intact.
Filed in French · English published by the European Commission
JDE Peet's is committed to the continued reduction of packaging waste and the promotion of a circular economy. In line with the circular economy objectives, we are designing 100% of our packaging to be reusable, recyclable or compostable by 2030.
UPM is one of the leading producers of sustainable packaging materials in the EU. Our renewable raw materials - pulp, wood-based naphtha and renewable mono ethylene glycol (MEG) are used to produce recyclable fibre-based packaging and renewable plastics. Food and a myriad of consumer goods are packed safely in UPMs flexible paper packaging materials.
***Position on the proposal for a Regulation on packaging and packaging waste***! Hellma Gastronomie-Service GmbH is a medium-sized company and celebrates its 100-year anniversary this year. At today’s Nuremberg site, we employ 30 people, 10 of whom are in the field. Our food and non-food products are placed on the market for safe, adequate and hygienic food outside the home.
Filed in German · English published by the European Commission
· · filed 28 Feb 2023 · source
SAES, The Portion Company, S.L. was founded in the early 80s in Barcelona, Spain. We have a total of 17 employees in our factory, where we package sugar and sweeteners in different individual formats, mainly for the HORECA sector. We also distribute other individually packaged items such as biscuits, chocolate, jams, sauces, salt, pepper and many others.
Filed in Spanish · English published by the European Commission
Feedback from Keep Sweden Tidy Foundation (KST) General feedback KST is positive to the ambition of the commissions proposal. We too believe that there is need for and much potential in harmonization. According to the OECD, around 5-11 percent of the waste generated in the EU is leaking out of the system and becomes litter.
The RCTP welcomes the ambitious proposal of the European Commission for a review of the Packaging and Packaging Waste Regulation (PPWR). Please find below the RCTP's main concerns: Define reuse: Crucial for a successful transition to reuse is to define the properties of Packaging (art. 3) and reusable packaging (art. 10) to ensure the correct application of reuse.
In Germany, the dual systems have been operating for decades with a waste collection system, including the sorting and recovery of packaging waste from private households. This system is constantly being expanded and improved.
Filed in German · English published by the European Commission
Specialised Nutrition Europe (SNE) thanks you for the opportunity to provide feedback. In summary, Specialised Nutrition Europe (SNE) supports FoodDrinkEuropes position A circular economy for food and drink packaging and welcomes the objectives of the Commissions proposal.
· · filed 17 Feb 2023 · source
As a manufacturer of forestry and gardening machines we support the replacement of the Packaging and Packaging Waste Directive by a regulation with binding rules in all MS (member states of the EU). Currently, more and more MS have enacted binding, country-specific and complex legislation (e.g. TRIMAN in France) for sorting information of packaging waste.
MOL Group’s position on the Commission proposal for a regulation on packaging and packaging waste MOL Group is committed to helping the EU in reaching its circular economy objectives and is transforming to adapt to a circular and low-carbon world.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
FEDEPOM represents the main French market players. It is important: (I) the ban on packaging for fruit and vegetables concerns only plastic; (II) packaging which involves cooking or preparing fruit and vegetables in the final consumer is exempted.
Filed in French · English published by the European Commission
· · filed 15 Feb 2023 · source
Ladies and gentlemen, as a small entrepreneur from the Odenwald producing specialised signs, I have ESTABLISHED my shipment to this country (and other EU countries) due to the new Packaging Ordinance in Austria since 2023! It is simply too expensive and too cumbersome for me to go through this process for my minimal turnover to these countries!
Filed in German · English published by the European Commission
EUMEPS, the association of European Manufacturers of Expanded Polystyrene, welcomes the proposed EU regulation for the Packaging and Packaging waste Regulation (PPWR), as it believes that it may play an essential role to prevent and reduce the adverse impact of packaging and packaging waste on the environment.
The Association of Municipal Enterprises (VKU) welcomes the European Commission’s extensive efforts to contribute to waste prevention and better recycling through the new Packaging Ordinance (PPWR). This requires in particular sound eco-design, the use of recycled materials, rules on placing on the market and clarification of reuse and disposal, which the European Commission rightly recognises.
Filed in German · English published by the European Commission
The European Compost Network (ECN) welcomes the opportunity to comment on the Commissions public consultation on the revision of the packaging and packaging waste directive. First of all, the ECN acknowledges the efforts of the Commission in addressing the increase of packaging and packaging waste generation and tackling the limited competitiveness of secondary raw materials.
· · filed 13 Feb 2023 · source
We applaud the European Commissions goal, and support any regulation that is effectively fighting the climate crisis and brings us closer to a circular economy. We strongly urge the Commission, however, to keep measures at a reasonable level for small enterprises financially and bureaucratically!
· · filed 9 Feb 2023 · source
Brown-Forman is a global spirits producer, and a proud member of SpiritsEurope. We support legislation via a Regulation, to protect the Single Market. Additional national requirements should be strictly limited.
· · filed 8 Feb 2023 · source
Dear Sir or Madam, Please find attached our modest comments to the current proposal - in request for kind consideration as per below: 1, Amendment of the definition "separate component" - to same logic as in german minimum standard Article 3 (35) separate component means a packaging component that is distinct from the main body of the packaging unit, which may be of a different material, that needs to be…
Almost 40% of European plastics consumption comes from packaging, but currently, more than 98% of the European plastics production derives from fossil fuels. Braskem therefore calls on the European Parliament and Member States to include biobased content targets for plastics, alongside recycled content mandates, in the Packaging and Packaging Waste Regulation.
For us, the German plastic packaging manufacturers, the proposed regulation offers an opportunity for the sustainable transformation of the entire packaging industry. Our members have invested in the recyclability of their products and stand ready with innovative solutions that combine high material efficiency with high recyclability and the use of recycled materials.
Safety exemptions in Packaging and Packaging Waste Directive Duracell Supports Revision of Packaging and Packaging Waste Directive Duracell fully supports the Commission's intention to review the Packaging and Packaging Waste Directive and has applied sustainably sourced cardboard to significantly reduce plastic in its packaging.
Ensure that circular business models are incentivized considering their environmental benefits and facilitate a secure and high-quality supply of secondary raw materials by: - Strengthening the role of the chemical sector in the processing of waste and the high-quality use of renewable raw materials. - Creating a stable and balanced tax regime in Europe for landfilling and burning of waste.
· · filed 30 Jan 2023 · source
The Vienna Forum for Democracy and Human Rights considers the proposed Regulation the right instrument for the purpose of reducing packaging waste in the marine environment as it sends a clear signal to non-EU market actors intending to place packaging products on the EU market. We support Art. 6, that requires packaging to be recyclable and sets out a two-stepped approach.
SFIF welcomes the European Commission´s objective to set revamped harmonised rules on packaging and packaging waste with the aim of putting an end to wasteful packaging and boosting its reuse and recycling. In the framework of the European Green Deal and the Circular Economy Action Plan, it is crucial to ensure that products placed on the European market contribute to reach the climate neutrality by 2050 objective.
We can only urge the EU to ensure that Member States do not complicate the single market by creating unnecessary barriers to trade and red tape that makes it economically impossible for small businesses to participate in the single market.
Filed in German · English published by the European Commission
· · filed 26 Jan 2023 · source
I am a sole trader and sell mainly within Germany, with a good handful of broadcasts going to Austria every year. All packed in either small air cushion bags or small cartons. Once it is licensed in Germany, it should be enough to grant a system of compulsory packaging. In addition, a licence has to be issued in Austria and, more recently, an agent for Austria is required, who in my case would cost 75.
Filed in German · English published by the European Commission
· · filed 26 Jan 2023 · source
The problem is how to deal with us, small and medium-sized enterprises, which send to other European countries. 1. There are no requirements for uniform minimum quantities, which would relieve shippers of small quantities financially. 2. The appointment of authorised representatives in each Member State in accordance with Article 40(2) of the draft is not feasible for small online traders.
Filed in German · English published by the European Commission
· · filed 24 Jan 2023 · source
Ladies and gentlemen, as a small business, this legal project simply triggers disappointment. This does not seem to have taken account of small businesses. I am a sole trader and earn my monthly salary with my online shop on Etsy, a global platform for small shop operators like me (EU/Europe/World).
Filed in German · English published by the European Commission
· · filed 21 Jan 2023 · source
As an online trader, I welcome the Packaging Act in general. It is unfortunate that some countries are treated separately, such as Austria, which makes it extremely difficult than traders to adequately comply with all the rules. In my view, this blocks the free market in Europe and reduces market diversity and the benefit of big players.
Filed in German · English published by the European Commission
· · filed 20 Jan 2023 · source
During the pandemic or now in the war on Ukraine, one can see the disadvantages that globalisation can have. However, the packaging laws within the EU should certainly not help to make it almost impossible for many small online traders to sell outside their own country within the EU... If you are struggling to introduce all the rules in a few months, it may be very different again.
Filed in German · English published by the European Commission
· · filed 18 Jan 2023 · source
Revision of the EU Packaging and Packaging Waste Directive: the EC proposal While the final text of the Packaging and Packaging Waste Regulation proposal, issued on November 30, seems to acknowledge that the line taken by DG ENV in its earliest drafts was totally unrealistic, very serious concerns remain on the overall approach taken by the European Commission in its revision of the existing legislation.
· · filed 18 Jan 2023 · source
All of our packaging is licensed in DE and therefore paid for. Why do we need to do this twice all over the world and how should we find out which packaging has been sent to which country with which order? Would we need to recredit the licence fees for DE for the amount paid in other countries and how should it work? This is what only someone who has no idea of the practice thinks, but this is not so rare.
Filed in German · English published by the European Commission
We believe that the European Commission has come up with a good response, which could lead to a necessary green paradigm shift in packaging, yet it is hardly enough to bring the EU into a fully sustainable future, just as the deadlines are too far away. Finally, packaging, and not only waste, is regulated.
Filed in Danish · English published by the European Commission
VYJÁDŘENÍ POTRAVINÁŘSKÉ KOMORY ČR (DÁLE JEN “PK ČR”) K RÁMCOVÉ POZICI K NÁVRHU NAŘÍZENÍ O OBALECH A OBALOVÝCH ODPADECH Obecné poznámky 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, zavedou minimalizaci obalů a zabrání vzniku obalů, pokud nejsou…
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)
The BGK strongly opposes the disposal of so-called compostable packaging and plastics through biological waste treatment (composting, digestion). The only exception is bio-waste bag, if it is explicitly permitted, desirable and suitable by the public waste disposal entities in consultation with the local recovery facility.
Filed in German · English published by the European Commission
· · filed 15 Jan 2023 · source
Since 2005, Good Day has been like a small online trader based in Germany with a niche product that is available almost exclusively through specialised traders throughout the EU. At the beginning of 2023, we unfortunately had to stop shipping to most EU countries.
Filed in German · English published by the European Commission
· · filed 14 Jan 2023 · source
Good day, the regulatory burden is increasingly destroying the European single market for small traders in the most cumbersome and bureaucratic way possible. The totals for registration are not high in some cases, but they often exceed the yield of the items sold to the countries concerned, and time cannot be taken into account in any case.
Filed in German · English published by the European Commission
· · filed 13 Jan 2023 · source
As a trader, we are sending to the EU, it is simply impossible to follow and implement the whole rule of packaging licence. We would like to see this done by means of a uniform flat rate or notification to e.g. the home country, but in every EU country some rules do not add value and exclude small traders from the market.
Filed in German · English published by the European Commission
As a small business owner, with exclusively online sales across the EU through the big platforms, it is impossible for me to register and buy a license in every single required country and still make a profit selling in those countries such as Spain, France, Luxembourg, Austria etc. and I have had to stop selling to these countries.
· · filed 9 Jan 2023 · source
Ladies and gentlemen, as a result of the amendment to the Packaging Ordinance which entered into force at the beginning of this year, it has been shown that many small and medium-sized enterprises from abroad have stopped supplying them to Austria.
Filed in German · English published by the European Commission
· · filed 9 Jan 2023 · source
Of course, we welcome a meaningful packaging reform which is absolutely necessary. However, implementation so far in the EU countries shows only one thing: free movement of goods is possible, but without packaging. In fact, the free movement of goods within the EU is therefore no longer fully possible. We already had to remove several countries from our mailing list, and new ones were added in 2023.
Filed in German · English published by the European Commission
· · filed 4 Jan 2023 · source
Ladies and Gentlemen, the EU’s internal market should ensure free movement of goods, the Geo-blocking Regulation prevents certain countries from being excluded, but the huge differences in the requirements, the different costs involved and the burden of administering the requirements prevent or do not make it impossible.
Filed in German · English published by the European Commission
· · filed 4 Jan 2023 · source
Good day, but I am a convinced European, but what I think of incapacitated people makes every effort to make a common Europe as impossible as possible is invisible to me. We certify (all) our packaging in D if we then send five packets to A cost a few hundred euros. Indisputably, this is something that can be thought of at all – and then it is still being implemented. For shame!
Filed in German · English published by the European Commission
· · filed 3 Jan 2023 · source
Ladies and gentlemen, I have been sending a long period of time to other EU countries and Switzerland. There should be more countries to follow. I have to consider this seriously. However, I have gone down on what we are supposed to pay for the ‘dummty’ of final consumers. Why can each country cook its own kitchen? Why is this not regulated collectively, at least for the EU?
Filed in German · English published by the European Commission
· · filed 3 Jan 2023 · source
At present, the Packaging Ordinance already leads to different reporting and registration obligations for companies in different countries, e.g. importing packaging by mail order (dispatching) to the Länder. A recent example is Austria, where, since 1 January 2023, a responsible person established in Austria must be designated by notarial certification.
Filed in German · English published by the European Commission
· · filed 2 Jan 2023 · source
We are a small family business and operate a pan-European online mail order. We generally support any measures to reduce packaging waste. For example, we use cardboard boxes and upholstery material from principle, even though this is usually uneconomical. However, the envisaged measures of this Regulation exclude us from the EU market.
Filed in German · English published by the European Commission
· · filed 2 Jan 2023 · source
Ladies and Gentlemen, I have a small online shop for teaching and learning materials and benefit from the harmonisation of the EU internal market, which allows me, as a small entrepreneur, to be able to offer my products not only in Germany but also throughout the EU. The customer community is small, I send a package once a week and I have more money in the account at the end of the year than before.
Filed in German · English published by the European Commission
· · filed 2 Jan 2023 · source
Dear Members of the European Commission, I am writing to you as a small enterprise with its registered office in Austria and would like to express a clear opposition to the last version of the EU project ‘Reducing packaging waste’! We believe that the new packaging rules for small businesses, like us, are very difficult to implement!
Filed in German · English published by the European Commission
· · filed 2 Jan 2023 · source
For small traders, the many different directives per country are far too burdensome, too costly and too opaque. A single set of rules for all EU countries would be useful here. I do not think it is necessary to have an authorised representative. This only drives costs even more. Much more would make sense for better control from non-EU countries.
Filed in German · English published by the European Commission
· · filed 30 Dec 2022 · source
As a small trader, the multitude of national packaging regulations is one reason why I will no longer sell across the EU. It is impossible to comply with all national requirements and I do not understand why, at least for small businesses, there is no EU-wide scheme that I can fulfil once at the central level.
Filed in German · English published by the European Commission
· · filed 29 Dec 2022 · source
While efforts to reduce packaging waste are welcome, registration in each country is impracticable for small and medium-sized enterprises (like my) and will reduce domestic trade and destroy jobs. There must be either sufficiently high thresholds (European or for each country) or centralised clearance for the EU as a whole.
Filed in German · English published by the European Commission
· · filed 29 Dec 2022 · source
Dear people, who, like me, frustrated these strange and disturbed packaging rules for each EU country, my full disregard! Is there something without the EU’s bureaucratic dictatorship? Are you afraid of shipping cartons and packaging waste that is already taxed and paid for here too? Stick more about how to do it better... [name removed], [email removed]
Filed in German · English published by the European Commission
· · filed 29 Dec 2022 · source
Ladies and gentlemen, I think it is in principle good for those responsible for packaging waste to be held responsible – for years I have fulfilled my obligations to the best of my knowledge and belief. However, for a few years, the sum of the packaging regulations within the EU has evolved in a completely wrong direction and is increasingly damaging to the EU’s internal market.
Filed in German · English published by the European Commission
· · filed 28 Dec 2022 · source
Ladies and Gentlemen, I run a small company that sends very small quantities to the EU. Because I am specialised, EU customers cannot buy everything in their own country. Please see EU uniformly exclude small quantities (e.g. up to 1 000 kg) from licences abroad. No representatives and extra costs for bureaucracy. In Germany, I am registered and use almost exclusively already licensed packaging.
Filed in German · English published by the European Commission
· · filed 27 Dec 2022 · source
Ladies and Gentlemen, I welcome the rules on the reuse of packaging for the overall reduction of waste. What, however, will be impossible and detrimental to the economy is the rules that you also bring to the attention of small businesses. Many HandMade companies with special products will no longer be able to deliver de facto because red tape and additional costs will not be sustainable.
Filed in German · English published by the European Commission
Although we do agree with the general reasons and objectives of the proposal, we do not understand the bias towards banning plastics, especially when they are the best alternatives. We should better use environmental footprint analysis (PEF method developed by the Comission) to analyse packaging alternatives without any bias.
· · filed 26 Dec 2022 · source
Dear Members of the European Commission, I would like to comment on behalf of my GbR on the EU project “Reducing packaging waste”. Of course, environmental protection is an important concern and regulation in this area is therefore to be welcomed in principle.
Filed in German · English published by the European Commission
· · filed 24 Dec 2022 · source
DEAR Ladies and Gentlemen, In principle, who supports the use of post-consumer regranulates in packaging and thus the closing of material cycles. However, the market does not offer the required qualities and it is therefore foreseeable that the required qualities will not be available. There are many critical applications.
Filed in German · English published by the European Commission
· · filed 22 Dec 2022 · source
In principle, I welcome a scheme to reduce packaging waste. However, it is currently taking a wrong approach. It is too burdensome and costly for smaller companies in particular. It is a considerable effort to appoint a representative for each country. It is often impossible for a smaller entrepreneur to say to which country he actually sends or within what limits.
Filed in German · English published by the European Commission
· · filed 22 Dec 2022 · source
Dear, we report on the draft law amending the EPR for packaging in the EU. This implementation would mean the death of countless small online shops and Amazon traders selling within Europe. These small shops cannot afford any representative in any EU country simply to sell in that country. The bureaucratic hurdles are simply impossible to implement.
Filed in German · English published by the European Commission
· · filed 20 Dec 2022 · source
Hello and Good Day, I have a small online shop on Etsy, like tens of thousands of other people in the EU. I am a small entrepreneur in Germany. I am sending vintage goods worldwide. I am sending (like many others) the vast majority of used materials such as cartons, newspapers as packaging material, etc.
Filed in German · English published by the European Commission
· · filed 19 Dec 2022 · source
We very much welcome the fact that it is finally starting to stop the overload of packaging. However, it is not on the backs of micro-entrepreneurs, who are building extreme barriers to entry. Implementing the regulations in the way envisaged further promotes the monopolistic position of large companies, for which the costs and costs of such implementation do not represent a threat of administrative and financial…
Filed in German · English published by the European Commission
We are facing many difficulties in managing our packaging obligations in the EU. We are selling in over 25 countries, and each country has a different interpretation of the EU Directive. As such, there is a total lack of harmonisation. For example, how is it possible that the Green Dot is forbidden in one country and is made mandatory in another?
High ambition of revised Packaging Waste Regulation and its targets must be preserved This is our feedback on a public consultation about the proposed regulation on Packaging and Packaging Waste (COM(2022)677) presented by the European Commission on 30.11.2022.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 17 Dec 2022 · source
This new rule is a step 1,000 years ago. Micro-attractiveism, as in the Middle Ages, has nothing to do with the basic idea of the EU. Small traders will not be able to afford red tape and financial barriers to selling to other EU countries. It seems that the lobby of large corporations has fled the responsible party here. In any case, useful tools should be put in place to reduce packaging waste.
Filed in German · English published by the European Commission
Ladies and Gentlemen, I am the owner of a small business in the fashion industry in Germany. I sell my own manufactured products via an online platform. In principle, I welcome the efforts to reduce or recycle packaging. The different developments in the Packaging Regulations in Europe have led in my shop to stop shipping within the EU and only to sell in Germany. The requirements of the current provisions, e.g.
Filed in German · English published by the European Commission
· · filed 16 Dec 2022 · source
Dear Commission, as a French TPE manufacturer of cosmetic products, we have taken steps to reduce unnecessary packaging and reduce unnecessary packaging from our inception. However, the draft of the new rules is inconsistent and will drastically reduce access to the common market for businesses such as ours. The cost of registering representatives in each country is simply prohibitive.
Filed in French · English published by the European Commission
· · filed 16 Dec 2022 · source
From 2023, as a small business owner, I can no longer deliver to Austria because it is an authorised representative is too expensive as a small business owner, I cannot ship to all EU countries because the requirements are too clear or too expensive a representative in every country but my own would exclude me as a small business owner from the EU single market For consumers, this means a significant reduction in…
Filed in German · English published by the European Commission
· · filed 16 Dec 2022 · source
Ladies and gentlemen, as the father of two children, I fully support environmentally sound disposal and responsibility. However, the rules currently provided for make life easy for small businesses, especially for small businesses, the large corporations in tax havens, as well as anonymised suppliers from the Far East, and destroy small and medium-sized firms.
Filed in German · English published by the European Commission
· · filed 16 Dec 2022 · source
There is no doubt that uniform and fair rules for extended producer responsibility for placing packaging on the market are essential for environmental and climate protection across the EU. However, both the existing rules and those provided for in the new draft Packaging Ordinance presented by the European Commission on 30 November 2022 lack the necessary degree of fairness.
Filed in German · English published by the European Commission
· · filed 15 Dec 2022 · source
small businesses will no longer be able to send to Austria as of 2023, because an authorised representative is too expensive and for few consignments per year, as small businesses cannot already send to all EU countries, because the requirements are too unclear or too expensive. The use of an authorised representative in each country apart from his own would exclude small businesses from the EU’s internal market!
Filed in German · English published by the European Commission
· · filed 15 Dec 2022 · source
There must be a central office for registration, reporting of quantities and payment of levies, and much more importantly a de minimis threshold under which small businesses are exempt from registration and also levies! This is because, as is currently the case, small businesses in the EU are severely disadvantaged!
Filed in German · English published by the European Commission
· · filed 15 Dec 2022 · source
Ladies and Gentlemen, Environmental protection is all about us and must be important for all of us. As a small trader, I am already doing everything possible to send my products to my customers as low packaging as is possible while maintaining a safe delivery. However, the current rules on packaging prevention already have the effect of excluding small businesses from the European market.
Filed in German · English published by the European Commission
Environmental protection and protection is important. I have been working for years to minimise the packaging waste generated by my online mailing. I only introduce cartons and paper into the circuit as new packaging – all upholstery materials such as plastic, foam, styropore or upholstery flakes are recycled material from the supplier’s consignments. But: The administrative burden on EPR is slowly overloaded.
Filed in German · English published by the European Commission
· · filed 15 Dec 2022 · source
Ladies and gentlemen, the reduction of the volume of packaging and the standardisation of the labels for the labelling of components are very welcome measures. But small businesses are already excluded from pan-European trade. The reporting and charging rules are simply opaque and totally uneconomic for most.
Filed in German · English published by the European Commission
Ladies and Gentlemen, I do not want to prevent and welcome a scheme to reduce packaging materials and the payment of a licence. However, for small businesses such as myself, the rules adopted by individual EU Member States cannot be overcome and lead to an end to EU-wide mailing and shopping opportunities for consumers.
Filed in German · English published by the European Commission
· · filed 15 Dec 2022 · source
— very good the creation of uniform systems: The same symbols and labels (e.g. on waste containers) will be used throughout the EU. — By 2040 there should be a 15 % reduction in packaging waste compared to 2018? what is packaging waste? Is this waste now entering the residual waste? Otherwise, this seems to me to be very unambitious. — WB separate collection in households is already doing well in Flanders.
Filed in Dutch · English published by the European Commission
· · filed 15 Dec 2022 · source
Dear Sir or Madam, I welcome the approach to harmonizing the EPR for all states in the EU. The current patchwork of regulations, which in part is only available in the native language of each state, prevents small businesses from using the whole market of the EU. Regulations like high fees for registration or authorized representatives are no burden for big companies.
· · filed 15 Dec 2022 · source
Authorisations are the death sentence for a large number of small entrepreneurs and EPUs. We cannot afford to pay these fees for several countries, which means that we become very limited in the customer base, which is particularly fatal for small countries such as Austria.
Filed in German · English published by the European Commission
· · filed 15 Dec 2022 · source
Ladies and gentlemen’s obligation to have one authorised representative per country to which they are sent represents a huge additional cost for small businesses and already means that we exclude Austria as a dispatch destination in 2023. Reducing shipping materials and waste prevention is an important step. We use almost exclusively two-hand boxes and packaging.
Filed in German · English published by the European Commission
· · filed 15 Dec 2022 · source
Ladies and gentlemen’s obligation to have one authorised representative per country to which they are sent represents a huge additional cost for small businesses and already means that we exclude Austria as a dispatch destination in 2023. Our Austrian customers are already looking for alternatives, such as delivery and delivery to a parcel service provider at the border, in order to receive their goods there.
Filed in German · English published by the European Commission
· · filed 15 Dec 2022 · source
As a small star on e-commerce, I feel discriminated against by EU politics. This EU requirement is knowingly punishing and ignoring hundreds of thousands of small businesses, which are already dealing with packaging waste much more environmentally and sustainably than the big ones.
Filed in German · English published by the European Commission
· · filed 15 Dec 2022 · source
Ladies and gentlemen, the Packaging Ordinance results in serious obstacles to intra-EU trade in small and micro-enterprises. Many German small businesses, for example, cease to send them to Austria on 1 January 2023 because the registration barriers and costs are so high. Small German traders have not been sending to other countries such as Spain for years.
Filed in German · English published by the European Commission
· · filed 9 Dec 2022 · source
At ecosistant, we welcome the approach of the European Commission for harmonization of packaging waste EPR, packaging labels for recycling, and packaging/recycling standards. However, although the Commission aims for specific treatment of SME`s and micro-enterprises to ensure that the impacts on them are proportionate, we fear that the current proposal will further increase the burden on SMEs and make it impossible…
· · filed 7 Dec 2022 · source
In the case of the Regulation, it has to be forgotten to set lower quantities. This will push small and micro-enterprises out of the EU’s single market and discriminate against them. We put forward our arguments on change.org and launched a petition: https://chng.it/bTKHTRMmDZ Please support this petition. Yours sincerely, oldthing.de [name removed]
Filed in German · English published by the European Commission
· · filed 5 Dec 2022 · source
It is very important to have uniform packaging labelling requirements. Today, some EU countries require a specific symbol to be displayed on the packaging when a product is sold in their country, while another EU country may have a direct requirement that this symbol should not appear on the packaging when the product is to be sold in their country. This has several negative consequences.
Filed in Danish · English published by the European Commission
· · filed 6 Aug 2020 · source
Dear Sir/Madam, in order to address climate change and its consequences, the management of packaging can play an important role. Preference should be given to the use of renewable raw materials. Wood, as a renewable CO2 reservoir and very long-term as a result of cascading use, offers ideal conditions for this. Wooden pallets, for example, have a clear advantage over plastic pallets.
Filed in German · English published by the European Commission
IK represents the plastic converting industry in Germany in the field of plastic packaging production with about 300 member companies, mostly SMEs. The branch produces a revenue of 15 bn Euro and employs about 90,000 people. We welcome the European Commission's goals of climate neutrality and a circular economy as laid down in the Green Deal.
EUROFER welcomes PW prevention measures that take into account the wider scope of a circular and resource efficient economy, ensuring a net decrease in carbon emissions. It is worth to look at design for high-quality recycling, guaranteeing high-quality input in the recycling operations.
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Eurima (European Mineral Wool Insulation Manufacturers) supports the efforts of the European Commission on the revision of the requirements for packaging and packaging waste. Our industry is committed to constantly improve the packaging of our products by reducing the use of “fossil based/virgin plastic” and increase the recycle content when it is technically feasible and economically viable.
Oceana is the largest international organisation dedicated solely to the conservation and defence of the oceans. Oceana focuses its efforts on restoring marine richness and biodiversity around the world and on implementing science-based policies in countries that control one third of the world's fish catch. Oceana supports measures intended to prevent waste and encourage reuse.
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Lets Do It Foundation, as the initiator of World Cleanup Day, a movement mobilizing millions of people to tackle the waste problem in their communities, welcomes this initiative and fully supports the aim that all packaging in EU should be recyclable or reusable. Our main suggestions to this review: 1. support deposit-return schemes (DRS) to scale up reuse.
The cosmetics industry in Poland shares the European Commission views with regards to the impact of climate change by 2050. The Polish Union of the Cosmetics Industry welcomes the European Commission’s European Green Deal announcement and its goals.
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CEPE contribution to EU consultation Review of the requirements for packaging and other measures to prevent packaging waste CEPE, in principal, supports any meaningful initiative aimed at preventing packaging waste.
EuroCommerce welcomes the opportunity to provide feedback regarding the Inception impact assessment on the review of the requirements for packaging and other measures to prevent packaging waste. The attached statement aims to summarize key points from the retail and wholesale sector on the essential requirements for packaging and support the Commission’s work in revising the Packaging and Packaging Waste Directive.
FCIO welcomes the European Commission’s European Green Deal and supports the overarching goals of the European Union to become CO2 neutral by 2050. We consider the following principles as critical elements for the discussion on essential requirements for packaging: - The initiative should contribute to the achievement of the circular economy goals - Optimized implementation and enforcement of existent legislation…
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FINAT is the European association for the self-adhesive label industry. We welcome the opportunity to provide feedback on the European Commission’s initiative, “Review of the requirements for packaging and other measures to prevent packaging waste,’’ and in particular regarding updates to the essential requirements for packaging to enable greater circularity.
The Extended Producer Responsibility Alliance (EXPRA), representing industry-owned, non-profit packaging and packaging waste recovery and recycling organisations, welcomes the opportunity to provide feedback on packaging waste prevention and essential requirements as part of the EU consultation on the PPWD review.
Citeo strongly welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to review requirements for packaging and other measures to prevent packaging waste. Citeo shares the Commission’s findings on the need for clearer and more specific requirements on the composition and the reusable and recoverable, including recyclable, nature of packaging.
Please, find attached FEAD’s full feedback to the EC Roadmap on Packaging Waste. FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the EC initiative on the review of the requirements for packaging and on other measures to prevent packaging waste and considers it of the utmost importance in achieving a…
Veolia is the global leader in optimised resource management. With over 163 000 employees worldwide, the Group designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries.
The NABU considers the measures planned by the European Commission to be useful and urgently necessary in order to minimise the negative environmental impacts of packaging and packaging waste (e.g. CO2 emissions from waste incineration, aquatic and terrestrial pollution from littering, biodiversity loss due to extraction of raw materials).
Filed in German · English published by the European Commission
NRK Verpakkingen, the Dutch trade association for plastic packaging manufacturing and trade, appreciates the opportunity to give input for the public consultation “Reducing packaging waste – review of rules”. Our main messages: 1. Sustainability is at the heart of packaging: new policies should always consider this. 2. Improve sustainability by dealing with the whole chain; no focus on packaging only. 3.
APK AG welcomes the initiative of the European Commission (EC) to examine the feasibility of reinforcing the Essential Requirements (ER) for packaging with a focus on 'improving design for reuse and promoting high quality recycling'.
Please refer to the document in the Annex for the full FoodDrinkEurope contribution to the Packaging and Packaging Waste Directive Inception Impact Assessment. The end goals of the future PPWD and the new Circular Economy Action Plan (CEAP) should be to reduce and limit the environmental footprint of the life cycle of providing products to the end consumer and ensure that no packaging waste ends up into the…
Introduction Stiftung Initiative Mehrweg (SIM) is a German civil law foundation which was established in 1996. It is SIMs objective to sustainably support the conservation of natural resources, to protect the environment and to promote the use of reusable systems in all economic sectors. The Executive Board of SIM is composed of mainly CEO´s and other Senior managers being active in the reuse industry.
03 August 2020 1 (2) Stora Enso reply to consultation on the review of the requirements for packaging and other measures to prevent packaging waste Stora Enso 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, as well as developing the single market for secondary materials.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We thank for the opportunity to give our feedback on the Roadmap on Review of the requirements for packaging and other measures to prevent packaging waste. Kotkamills is a Finnish forest indsutry company. We also manufacture packaging boards for flexible boxboards as well as for food packaging.
The Steel Association welcomes the Commission’s efforts to reduce packaging waste and promote recycling. The European Packaging Directive, as a regulatory pillar of packaging recycling, has managed to bring large quantities of packaging back into the recycling cycle, although this is almost exclusively the case for traditional packaging materials such as steel and tinplate, for which recycling systems already…
Filed in German · English published by the European Commission
Neste Corp. (www.neste.com) is the world’s largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the polymers and chemicals industries. Our business is focused on combating climate change and driving circular economy, and we are committed to becoming a solution provider in chemical recycling by providing cost-effective and sustainable innovations.
PLEASE FIND ATTACHED OUR FULL POSITION Reusable Packaging Europe (RPE) is the European association which represents the interests of companies active in the area of reusable transport packaging systems, primarily in the pooling of Reusable Packaging Containers (RPCs).
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Hello, At the association No Plastic In My Sea, we believe it is necessary to: — A ban on the marketing of non-recyclable packaging — A reduction target for plastics production in the global and sector by sector — Reduction targets for plastic packaging and packaging with negative environmental impact — encouragement of innovation to transform models, including drinks in plastic bottles and take-away/delivery of…
Filed in French · English published by the European Commission
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Hello here are a few additional comments on an otherwise excellent programme: The focus will be on developing packaging free business models first, then reuse. Packaging recycling should focus first on the separate handling of food packaging.
Filed in Danish · English published by the European Commission
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Europe’s action on reducing natural resource consumption is long overdue, and the huge amounts of packaging waste being produced every year is a clear sign that we have failed to implement the policies that will deliver on making the waste hierarchy a reality. Focusing on recycling will not do the trick.
The natural qualities of timber make wooden packaging an environmentally friendly packaging solution. Wood pallets and wood-based packaging are almost completely made out of wood. And wood’s strong environmental credentials have been captured in various Life-Cycle Assessment studies and Environmental Product Declarations. Generally speaking, wooden packaging as divided into two subgroups: 1.
Re: Inception Impact Assessment: Review of the requirements for packaging and other measures to prevent packaging waste (Inception Impact Assessment) Background Areco: Asociación de Operadores Logísticos de Elementos Reutilizables Ecosostenibles (“ARECO” – Association of Logistics Operators for Eco-sustainable Reusable Items) is a Spanish industry association representing and promoting the usage of reusable…
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A.I.S.E. supports the revision of the existing requirements for packaging and the consideration of other measures to prevent unmanaged packaging waste. A.I.S.E. calls for a revision that helps steering tangible progress, while stimulating innovation and competitiveness of the EU industry in a well-functioning Single Market, allowing free movement of packaging and packaged goods.
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MedTech Europe - the European trade association for the medical technology industry including diagnostics, medical devices and digital health - welcomes the opportunity to contribute to the initial roadmap consultation regarding the review of the requirements for packaging and other measures to prevent packaging waste.
CEWEP feedback on the European Commission’s Review of the requirements for packaging and other measures to prevent packaging waste Within the review of requirements for packaging and other measures to prevent packaging waste, CEWEP would like to highlight the importance to maintain a holistic approach and to strike the right balance between policy goals (e.g.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Packaging is an essential element of the European fresh fruit and vegetable supply chain. The fresh produce sector uses packaging throughout the supply chain from production, wholesale, logistics, trade and at retail level to provide safe, high quality and fresh products to consumers.
CONTRIBUTION OF MOL GROUP MOL Group welcomes the objective of the initiative to establish a well-functioning market for secondary raw materials through fully harmonised rules on packaging while tackling negative impacts on environment and health from packaging and packaging waste.
Verband der deutschen Lackund Druckfarbenindustrie e.V. VdL-Position zum Fahrplan: Überprüfung der Vorschriften Verringerung von Verpackungsabfällen – Der Verband der deutschen Lack- und Druckfarbenindustrie e.V. (VdL) unterstützt jede sinnvolle Initiative zur Minimierung von Verpackungsabfällen, insofern sie wirtschaftlich tragfähig ist.
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)
July 2020 REPLY TO THE CONSULTATION ON THE INCEPTION STUDY ON REVIEW OF THE REQUIREMENTS FOR PACKAGING AND OTHER MEASURES TO PREVENT PACKAGING WASTE PlasticsEurope welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to review the rules regulating the placing on the market of packaging with a view to make packaging increasingly sustainable and circular, and minimize…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
• The European Dairy Association (EDA) welcomes the Commissions effort to review the Packaging and Packaging Waste Directive, including the Essential Requirements, with a focus on ensuring a European framework for investments in new and cutting-edge packaging solutions, supporting the reduction of packaging waste and enhancing the sustainability of packaging in an economically viable manner.
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The Estonian Food Industry Association supports the objectives of the European Union’s Green Deal policy to move towards a cleaner environment, more efficient use of resources and a carbon-neutral economy. We support the proposal of producer organisations that in 2030 all packaging on the EU market should be reusable or recyclable.
Filed in Estonian · English published by the European Commission
Tetra Pak supports the EU Commission’s objectives for the revision of the Packaging and Packaging Waste Directive (PPWD) to ensure the internal market for packaging, compliance with recycling targets and the reduction of packaging waste.
European Paper Packaging Alliance Response to the Inception Impact Assessment for the Review of the Packaging and Packaging Waste Directive The European Paper Packaging Alliance (EPPA) is a not-for-profit food and foodservice packaging association. EPPA’s priority is to provide efficient environmental, low carbon and health-safe products to the European population, with improved recycling solutions.
Feedback on the review of the requirements for packaging and other measures to prevent packaging waste FNADE, the French association for waste management, welcomes the European Commission's initiative to reduce and better recycle packaging waste. First of all, this initiative will have to ensure that the reusability of packaging does not hinder its recyclability at the end of its life.
Henkel fully supports the European Commission’s ambition for a transition towards a more sustainable and circular economic system in packaging. Thus, we are welcoming the review of the Packaging and Packaging Waste Directive in order to fully realize the potential of a Circular Economy, notably through addressing the supply gap of high-quality secondary raw materials and increasing the competitiveness of recycled…
ACE Iberia supports an ambitious implementation of the Packaging and Packaging Waste Directive, as well as the new Circular Economy Action Plan. This is a unique opportunity to scale up the contributions of materials towards a circular economy and climate neutrality by incentivising the efficient use of low carbon and circular packaging.
Attached is feedback submitted on behalf of European Bioplastics. We believe that bioplastics are a major driver in the evolution of plastics and that they contribute significantly to a more sustainable society. Our mission is to advance the economic and regulatory framework in Europe to allow for the bioplastics market to grow and flourish.
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Feedback to the EU Inception Impact Assessment on the initiative “Review of the requirements for packaging and other measures to prevent packaging waste”. BillerudKorsnäs provides packaging materials and solutions that challenge conventional packaging for a sustainable future. We are a world-leading provider of fibre based packaging materials and support customers with packaging solutions for food and beverages.
Intergraf, the European federation for the printing industry, welcomes the European Commission’s review of the essential requirements of packaging. A key part of the value chain and the circular economy, the printing industry brings together the materials, ink, and packaging design which make the final packaging product.
The European Snacks Association asbl (ESA) is Europe's only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers, as well as national trade organisations.
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As Borealis, producer of polyolefin plastic resins for packaging applications as well as active recycling company, we welcome clearer legislation on the essential requirements for packaging. This will incentivise a higher degree of circularity, whilst at the same time maintaining the principles of a unified European market, optimizing the use of natural resources in balance with content preservation, stimulating…
WKÖ comment Kommentar zu Inception Impact Assessment „Review of the requirements for packaging and other measures to prevent packaging waste“ Die Wirtschaftskammer Österreich bedankt sich für die Gelegenheit zur Initiative „Überprüfung der Anforderungen Verpackungen und andere Maßnahmen zur Verhinderung Verpackungsabfälle“ Stellung zu nehmen.
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)
FEFPEB is the European federation of the wooden pallet and packaging industry, a "not for profit" organisation representing the manufacturers, repair and trade companies in the field of wooden packaging and related organisations (www.fefpeb.eu). FEFPEB underlines the importance to ensure free movement of packaging and packaged goods and to ensure a well-functioning market for secondary raw materials.
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With regard to the roadmap, the Compost & Biogas Association Austria would like to emphasize that the reduction of packaging waste must comply with the following principles: -Wherever possible, single use products should be replaced with reusable ones. Packaging design and extended producer responsibility are to be considered in line with the circular economy strategy.
Rethink Plastic feedback Roadmap on Reducing Packaging Waste August 2020 Rethink Plastic Alliance welcomes the review of the requirements for packaging and measures to prevent packaging waste. Here we outline our main comments on the inception document. A. Context, Problem definition and Subsidiarity Check Growing levels of packaging waste are problematic both from a climate and a natural resource perspective.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
BBIA represents producers of compostable packaging sold, produced and distributed in the UK. We welcome the revision of the Packaging and Packaging Waste Directive with a view to reducing packaging waste. We suggest the guidelines adopted by WRAP in the UK (see https://www.wrap.org.uk/compostable-plastic-packaging-guidance) as a basis of discussion for the role of compostable materials in a transition towards…
Comment on Inception Impact Assessment „Review of the requirements for packaging and other measures to prevent packaging waste“ When amending the essential requirements on packaging to improve design for reuse and promote high quality recycling, it should be considered that the functionality of the packaging (e.g.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Consultation response | Reducing packaging waste Health Care Without Harm (HCWH) Europe welcomes the opportunity to provide feedback on packaging requirements and other measures to prevent packaging waste. In the context of the new Circular Economy Action Plan (CEAP), presented by the Commission on 11 March 2020, this initiative is a promising continuation, recognising key issues and remaining gaps to deliver a more…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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At EBM we welcome the goals of the review and will stress a few points. One of its specific objectives is to ensure a reduction in packaging waste generation. Waste prevention has been a priority since the introduction of the waste hierarchy in the WFD, yet it never received much attention — and definitely not as much as it pertains to an item touted as a foremost priority.
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We, ALPLA, are a rigid plastics packaging producer based in Austria and are working on to produce sustainable and circular packaging. • ALPLA welcome the initiative that our CE targets are already in line with the addressed measures. • For us as a converter/recycler, harmonised rules on packaging (e.g.
UNESDA SUBMISSION TO THE CONSULTATION ON THE INCEPTION IMPACT ASSESSMENT ON REDUCING PACKAGING WASTE – REVIEW OF RULES Making packaging more circular The EU soft drinks sector is delivering beverages to all EU consumers in different formats, using different packaging (aluminum, glass, plastics, carton beverage).
Chemical recycling is one of the key solutions contributing to the circular economy of plastics. In addition to increasing the recycling rates of some plastics currently not being recycled, it is creating recycled content of virgin-quality which will be essential to fulfil the strong demand incentivized by the EU Plastic tax, the Circular Economy Action Plan or the EU Green Deal.
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Assobioplastiche is the Italian association representing the bio-based, biodegradable and compostable plastics sector. The following feedback is related to the study “Effectiveness of the Essential Requirements for Packaging and Packaging Waste and Proposals for Reinforcement” commissioned by the European Commission to Eunomia and published in April 2020.
Cosmetics Europe represents the cosmetics and personal care industry in Europe. Ranging from antiperspirants, fragrances, make-up and shampoos, to soaps, sunscreens and toothpastes, cosmetics and personal care products play an essential role in in all stages of our life. European citizens use cosmetic products as part of their daily lives, serving their essential needs and expectations.
Elipso represents French plastic packaging association. our team was extremely busy during the recovery period, we did not have time to work on the answer before the edadline (in the middle of holydays) Howevere I would like to send back comments before 1st of September Is it possible to extend the timing of the answers? regards
Flexible Packaging Europe (representing the flexible packaging industry in Europe) welcomes the opportunity to share its views on the inception impact assessment regarding the review of packaging and packaging waste rules. As the circular economy becomes a cornerstone of the EU’s industrial base, we appreciate the relevance of updated packaging rules.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.