Single-Use Plastics Directive

We welcome the initiative to tackle these macroplastic sources. Given the recent UNEA resolution on marine litter and microplastics, the EU has both the opportunity and the responsibility to implement effective source-to-sea reduction measures.

In September 2017, the Scottish Government announced their commitment to introduce a deposit return system for all drinks containers. They have commissioned Zero Waste Scotland to design the system, and we expect there to be a public consultation in spring 2018. This decision was based on evidence from the 45+ places around the world that already operate deposit return systems.

The Circular Plastics Platform (the “CPP”) – a think-tank on eco-design, materials standards and market outlets for plastics by the leading Producer Responsibility Organisations (PROs) for packaging representing the obliged industry in Austria, France, Germany, Ireland, Poland, Portugal, and in the United Kingdom (the “G7”) – welcomes the European Commission’s initiative to tackle sources of marine litter.

Versalis fully supports the European Commission’s commitment to reduce marine litter. With regard to the threefold approach outlined in the Inception Impact Assessment and in particular the policy options, we can already provide some preliminary considerations: 1) Items already captured: We support the proposal to incentivize collection and recycling rates.

Overarching comments ClientEarth agrees that we need urgent action on plastics pollution. In that context, the framing of this inception impact assessment (IIA) as relating to ‘marine litter’ rather than ‘plastics pollution’ is unhelpful because: • It ignores the non-visual aspects of plastics pollution (including those relating to SUP and fishing gear), which go far beyond beach litter.

KIMO welcomes this initiative and supports rapid and urgent implementation of dedicated legislation to combat single-use plastics and ALDFG. We have made general comments here in the expectation that a focussed and researched consultation will be available for more detailed comment.

WDC welcomes this initiative, as we believe that a concerted EU action to reduce the amount of marine litter is long overdue. Within this initiative, a commitment to develop strong regulatory measures to reduce or even eliminate single-use plastic items should be a clear priority for the European Commission. There are clear precedents already in place within the EU to move towards regulating single use plastic.

Position Paper 12 January 2018 Feedback regarding the Inception Impact Assessment “Reducing marine litter: action on single use plastics and fishing gear” Today at least 10% of the 100 million tons of plastic we use every year end up in the oceans. In accordance to different sources we will have more plastic in Oceans then fish by 2050.

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

Comments by Independent Retail Europe Independent Retail Europe welcomes the idea to reduce waste and marine litter which is why our members have already many respective measures in place. We have only few comments on the current inception impact assessment (IA) but we will respond in more detail to the public consultation (Deadline 12 February).

WASTE AGENCY OF CATALONIA FEEDBACK about THE INITIATIVE: Reducing marine litter: action on single use plastics and fishing gear B. Objectives and Policy options Single-Use Plastics B (2) Items which could be replaced by more sustainable alternatives: If in this initiative we suggest to include single use wipes, because we know that these kind of products could contain resins and non-natural fibers; so, criteria…

The food and drink industry supports that actions have to be made in the field of single use plastics are taken at EU level. As highlighted in the Impact Assessment the free movement of packaged goods in the internal market is a fundamental principle of the EU and a crucial dimension for the food and drink industry and to the benefits of European consumers.

Assobioplastiche, the Italian Association of Bioplastics and Biodegradable Materials, has been founded by a group of companies working (involved in manufacturing biopolymers biodegradable and compostable and finished products), Authorities, NGO, Universities and other Associations and Consortium involved in end of life disposal of biodegradable products.

In Flanders, various waste municipalities have set up a steering committee called "RECOVER". Last year, RECOVER opened an investigation for searching an improved packaging waste policy. This in response to the many problems local authorities have with the current system of packaging in Belgium.

The European Recycling Platform (ERP) welcomes the initiative of the European Commission to tackle the leakage of single use plastics into the environment and to reduce the negative economic and environmental impacts arising from that. As set out correctly in the inception impact assessment document, the leakage of plastics is indeed a global problem, especially when it comes to marine litter.

The below observations of Members of Polish Chamber of Chemical Industry focus on the single use plastics (SUP) aspects of the initiative that the Commission has announced. They are based on the inception impact assessment (IIA). The roadmap for the Plastic Strategy states as one of its objectives “improving the economics, quality and uptake of plastic recycling and reuse”.

Reloop’s Position Paper on the upcoming European Commission’s Strategy on Plastics Reloop is a platform that brings together industry, government, and non-‐governmental organisations to form a network for advances in policy that create enabling system conditions for circularity across the European economy. Reloop welcomes the European Commission’s announcement to publish a Strategy on Plastics in early 2018.

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

Inception impact assessment on the EU’s initiative “Reducing marine litter: action on single use plastics and fishing gear.” Reloop welcomes this initiative as it recognises the importance of setting up progressive and binding EU legislative measures to combat single use plastics.

European Bioplastics welcomes the initiative of the European Commission to reduce marine litter. We support the multi-way approach suggested in the roadmap and taking into account the manifold reasons for litter ending up in the marine environment.

Oceancare welcomes this Initiative and we strongly agree that urgent action at EU Level is necessary and that dedicated regulatory action at EU level to tackle marine litter is needed. Our detailed feedback is provided in the attached file, however these are our summarised key points: To transition towards a circular economy approach for tackling ocean plastic, an overarching objective to reduce or even eliminate…

Among the approaches examined to reduce the impacts caused by SUP waste, more sustainable alternatives are also envisaged (Point 2, Section B). In particular, substitution with materials is considered. The text indicates specific materials (paper and wood) as a possible solution.

Single-use Plastics. (1) The increase of the collection (beverage packaging) makes sense only if the reference flow shall be collected. There is to date only one system for: Deposit. Norway has proved that when recycling targets imposed are excessively high taxes (or otherwise) the packaging itself opts for a deposit and that therefore regulates itself.

Filed in Dutch · English published by the European Commission

I would like to send a request to consider the marine coastal communities as the constant beneficiaries of the EU or the European Neighbourhood Policy subsidiary and economic programs which will compensate the consequences of the permanent pollution of marine beaches, the related continuous risks and will fund the persistent expenses such as monitoring, analytics, collection, deposit, disposal and recycling schemes…

L.S. As with most of the measures to combat littering seas and oceans, there are no wrong measures. Preventing beach littering and derelict fishing gear is always good, but there is an elephant in the room, the river. Rivers are a pathway, transportmedium, from litter on land to litter in seas.