Citeo

Citeo would like to provide feedback to the European Commission in order to leverage its expertise in the circular economy for the development of ambitious, pragmatic Circular Economy Act that can ensure a competitive and circular European economy.

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

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.

In 2020, the French recycling rate is estimated at 68.2%, slightly lower than the revised 2019 recycling rate of 68.8% . It could be explained by the health crisis in 2020 led to malfunctions in the selective collection system, which collection system, degrading recycling performance.

Citeo is the French company in charge of the Extended Producer Responsibility (EPR) for household packaging and graphic papers. Citeo welcomes the EC proposal to provide harmonized rules on substantiation, communication, verification of voluntary green claims at European level.

Citeo strongly welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to propose a new legislation on substantiating green claims, aiming at enhancing environmental performance of products and businesses.

Citeo, the French company in charge of Extended Producer Responsibility (EPR) for household packaging and graphic papers, would like to share its views on the proposal for a regulation on ecodesign for sustainable products presented by the European Commission on 30 March 2022, as part of the Sustainable Product Initiative, the Circular Economy Action Plan and the European Green Deal.

Citeo supports the European Commissions ambition to establish a robust and coherent regulatory framework that advances environmental objectives while strengthening the business case for companies operating in the European Union.

Citeo welcome the proposal for a regulation on preventing plastic pellets losses to reduce microplastic pollution, which purports the objective of restricting microplastics added unintentionally in products and addressing intentional emissions of microplastics, and which considerations for this purpose all the microplastic chain. However, we call for further clarification of several provisions.

Filed in French · English published by the European Commission

Citeo welcomes the publication of the methodology of calculating the integration of recycled content with mass balance approach, which is essential for the development of an EU secondary material markets. We underline the following points: Support for the prioritization of mechanical recycling where quality allows, while recognizing the complementary role of chemical recycling to improve overall recycling…

Citeo underlines the risk of misunderstanding and legal uncertainty with the existence of definitions of recycled plastic in two legal instruments. In order to calculate the weight of the beverage bottle, Citeo believes all the components should be taken into account and not only the plastic parts of the beverage bottles.

Article 7.8 of Regulation (EU) 2025/40 mandates the Commission to adopt an implementing act establishing a harmonised methodology for calculating and verifying the recycled content of packaging. Verification schemes already operate at national level, built on internationally recognised standards and third-party certification.

In 2016, export of waste from the EU to third countries outside the EU amounted to around 40 million tonnes, around 20% of the global export of waste. At the same time, approximately 13 million tonnes of waste were imported into the EU 1.

Citeo welcomes that the new draft implementing decision makes clear that the comparability criteria apply to all collected bottles and not only to bottles collected in co-mingled collection systems and does no longer require cross-checks and the characterisation of non-targeted material and other substances.