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ZERO congratulates the EU for finally moving forward in reducing the problems for health and the environment resulting from FCM. It is clear for us that hazardous chemicals must never be allowed in whatever FCM. That is fundamental to honor the commitments of the Green Deal and the new Chemicals Strategy for Sustainability.

The Changing Markets Foundation welcomes that the Commission has committed to ban the most hazardous chemicals from consumer products, including FCM, and has committed to revising the FCM legislation. We believe this is an important opportunity to establish safer and more sustainable food packaging as part of achieving a toxic-free circular economy.

The objective of Article 9 SUPD is the seperate collection of plastic bottles in order to ensure that they don’t end up littered in the environment and the evidence shows that the only way to achieve viable and long-term 90% separate collection rates is through mandatory Deposit Return Systems.

From ZERO's point of view it will be very important that strict requirements for the quality of the material are set, even in the cases where plastic botles are collected together with other recyclables, so that closed-loop bottle-to-bottle recycling is still possible.

- ‘Products & services’ are the entry point for material loops: 80% of environmental impacts are determined at design stage and if injecting single use & toxic materials through products we spoil the whole potential for circularity. It is no brainer that products and services need to be better designed for circularity. It’s impossible to make a good recipe with rotten ingredients.

We agree with the feedback by the European Environmental Bureau, which they have handed it (EEB proposals for a more coherent EU Product Policy Framework contributing to the Circular Economy). We have a few additions as that we have encountered as part of our campaigns, notably our campaign to increase circularity of the carpet sector.