Društvo Ekologi brez meja

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

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.

EBM welcomes the revision of the EU waste framework as it is clear that further regulatory measures will be needed to ensure a satisfactory transition to a circular economy. Waste prevention has been at the top of the waste hierarchy since its inception, yet decades of practice show it only has this position nominally.

We welcome the intention of establishing binding food waste reduction target(s), as at these have proven to be effective in Slovenia time and time again. It may also be beneficial to consider separate targets for food losses, additionally since there is risk that food loss prevention will sometimes be reported as food waste prevention.

The planned revision of the ETS is a good opportunity to account for more GHG emissions stemming from waste management operations. In particular, we feel the incineration of municipal solid waste has so far been unduly excluded. As a result, there has been little pressure to reduce GHG emissions, which would automatically also reduce toxic emissions, ticking the box also for the "zero pollution" ambition of the EC.

Considering the goals of the Green Deal, it's a shame that IED doesn't address the climate crisis directly. The regulation of GHG emissions is left to the ETS Directive, but at the same time more than 90% of industrial greenhouse gas emissions are covered by free ETS emissions allowances, so that Directive provides almost no incentive to energy-intensive industries to decarbonize.

The negative impacts of microplastic pollution are becoming clearer and clearer by the day, so concerted efforts to limit it are needed. We are therefore happy to see this initiative, since at the EU level thought has been given only to microplastics intentionally added to products.

According to the impact assessment, avoiding releases of POPs from waste is a priority. Yet a large part seems to be geared towards facilitating negligent recycling, all the while some of the limit values are already not low enough to ensure public health and environmental safety (both Stockholm Convention objectives).