Landbell Group company European Recycling Platform (ERP) is pleased to provide the attached feedback. ERP operates seven packaging Producer Responsibility Organisations (PROs) across Europe, and our feedback presented here is based on our direct experience in this field. ERP is generally in support of the draft articles and annexes, however, we provide feedback and proposals for consideration on specific aspects.
European Recycling Platform
Company · Germany · EU Transparency Register 194953315534-56
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,800 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1212 companies & groups on this site, they rank #100 by legislative files engaged, a count of participation, not a measure of influence.
Declares membership of
- European Recycling Platform SAS is a subsidiary of Landbell AG (see below).
- "European Recycling Platform" is the brand of Landbell AG operating Producer Responsibility Organizations (PROs) and…
- Landbell AG runs own activities under its own name and has its own registration in the Transparency Register (9316252…
Self-declared to the EU Transparency Register (snapshot 15 Oct 2026).
- Register category
- Companies & groups
- Registered as
- European Recycling Platform SAS (ERP SAS)
- Head office
- Paris, France
Self-declared to the EU Transparency Register (snapshot 15 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
European Recycling Platform filed 13 positions between 8 Apr 2020 and 16 Sept 2026, across 12 of the 665 legislative files tracked here, attaching a full position paper 13 times.
What they argued
European Recycling Platform (ERP) appreciates the opportunity to provide feedback on the European Commission's proposal for a new Regulation on Packaging and Packaging Waste (PPWR). We support the proposal's ambition to further harmonise the European internal market and to create a level playing field for all actors involved in the pre- and post-consumer phase of packaging.
European Recycling Platform (ERP) welcomes the Commission’s initiative to revise the Waste Framework Directive (WFD) and would like to thank them for the opportunity to contribute to the ongoing stakeholder consultation.
European Recycling Platform (ERP) welcomes the European Commissions evaluation of the Single-Use Plastics Directive (Directive (EU) 2019/904). Several years after its adoption, implementation across Member States reveals structural challenges.
European Recycling Platform (ERP) welcomes the European Commission’s initiative to revise legislation on food contact materials (FCM) and the publication of the inception impact assessment. As pan-European producer responsibility organisation (PRO) for packaging, batteries, and electrical and electronic equipment, we have helped to implement EPR in several countries of the European Union and beyond and operate at…
European Recycling Platform (ERP) very much welcomes the European Commission’s proposal for a new Batteries Regulation and its overall objective to promote a competitive, circular and sustainable value chain for batteries in Europe.
European Recycling Platform (ERP) welcomes the European Commission’s plans to modernise the European Union’s batteries legislation in order to reflect latest market and technology developments, to address the lack of definitions, and to align it with the latest amendments to general waste legislation.
The initiative aims to streamline reporting and administrative requirements while maintaining existing environmental objectives. For the world of extended producer responsibility (EPR), the package is particularly relevant.
Landbell Group company European Recycling Platform (ERP) supports the development of robust sustainability criteria for plastic recycling technologies. The criteria should be technology-neutral, allowing different recycling technologies to demonstrate compliance rather than favouring or excluding specific technologies by design. Please see attached for full feedback.
European Recycling Platform (ERP) welcomes the European Commission’s plans to revise rules on waste shipment and to better align them with the overall objective of transitioning the continent towards a circular economy.
Consultation feedback: Packaging and packaging waste – conditions for importing recycled materials into the EU for use in packaging Mainz, September 2026 Within the context of the European Commission’s call for evidence on conditions for importing recycled materials into the EU for use in packaging under the Packaging and Packaging Waste Regulation (PPWR), Landbell Group company European Recycling Platform (ERP) is…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Producer responsibility organisations like European Recycling Platform (ERP) are managing the collection and treatment of waste streams like WEEE on producers’ behalf and, therefore, are heavily affected by the above-mentioned provisions.
European Recycling Platform (ERP) welcomes the opportunity to comment on the European Commission's proposal for a Directive amending the Waste Electrical and Electronic Equipment (WEEE) Directive to address the implications of the European Court of Justices judgment (Case C-181/20) on the financing of the collection and treatment of WEEE from users other than private households.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.