EUROPEN - The European Organisation for Packaging and the Environment

Dear Sir/ Madam, Please find EUROPEN's contribution attached, which brings together two Joint Statements - one on the forthcoming Circular Economy Act and another one on One-stop-shops (OSS) for EPR - along with EUROPEN's feedback to the public consultation on the 28th Legal Regime. Kind regards, [name removed]

EUROPEN supports the general objective of this initiative, which is to unlock opportunities for the circular and green economy, including by fostering the growth of green markets through value chain thinking and ensuring a more efficient use of resources.

While the Single-Use Plastic Directive (SUPD) has contributed to increased awareness of marine pollution, its implementation has generated disproportionate compliance and administrative costs for industry compared to the environmental benefits delivered.

EUROPEN has consistently highlighted the potential of the DPP as a tool to store relevant information and support digitalisation in previous consultation initiatives launched in 2025. Building on that initial input, we would like to take this opportunity to further complement our contribution through the present submission.

Dear Sir/ Madam, Please find attached EUROPEN's contribution on the proposed implementing decision. The document outlines our suggestions on the draft text and elaborates on its interaction with the secondary legislation to be adopted under the Packaging and Packaging Waste Regulation. Kind regards, [name removed] - EUROPEN

EUROPEN - the European Organisation for Packaging and the Environment - supports the adoption of detailed rules for the calculation, verification and reporting of the recycled content targets introduced by Directive (EU) 2019/904 on Single-Use Plastics (SUPD) to ensure the harmonised transposition of its requirements across EU Member States. Please see in the enclosed document our detailed feedback.

EUROPEN believes that the timely publication of harmonised end-of-waste (EoW) criteria is essential to ensure a consistent approach across all Member States, foster a level playing field, provide legal certainty for economic operators, and support the scaling-up of recycling in Europe.

EUROPEN already provided initial feedback on this topic through the survey on the Simplification Omnibus Aligning EU Product Legislation with the Digital Age, launched on 11 April, which we are sharing as an attachment. Building on that initial input, we would like to take this opportunity to further complement our contribution through the present submission.