Plastics Europe

Plastics Europe supports the objective of establishing common formats for registration in, and reporting to, national producer registers in the context of the PPWR. Effective harmonisation is essential to the functioning of the Single Market: companies operating in several Member States should not face divergent data fields, classifications, submission processes or national interpretations for the same EPR…

Plastics are integral to the European economy, serving a wide range of strategic industries such as automotive, packaging, construction, electronics, healthcare, renewable infrastructure and consumer goods. Although the European plastics value chain currently supports around 1.5 million jobs across more than 50,000 businesses2, the warning signs are clear: production lines are shutting down, plants are closing, and…

Plastics Europe calls for market-pull measures for low-carbon products and products from sustainable carbon sources under the Industrial Accelerator Act (IAA) to support European plastics value chains, including the introduction of Union origin requirements. These measures should strengthen Europes industrial base and accelerate the transition to a low carbon and circular economy.

Plastics Europe is the pan-European association of plastics manufacturers with offices across Europe. With close to 100 members producing over 90% of all polymers across Europe, we are the catalyst for the industry with a responsibility to openly engage with stakeholders and deliver solutions which are safe, circular and sustainable.

July 2020 REPLY TO THE CONSULTATION ON THE INCEPTION STUDY ON REVIEW OF THE REQUIREMENTS FOR PACKAGING AND OTHER MEASURES TO PREVENT PACKAGING WASTE PlasticsEurope welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to review the rules regulating the placing on the market of packaging with a view to make packaging increasingly sustainable and circular, and minimize…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PlasticsEurope comments on the Inception Impact Assessment “Revision of the Energy Performance of Buildings Directive 2010/31/EU” 22 March 2021 PlasticsEurope welcomes and supports the European Commission’s statements that “The decarbonisation of the buildings sector is vital to deliver on the EU’s 2030 and 2050 climate and energy objectives, given that buildings are responsible for 40% of total energy consumption…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Plastics Europe supports the intention of the European Commission to review the WFD and appreciates the opportunity to contribute to this call for evidence. We provide the following feedback on behalf of European plastics manufacturers and are available for further dialogue on this matter: - Plastics Europe welcomes the revision of the Waste Framework Directive (WFD) with a view to support the EU climate ambition…

PlasticsEurope is a leading European trade association, with centres in Brussels, Frankfurt, London, Madrid, Milan and Paris. We network with European and national plastics associations and have more than 100 member companies, who are responsible for producing more than 90% of all polymers across the 27 member states of the European Union, plus Norway, Switzerland, Turkey and UK.

Our views Even if polymers are not in the currently proposed scope, they could be considered in a later stage; in addition, certain polymers using some products of the current list as raw materials, such as ammonia, can be impacted by the proposed mechanism in its initial scope.

Plastics Europe contributes to the stakeholder consultation as follows: 1) Waste: Annex I In order to contribute to the EU climate neutrality objective, plastic producers aim at maximizing the plastics circularity, which is a key means to reduce GHG impact of the plastics value-chain.

Position Paper Plastics Europe initial comments on the revision of the Construction Products Regulation (CPR) Key Points: • Plastics Europe supports a future-orientated Construction Products Regulation – one that recognises the value of plastics as a high-performance, durable, and sustainable construction material.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PlasticsEurope’s comments on the Inception Impact Assessment “Review of the Construction Products Regulation” PlasticsEurope is one of the leading European trade associations with centres in Brussels, Frankfurt, London, Madrid, Milan and Paris, with more than 100 member companies, producing over 90% of all polymers across the EU28 member states plus Norway, Switzerland and Turkey.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PlasticsEurope and its members, welcome the opportunity to contribute to the European Commission's inception impact assessment on revision of the CLP Regulation. Via the attached document, feedback is provided on the problems this initiative aims to tackle. About PlasticsEurope: PlasticsEurope is the pan-European association of plastics manufacturers.

Plastics Europe supports the European Commissions ambition to scale up the share of bio-based feedstocks in plastics production - a key pathway to reduce greenhouse gas emissions while supporting circularity and industrial competitiveness. The Biotech Act II can set an enabling, predictable and coherent framework to seize the opportunities offered by Europe's bioeconomy.

Plastics Europe supports the intention of the Single-Use Plastic Directive (SUPD) to reduce marine litter and environmental impacts, while promoting circular approaches aimed at reducing waste generation and safeguarding the functioning of the internal market. The current scope of the Single-Use Plastic Directive (SUPD) should be maintained without further extension.

Plastics Europe supports the high level of ambition shown by the European Commission in the End-of-Life Vehicles Regulation proposal. To reach the target, the recognition for chemical recycling, operating in a complementary manner to mechanical recycling, as well as a separate additional circular plastics target will all be needed. We therefore call for:

Position Paper Net Zero Industry Act More Leverage for Circularity Needed in Net Zero Industry Act Plastics Europe fully supports the EU’s objective to become climate neutral by 2050 and is committed to contribute to that goal, by targeting a climate neutral plastics industry by that date.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PlasticsEurope and its members, welcome the opportunity to contribute to the European Commission's inception impact assessment on revision of the REACH Regulation. Via the attached document, feedback is provided on the problems this initiative aims to tackle. About PlasticsEurope: PlasticsEurope is the pan-European association of plastics manufacturers.

Plastics Europe strongly supports the European Commissions Housing Simplification Package under the European Affordable Housing Plan to tackle the housing crisis by lowering costs and boosting construction productivity. High-performing polymer applications are essential for delivering energy-efficient, affordable housing, particularly as key enablers of modern modular and offsite construction.

In summary, Plastics Europe welcomes the European Commission's proposal to address plastic pellet loss. We suggest that further refinement is required to achieve the European Unions 2030 microplastic reduction targets.

Plastics Europe, welcomes the opportunity to provide input to this call for evidence on microplastic pollution. We provide full feedback in the attached file, however in summary: • Data supports the effectiveness of voluntary pellet loss prevention measures via Operation Clean Sweep. • A high degree of site specificity requires bespoke approaches to implementing pellet loss prevention measures.

Plastics Europe is the pan-European association representing plastics manufacturers with offices across Europe. With close to 100 members producing over 90% of all polymers across Europe, we are the catalyst for the industry with a responsibility to openly engage with stakeholders and deliver solutions which are safe, circular and sustainable.

Plastics Europe urges the Commission to design and implement sustainability criteria that provide investment certainty, enable scale-up of innovative recycling technologies, and safeguard EU competitiveness, while delivering plastics circularity at scale. Mechanical, solvent-based and chemical recycling each play a complementary role in the management of plastic waste.

Plastics Europe supports the development of a methodology under Article 7(8) that rewards the use of recycled plastics across all packaging components, provides legal certainty through clear definitions, and preserves the flexibility needed for manufacturers to comply efficiently. We continue to support a fuel-use excluded mass balance approach, but urge some changes compared to the SUPD rules.

Plastics Europe considers the Digital Product Passport (DPP) as a valuable tool for improving the understanding of a products sustainability aspects by its users, increasing transparency among all the actors in the value chain and encouraging innovation in sustainable solutions.

Plastics Europe welcome the revision of the Waste Shipment Regulation (WSR). We recognise the EU Commission efforts to simplify the procedural framework governing shipment of waste within the Europe Union and countries of the European Economic Area (EEA) and to strengthen enforcement.

The European plastics manufacturers support the intention of the Commission to review the current Regulation (EC) No 1013/2006 on shipments of waste (WSR), with a view to: - simplify and reduce burdens linked to its implementation; - ensure a smooth functioning of the EU internal market for waste destined for reuse or recycling, and support its transition to circular economy models; - better address illegal…

To ensure a level playing field across all recycling technologies and to support the EUs circularity and climate objectives, we urge the European Commission to promptly initiate work in parallel on an implementing regulation covering additional recycling technologies and to clarify key elements of the current proposal. 1.

Plastics Europe supports a mirror clause that ensures all recycled content counting towards PPWR targets is subject to equivalent requirements, whether it originates in the EU or in a third country. To achieve this, the focus should be on defining equivalence criteria and strengthening the verification and enforcement of those requirements in a fit-for-purpose and implementable manner across the value chain through…

We welcome the Commission's draft delegated acts under the Waste Shipment Regulation and support the proposed new entries for non-hazardous WEEE and WEEE-derived fractions, selected textile waste mixtures, fibre-reinforced polymer composites and non-hazardous waste mattresses.

The Fluoropolymers Product Group (FPG) of Plastics Europe welcomes the opportunity to provide input to the ongoing evaluation and revision of Regulation (EU) 2019/1020 on market surveillance and compliance of products (MSR). The MSR aims to ensure that only compliant products offering a high level of protection for public interests are made available on the Union market.

The Polycarbonate/Bisphenol A group of Plastics Europe represents the main producers of BPA and Polycarbonate in Europe. Bisphenol A (BPA) is used mainly as building block (monomer) to manufacture polymers, namely polycarbonate and epoxy resins. Polycarbonate plastic is the main use for BPA, accounting for about 70% of global BPA production.

The PC/BPA group of Plastics Europe represents the main producers of Polycarbonate (PC) and Bisphenol A (BPA) in Europe. We appreciate the opportunity to provide our observations regarding EFSA´s activities and approach based on our experiences during the re-evaluation of BPA by EFSA between 2017 and 2023.

Plastics Europe PC-group submission This input is provided by the Polycarbonate Product Group of Plastics Europe (PC-group). Its members comprise manufacturers and compounders of polycarbonate (PC) in the EU (Covestro, Sabic, Trinseo). We also refer to the Cefic Bisphenols sector group entry. We support targeted regulation to protect vulnerable consumer groups.

The Fluoropolymers Product Group (FPG), part of Plastics Europe, appreciates the opportunity to provide comments on implementation of regulations for C9-C21 long-chain perfluorocarboxylic acids (C9-C21 PFCAs). LC PFCAs are used in the manufacture of advanced fluoropolymers, which are essential for high-performance applications across sectors such as healthcare, energy, transportation, and electronics.

PlasticsEurope comments to the Commission on Roadmap for evaluation of the EU RoHS (Restriction of Hazardous Substances in electrical and electronic equipment) PlasticsEurope appreciates the opportunity to comment on the Commission Roadmap for evaluation of Directive 2011/65/EU of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment.