Procter & Gamble

P&G supports the Digital Product Passport (DPP) as a practical tool to digitize product information requirements, improve transparency for value-chain actors, and simplify compliance for companies. To keep the DPP registry simple-by-design and workable for high-volume sectors, while avoiding unnecessary costs, we recommend the following: 1.

The sustainability assessment and resulting key criteria for plastic recycling technologies should be technology neutral, so as to permit (rather than hinder) innovation in support of a circular plastics economy. This requires a focus on objective and transparent indicators of performance rather than an a priori preference for a specific technology per se.

We welcome the legal certainty provided by the harmonisation of rules for the calculation and verification of recycled content in plastic packaging. This is essential for the Single Market in packaged goods. Divergent national approaches would create additional administrative burdens that distort competition and result in uncertainty throughout the value chain.

Article 7(3) explicitly permits the use of recycled content from third-countries subject to the specific conditions mandated in Article 7(10). As a consequence, the Implementing Act should strive to be fundamentally permissive in nature, rather than a construct that effectively prohibits international trade in post-consumer recyclate.

Article 1 of Directive 92/106/EE ‘on the establishment of common rules for certain types of combined transport of goods between Member States’ established constraints on the initial or final road leg combined transport operations.