Zero Waste Europe

Material use and waste generation show no signs of significantly decreasing in the EU, and it is clear that ambitious measures are required to remedy this. The Rethink Plastic Alliance is therefore advocating for an EU Circular Economy Act that truly rises to the challenge and reflects the urgent need to reduce, reuse and recycle materials.

Zero Waste Europe welcomes the European Commissions plan to adopt a Circular Economy Act (CEA) in 2026 (Q3) and its ongoing call for evidence and public consultation, but would like to highlight the following: On the framing, while we agree that boosting recycling and improving the market for secondary raw materials are essential to strengthen Europes competitiveness and resource resilience, the current framing…

The Rethink Plastic Alliance asserts that decarbonisation and defossilisation should be at the core of the proposed Regulations objectives. In our feedback, we set out how this should be reflected with regard to plastic production, a sector that is already facing significant challenges both in terms of overcapacity and because of the huge impacts of its full supply chain on the environment, climate and the health of…

ZWE welcomes the EC proposal for the Renewable Energy Directive (RED) reform. In order to ensure that the RED only supports energy from biogenic wastes, it should only allow energy from separately collected biowaste or biogenic waste that is segregated from fossil waste in case of mixed waste.

Zero Waste Europe (ZWE) is the European network of communities, local leaders, experts, and change agents working towards the elimination of waste in our society and to empower communities to redesign their relationship with resources and to adopt smarter lifestyles and sustainable consumption patterns in line with a circular economy.

Feedback on the EU Packaging Regulation revision Recommendations for an ambitious revision of the Packaging and Packaging Waste Regulation (PPWR) Position Paper April 2023 zerowasteeurope.eu Contents 2 General Recommendations 2 4 Material neutrality approach needed Sustainability without safety?

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

The Rethink Plastic alliance welcomes the European Commission proposal for the Packaging and Packaging Waste Regulation (PPWR). Notably, we welcome the proposed waste prevention and reuse targets, as well as the strengthened measures for tackling packaging waste.

Rethink Plastic feedback Roadmap on Reducing Packaging Waste August 2020 Rethink Plastic Alliance welcomes the review of the requirements for packaging and measures to prevent packaging waste. Here we outline our main comments on the inception document. A. Context, Problem definition and Subsidiarity Check Growing levels of packaging waste are problematic both from a climate and a natural resource perspective.

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

Zero Waste Europe welcomes the initiative of the European Commission to revise the Climate and Environmental Delegated Acts with the aim of improving clarity, usability and legal certainty. While simplification is valuable, it must always preserve environmental ambition.

Zero Waste Europe (ZWE) welcomes the European Commissions initiative to revise the Climate and Environmental Delegated Acts. We strongly support efforts to enhance clarity, usability, and legal certainty within the EU Taxonomy. However, we underline that simplification must not come at the expense of environmental integrity.

21.11.2023 Zero Waste Europe’s feedback to the proposal for a targeted revision of the Waste Framework Directive (2023/0234 (COD)) Contents Contents.................................................................................................................................................................................................................1 Strengthen the provisions on food waste and…

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

The Rethink Plastic alliance welcomes the initiative of the Commission to revise the Waste Framework Directive and the opportunity to provide feedback. The alliance supports the adoption of regulatory measures to reduce waste in absolute terms, and fully apply both the waste hierarchy and the polluter pays principle.

Zero Waste Europe welcomes the European Commission’s initiative to revise the Waste Framework Directive with the aim to improve the overall environmental impact of waste management in the EU. The focus on qualitatively improving the recycling system as well as the focus on waste prevention are of high importance as so far, the EU efforts on circular economy have only led to a quantitative increase in recycling.

Towards a zero food waste food system Zero Waste Europe welcomes the initiative of the European Commission to start the process to set-up binding food waste reduction targets across the EU. Food waste is a multifold problem that not only causes environmental and climate damage but is also morally unacceptable.

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

We encourage the Commission to ensure full inclusion of municipal waste incineration under the EU ETS with the following considerations: (1) Both power and heat from MWI should be covered without free allowances, aligning with ETS coverage of the buildings sector in 2027.

The Rethink Plastic alliance welcomes the launch of the Sustainable Products Initiative (SPI) and its overarching objective to make sustainable products and services the norm. In order to achieve its overarching objective and meet the seriousness of current environmental challenges, the proposed product policy framework must be applied across all sectors of the economy in an integrated manner.

ZERO WASTE EUROPE RESPONSE TO THE SUSTAINABLE PRODUCT INITIATIVE Zero Waste Europe (ZWE) welcomes the European Commission’s commitment to develop a Sustainable Product Initiative as part of the Circular Economy Action Plan (CEAP) and the opportunity to provide its recommendations in line with our vision to create a zero waste Europe.

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

Zero Waste Europe welcomes the revised EU ETS. We would like to suggest amending the EC proposal to include municipal solid waste incinerators (MSW) in the scope of the Directive. Currently, the municipal solid waste incinerators are one of the few sources of fossil CO2 that is left out of the scope of the Directive despite of the growing emissions.

The upcoming revision of the EU Emission Trading System (ETS) represents a crucial opportunity to strengthen the Directive and ensure it contributes to the goals of the Paris Agreement. The Rethink Plastic alliance welcomes this opportunity to feedback, and considers that the review should include the following elements: - A higher Linear Reduction Factor (LRF) and an one-off reduction of the cap : The new LRF and…

ZWE welcomes the opportunity to provide feedback on the revision of the EU Emissions Trading Scheme (ETS). As the EC inception impact assessment states, we will need to decarbonise our industries in the coming decade in order to achieve climate neutrality by 2050. EU ETS currently covers only 38 % of total greenhouse gas emissions in the EU.

As the European Union seeks to meet both climate and circular economy goals while boosting its competitiveness, the extension of the Carbon Border Adjustment Mechanism (CBAM) presents a unique opportunity to introduce financial incentives that simultaneously address carbon leakage and drive the transition toward a truly circular economy.

The priority for the Rethink Plastic Alliance is to ensure that the evaluation of the Single-Use Plastics Directive (SUPD) further reinforces - rather than undermines - the ongoing environmental objectives and pollution-prevention measures.

ZWE recommends revising the IED to ensure that waste incineration and co-incineration plants respect the same total emissions levels. Current legislation sets higher emissions ceilings for cement plants co-incinerating waste than those for dedicated waste incinerators.

Feedback on the Environmental Omnibus Feedback from the Rethink Plastic Alliance to the European Commission’s Communication on “Simplifying for Sustainable Competitiveness” (Environmental Omnibus). About Rethink Plastic The Rethink Plastic Alliance is a coalition of leading European NGOs advocating for ambitious EU policies to tackle the growing crisis of plastic pollution.

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

Zero Waste Europe (ZWE) acknowledges that reducing administrative burden can be beneficial in some cases. However, simplification should be strictly limited to genuine administrative improvements (such as, for example, avoidance of data duplication and harmonisation of reporting obligations across different legislations), in order to ensure that core policy objectives continue to be fully pursued.

Rethink Plastic Alliance’s response to the roadmap consultation for the inception impact assessment of the revision of the Non-Financial Reporting Directive 1 About Rethink Plastic Alliance Rethink Plastic is an alliance of leading European NGOs, with thousands of active groups, supporters and citizens in every EU Member State.

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

The Rethink Plastic Alliance welcomes the opportunity to provide feedback on the EU Ocean Act. We believe the Ocean Act is an opportunity to establish a coherent legislative framework with clear targets to reduce marine plastic pollution, while ensuring that existing legislation is effectively implemented and funded appropriately, and that additional measures to address microplastics are adopted.

The Rethink Plastic Alliance has consistently brought to the attention of EU institutions the alarming issue of plastic pellet pollution. Over the years, we have diligently reported numerous cases, highlighting the detrimental impact of plastic pellet pollution on ecosystems and communities.

The Rethink Plastic alliance welcomes the European Commission’s initiative on microplastics unintentionally released into the environment as microplastics pollution is a widespread issue requiring urgent action. Please find attached our comments and recommendations.

Zero Waste Europe (ZWE) welcomes the opportunity to provide feedback on the Implementing Decision proposal for calculating, verifying, and reporting recycled plastic content in single-use plastic beverage bottles.

The Rethink Plastic Alliance welcomes the opportunity to provide feedback to the Commissions draft Implementing Decision. In the attached document, we outline a number of concerns with the draft that we believe would endanger the transition to a clean, non-toxic circular economy.

Zero Waste Europe welcomes the opportunity to provide feedback on the implementing decision laying down common rules for calculating, verifying and reporting on recycled plastic content in single-use plastic beverage bottles. Since the adopted methodology will be the first of this type, it will create a precedent for the upcoming legislative pieces.

Sustainability criteria for recycling Regulatory requirements under the Packaging Packaging Waste Regulation Response to call for evidence September 2026 zerowasteeurope.eu Zero Waste Europe (ZWE) welcomes the opportunity to provide evidence on the three acts of the secondary legislation on recycling from the Packaging Packaging Waste Regulation (PPWR).

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

The sustainability criteria under the PPWR should apply the Do No Significant Harm (DNSH) principle across seven un-aggregated areas: carbon footprint (via Product Environmental Footprint/PEF without credit mass balance), human toxicity, energy use, water use/pollution, localized pollution, biodiversity, and fossil resource use.

Methodology for recycled content Regulatory requirements under the Packaging Packaging Waste Regulation Response to call for evidence September 2026 zerowasteeurope.eu Zero Waste Europe (ZWE) welcomes the opportunity to provide evidence on the three acts of the secondary legislation on recycling from the Packaging Packaging Waste Regulation (PPWR).

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

For calculating and verifying recycled plastic content, the EU should move away from "credit" mass balance systems that decouple reporting from physical reality. This means prioritising segregation and controlled blending models, and allowing only rolling average mass balance at site level.

The ReFuelEU Aviation initiative can only contribute to climate change mitigation in the aviation sector by aligning finances with actions that help move the EU towards the circular economy. I. Policy Coherence - Any potential support to waste-based fuels needs to be fully in line with other environmental and climate policies.

Zero Waste Europe welcomes the opportunity to contribute to the call for evidence on the upcoming initiative on a CO market and infrastructure in the EU. We recognise that carbon management will play a role in the EUs 2040 and 2050 climate objectives.

6 April 2020 Brussels Feedback from Zero Waste Europe (ZWE) and the European Environmental Bureau (EEB) on the Inception impact assessment of Waste Shipment Regulation (WSR) We welcome the inception impact assessment (IIA) of the WSR stressing the intention to stop exporting waste outside the EU and revisit existing rules. According to the IIA, “International trade in waste has increased considerably.

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

The do no significant harm (DNSH) principle should become a robust and consistently applied eligibility condition across the 20282034 Multiannual Financial Framework (MFF). Experience from the current MFF and from recovery instruments demonstrates that DNSH has often been applied unevenly across funds, sectors and implementation channels.

The Rethink Plastic alliance welcomes the decision of the European Commission to introduce a legislative act to reduce methane emissions in the energy sector, and would like to highlight the need to ensure a comprehensive approach toward addressing methane emission across the supply chain, including in the energy-intensive petrochemical sector.

The Rethink Plastic Alliance welcomes the opportunity to provide feedback on the Commission's draft Implementing Regulation to set harmonised End-of-Waste (EoW) criteria for plastics in the EU. Overall, we welcome the proposed EoW criteria for plastics but we urge the EU to strengthen the criteria for eligible inputs and control mechanisms to ensure genuine circularity.

Zero Waste Europe (ZWE) welcomes the opportunity to provide feedback on the implementing regulation establishing EU-wide End-of-Waste (EoW) criteria for plastic waste. The introduction of an EU-wide EoW framework for plastics is a positive and necessary step towards the development of a market for plastic recyclates in the EU.

Defining equivalence rules for recycling Regulatory requirements under the Packaging Packaging Waste Regulation Response to call for evidence September 2026 zerowasteeurope.eu Zero Waste Europe (ZWE) welcomes the opportunity to provide evidence on the three acts of the secondary legislation on recycling from the Packaging Packaging Waste Regulation (PPWR).

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

The EU implementing act for assessing, verifying and certifying equivalence should strictly align the definition of recycling with EU legislation by excluding fuel, and ensuring imported post-consumer recycled plastic meets identical recycling, environmental, and non-fuel processing criteria.

ZWE welcomes the FuelEU Maritime Initiative. In order to further develop the initiative we recommend the following: I. Policy Coherence: any potential support to waste-based fuels should be in line with other environmental and climate policies.

The Rethink Plastic Alliance (RPA) is deeply concerned by the proposed expansion of green-listing waste streams with these draft Delegated Acts. RPA supports clear and harmonised rules that enable environmentally sound management (ESM) of waste and high-quality recycling.

ZWE welcomes the Commission proposal to review the Ambient Air Quality Directives. End of life treatment of waste such as waste incineration release pollutants to ambient air. These pollutants, at certain concentrations, lead to health and environmental issues, as the World Health Organization has acknowledged.

Zero Waste Europe would like to highlight the importance of excluding waste (co)incineration from the scope of the fund. Burning waste in coal power plants is sometimes presented as an alternative to burning coal as well as a low-carbon source for the creation of energy. It is also justified as a way to give a new lease of life to old power stations.

Market surveillance and compliance of products – evaluation and possible revision of Regulation (EU) 2019/1020 Zero Waste Europe feedback Brussels, 4 February 2026 Zero Waste Europe (ZWE) is the European network of communities, local leaders, experts, and change agents working towards a better use of resources and the elimination of waste in our society.

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

Rethink Plastic feedback Hazardous waste: updated concentration limits for chemical pollutants August 2020 The Rethink Plastic alliance welcomes the opportunity to share our views. The update of the regulatory concentration limits for Persistent Organic Pollutants (POPs) takes place in the context of the European Green Deal and its Circular Economy Action Plan (CEAP).

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

ZWE recommends to align the EU POPs Regulation with the objectives and requirements of the Stockholm Convention. The current limitations for POPs in waste are too weak and do not hinder the circulation of POPs in reused materials and recycled products. This occurs fro example by recycling ash from incinerators containing high concentrations of dioxins (Katima, Bell et al.

Zero Waste Europe, a leading organization dedicated to promoting sustainable waste management practices across the continent, hereby submits a formal response to the ongoing public consultation concerning the measurement method for Municipal Solid Waste (MSW) emissions.

The Rethink Plastic alliance welcomes the opportunity to provide feedback on the draft implementing act. The alliance would like to highlight that it is critical that the definition of "separate collection" is in line with the Waste Framework Directive and that the implementing act clearly states that waste splitting/post-sorting of bottles after residual waste mixed collection is not separate collection.

Zero Waste Europe welcomes the opportunity to contribute to the Commission’s EU implementation of the Aarhus Convention in the area of access to justice in environmental matters. Zero Waste Europe is an European network of communities, local leaders, businesses, experts, and change agents working towards the same vision: eliminating waste in our society.

Strong and independent environmental assessment is essential to uphold transparent, democratic and evidence-based policymaking, particularly where implementation and regulatory changes are subject to competing political and industry interests. EEA strategy over the next five years should not only focus on measuring Europes environmental problems.

Zero Waste Europe welcomes the opportunity to give feedback on the REPowerEU proposal. We would like to give recommendations regarding investment in projects related to the waste sector to ensure these are in line with the Paris Agreement and the existing European Commission policies.