The Implementing Decision developed under the Single-Use Plastics Directive provides a fuel-use-excluded mass balance methodology. The VTCR supports using this methodology as the starting point for the PPWR, with targeted improvements based on lessons learned. Reopening the entire methodology would create unnecessary delay and uncertainty. Key recommendations: 1. Adopt the Implementing Act without delay!
VNO-NCW / VTCR
Industry association · Netherlands
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Their record over time
VNO-NCW / VTCR filed 2 positions on 16 Sept 2026, across 2 of the 655 legislative files tracked here, attaching a full position paper 2 times.
What they argued
Key recommendation: 1. Apply a clear geographical scope. Only plastic waste collected, sorted and recycled within the EU27, EFTA and the United Kingdom should count towards mandatory recycled-content targets for packaging produced or filled in Europe. 2. Adopt the Implementing Act without delay. Timely adoption is essential to provide investment certainty and make the 2030 recycled-content targets operational.
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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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