27 Aug 2020

EUROPEN’s feedback on substantiating green claims

As announced as part of the European Green Deal and the new Circular Economy Action Plan, the European Commission has presented its initiative for a legislative proposal on substantiating Green Claims.
EUROPEN has responded to the Commission’s Inception Impact Assessment in August 2020, demonstrating its supports for the objective of this initiative 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. We also support the objective of moving towards a harmonised EU approach to measure and communicate accurate, reliable and meaningful information on the environmental performance of (packaged) products.
EUROPEN has constructively collaborated in the joint effort, by industry and the European Commission, to develop the Product Environmental Footprint (PEF) methodology as a robust and credible method to measure and communicate the environmental footprint of products.
EUROPEN has put forward five key principles for substantiating green claims:
  • Need for a holistic life-cycle approach reflecting packaging’s valuable role and functionalities across the value chain. In the context of PEF, it is crucial that packaging be intrinsically linked to the (packaged) product.
  • An EU harmonised approach to the use of the PEF methodology is needed to safeguard the Internal Market while ensuring that continuous investments are supported to boost EU competitiveness.
  • The choice of making green claims should remain voluntary but based on harmonised EU methodology. Hence, we support the establishment of a voluntary EU legal framework enabling companies to make green claims in accordance with the Environmental Footprint methods.
  • Coherence of policy objectives to avoid the risk of undermining the EU sustainability goals and to support investments in innovation.
  • A transparent application of PEF and for extensive related awareness raising campaigns which would ensure consumer acceptance of PEF-based label.