30 Aug 2016
Joint Statement from 38 Packaging Value Chain associations on the legislative review amending the WFD and PPWD
- Ensure a life-cycle approach in legislation, taking into account the functionalities of packaging, such as preserving the entirety of resources invested in the packaged product along the entire value chain.
- Safeguard the Internal Market (the legal basis of the PPWD) to ensure the free movement of packaging and packaged goods. Avoid de facto trade barriers for packaging and packaged goods; retain the PPWD’s pre-notification procedure and Article 21 Committee.
- Ensure relevance of the EU EPR “general requirements” for the packaging waste stream, alongside nationally and clearly defined roles and responsibilities, for all actors involved in EPR implementation. Obligated costs for producers need to be clearly demarcated and net of revenue from the sale of secondary raw materials.
- Allow free competition so that producers can choose the packaging most appropriate for the product and distribution system. Legal requirements that mandate additional packaging reuse systems alongside existing EPR systems risk undermining the cost-efficiency of EPR and recycling efforts/investments. Resist national measures to promote packaging reuse systems that will distort the Internal Market.
- Set realistic and achievable packaging “preparing for reuse”/recycling targets, based on an updated ex-ante impact assessment, known starting points, as well as a harmonised and clarified measurement point and calculation methodology.