27 Apr 2021

The successful roll-out of the Circular Economy Action Plan needs a strong EU Single Market

The Green Deal and the new Circular Economy Action Plan intend to create the conditions for the EU industry to lead the transformation towards a sustainable economy, by stimulating the development of harmonised lead markets for climate neutral and circular products.

EUROPEN is fully committed to supporting this objective, while stressing that the integrity of the Single Market remains an essential precondition to enable our industry to make bigger leaps towards greater circularity and climate neutrality.

In a  joint industry statement published in fall 2020, EUROPEN and 58 other European and national organisations from across the packaging value chain stressed that the scale of the Single Market and the certainty of free movement of packaging and packaged goods are essential to underpin the major investments in technology and product innovation needed to transition to a circular economy. This requires a good coordination amongst all stakeholders as well as a rigorous and harmonised implementation and enforcement of the Single Market principles across the EU to avoid the adoption of diverging and disproportionate national measures.


Concerns are growing in the industry as we see more and more cases of disruptions of the Single Market arise. The Single-Use Plastics Directive (SUPD) has been at the center of the attention lately, as the deadline for the EU Member States to transpose the Directive into national law is 3 July 2021 and the European Commission is still expected to publish key implementing acts and guidelines to facilitate the process. Concerns related to the implementation of the SUP Directive regard in particular:

  • The draft SUP Guidelines: The Guidelines on single-use plastic products must promote a harmonised transposition of the SUP Directive and preserve the integrity of the EU Single Market. Clear and accurate Guidelines fully aligned with both the stated objectives and the spirit of primary legal text will sustain the efficient functioning of the EU Single Market, which is a necessary condition to foster investments in innovation to reduce plastic waste and deliver a circular economy.
  • The Implementation of the harmonised marking requirements: Any decision to move away from “placing on the (Union) market” as the single decisive moment to apply the harmonised markings (as well as for other provisions of the SUP Directive) would be inconsistent with the Single Market principles and would result in both negative economic and environmental impacts. It is crucial to ensure that once a product is placed on the Union market, a further making available on the market of another Member State cannot constitute a new “placing on the market”.


  • Q2 2021: Expected publication of SUP Guidelines (initially expected in July 2020)
  • Q2 2021: Expected publication of Implementing Act for harmonised calculation & verification methodology of consumption reduction trend (initially expected in January 2021)
  • 3 July 2021: Deadline for EU Member States to transpose the SUP Directive
  • Q3/July 2021: Expected publication of Guidelines on litter clean-up costs criteria

EUROPEN members: Do not hesitate to visit the dedicated members’ area of our website here to know more about our work to support a harmonised implementation of the SUD Directive across the EU and preserve the Single Market.