9 November, 2023
Recognising the complementarity of reuse and recycling does not mean
lacking ambition
Ahead of the plenary vote on the Packaging and Packaging Waste Regulation (PPWR), the
signatories to this letter would like to share some of their concerns regarding the approach
adopted by the Parliament’s Environment Committee (ENVI) on 24 October.
While we recognize the good progress made on the text in a number of areas which will help the
industry to achieve its circular ambitions, we are highly concerned with the amendments to Art. 26
of the draft PPWR which have been adopted by the ENVI Committee, and in particular:
1. The possibility provided to Member States to go beyond the proposed increased reuse
targets without any justification needed.
2. The absence in the proposal of a mechanism which would allow for single-use packaging
as an alternative to packaging for reuse if a better overall environmental outcome on the
basis of a waste management or life cycle assessment can be achieved.
The first point goes directly against the objective of the European Commission to promote
harmonization and risks fragmenting the EU Single Market by creating a patchwork of national
targets that will have a considerable impact on Europe’s competitiveness.
This would also increase
the complexity of the implementation of the targets, would result in an unworkable situation for our
companies and act as a barrier to the Single Market as different targets would make it impossible to
achieve a level-playing field. Furthermore, it is worrying to see that the text does not seem to require
any form of impact assessment being performed by Member States to justify going beyond the EU
targets.
Our second point refers to the ITRE opinion adopted in July 2023 and alternative compromise
amendments proposed ahead of the vote in ENVI.
These correctly recognize that
reusable and
refillable solutions will not bring environmental benefits in all situations and for all packaging, and
it is therefore important to provide for an alternative option if economic operators can prove that
the use of single-use packaging is environmentally more sustainable than the re-use of packaging.
The adopted opinion and the alternative compromise amendments propose the possibility of using
a lifecycle assessment, a recycling rate or a collection rate as justifications for qualifying for an
exemption from the reuse targets.
Facilitating complementarity is of critical importance to support
the achievement of our sectors’ climate objectives and ensure that operators have to invest in
reusable packaging formats only when it actually makes more sense than single-use packaging from
an environmental perspective.
We therefore ask you to:
1. reject any proposal that would allow an increase of the targets under Article 26 above the
levels proposed by the European Commission.
2. support plenary amendments that propose mechanisms which would support the
complementarity of single-use packaging and reusable packaging.
We thank you in advance for your attention and respectfully request the opportunity to meet with
you at your earliest convenience to discuss this matter further.
Kind regards,