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Calculation, verification and reporting of data on the separate collection of SUP beverage bottles

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Public consultation

ID: 13032

Lobbying Activity

18 responses

Consultation response

Wirtschaftskammer Österreich, 16 Jun 2021

The Austrian Federal Economic Chamber thanks for the opportunity to comment on the draft implementing decision laying down rules for the application of Directive (EU) 2019/904 of the European Parliament and of the Council as regards the calculation, verification and reporting of data on the…

Consultation response

FUNDACION OCEANA, 17 Jun 2021

Oceana welcomes the separate collection targets laid out in Article 9 of Directive (EU) 2019/904 that apply to beverage bottles with a capacity of up to three litres, including their caps and lids. These targets establish that by 2025, Member States shall take the necessary measures to ensure the…

Consultation response

Seas At Risk, 17 Jun 2021

The objective of Article 9 SUPD is the separate collection of plastic bottles in order to ensure that they don’t end up in the open environment. Putting an end to plastic pollution of SUP products is one of the main parts of the Plastic Strategy’s vision. Furthermore, a high-quality…

Consultation response

Zero Waste Europe, 17 Jun 2021

The Rethink Plastic alliance welcomes the opportunity to provide feedback on the draft implementing act. The alliance would like to highlight that it is critical that the definition of "separate collection" is in line with the Waste Framework Directive and that the implementing act clearly states…

Consultation response

Bund für Umwelt und Naturschutz Deutschland e. V., 17 Jun 2021

The objective of Article 9 SUPD is the seperate collection of plastic bottles in order to ensure that they don’t end up littered in the environment. Putting an end to littering of SUP products is one of the main parts of the Plastic Strategy’s vision. Furthermore, a high-quality bottle-to-bottle…

Consultation response

European Recycling Industries' Confederation, 17 Jun 2021

The European Recyclers’ Industry Confederation (EuRIC) welcomes this draft Implementing Decision regarding the calculation, verification and reporting of data on the separate collection of waste single-use plastic beverage bottles. Unfortunately we received notice of this consultation late and have…

Consultation response

Plastics Recyclers Europe, 16 Jun 2021

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the drafted implementing decision laying down rules for the application of Directive (EU) 2019/904 (SUPD) as regards the calculation, verification, and reporting of data on the separate…

Consultation response

Union of European Beverages Association, 17 Jun 2021

UNESDA and its members welcome the opportunity to share comments on the draft implementing act on calculating, verifying and reporting data on separate collection of single-use plastic bottles. You will find our detailed comments attached.

Consultation response

Environmental Investigation Agency, 16 Jun 2021

It is our view that the current draft Implementing Act contains vague and unclear terminology, leaving room for interpretation which in turn could have negative consequences. For instance, this includes the definition of how bottles can be collected for recycling, terms with regards to quality…

Consultation response

RELOOP, 16 Jun 2021

Reloop welcomes the development of the draft Implementing Decision in order to ensure correct implementation of Article 9 SUPD on setting separate collection targets for beverage bottles. We are concerned that the current draft is ambiguous, and can be intepreted to include bottles pulled from…

Consultation response

Natural Mineral Waters Europe aisbl, 17 Jun 2021

Natural Mineral Waters Europe (NMWE) welcomes the development of the draft Implementing Decision in order to ensure correct implementation of Article 9 SUPD on setting separate collection targets for beverage bottles. NMWE members have already embarked on a transformation journey to become a…

Consultation response

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 16 Jun 2021

From ZERO's point of view it will be very important that strict requirements for the quality of the material are set, even in the cases where plastic botles are collected together with other recyclables, so that closed-loop bottle-to-bottle recycling is still possible. It is of the utmost…

Consultation response

Extended Producer Responsibility Alliance, 17 Jun 2021

Packaging Recovery Organisations, including the 27 members represented by the Extended Producer Responsibility Alliance (EXPRA) as well as CITEO and Altstoff Recycling Austria AG (ARA), would like to comment on the proposed methodology for the determination of the weight of separately collected…

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 17 Jun 2021

FNADE: position paper on SUP directive implementing act proposal FNADE, the French Waste Management association would like to take the opportunity to make some comments regarding the European Commission’s proposal on SUP directive guidelines: First, in the draft proposal the word “collection” in…

Consultation response

TOMRA Systems ASA, 15 Jun 2021

TOMRA has, like many other stakeholders who are interested in a high level Circular Economy and the avoidance of litter at source rather than cleaning up afterwards, supported and signed the position paper of Brussels based not-for-profit organization Reloop. Insofar we would like to refer to…

Consultation response

CITEO, 16 Jun 2021

Citeo welcomes that the new draft implementing decision makes clear that the comparability criteria apply to all collected bottles and not only to bottles collected in co-mingled collection systems and does no longer require cross-checks and the characterisation of non-targeted material and other…

Consultation response

Stichting Changing Markets, 16 Jun 2021

The objective of Article 9 SUPD is the seperate collection of plastic bottles in order to ensure that they don’t end up littered in the environment and the evidence shows that the only way to achieve viable and long-term 90% separate collection rates is through mandatory Deposit Return Systems.…

Consultation response

CONSORZIO NAZIONALE IMBALLAGGI, 17 Jun 2021

CONAI, the Italian National Packaging Consortium, is a private non-profit entity which gathers more than 700 thousand companies to ensure a sustainable and circular management of waste packaging in the EPR regulatory framework. CONAI in synergy Municipalities pursues the objective of guaranteeing…