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Review of the requirements for packaging and feasibility of measures to prevent packaging waste

Environment

In a circular economy model packaging waste should be reduced and packaging should be made easier to recycle. The Commission will review the requirements on packaging and packaging waste placed on the EU market. This will included assessing how to improve packaging design to support waste prevention, reuse, recycling, and to increase recycled content in packaging. Measures to tackle excessive packaging and reduce packaging waste will also be explored.

Links

Public consultation

ID: 12263

Lobbying Activity

315 responses

Environmental Bureau Demands Stricter EU Packaging Waste Prevention Targets

European Environmental Bureau, 9 Mar 2023

The EEB requests more ambitious waste prevention targets, expanded reuse requirements, and stronger chemical restrictions. They argue the proposal's 5% reduction target by 2030 is insufficient and call for 15% reduction to reverse the last decade's packaging growth. They want reuse targets expanded beyond beverages to retail, cosmetics, and other sectors, with systems requiring deposit incentives.
This would advance their environmental protection mission and circular economy advocacy goals.
Packaging industry faces higher compliance costs and operational restrictions from stricter requirements.

AmCham EU urges harmonised rules and longer packaging transition periods

American Chamber of Commerce to the European Union, 24 Apr 2023

AmCham EU advocates for a 36-month transition period and recommends applying recycled content targets to portfolios rather than individual units. They also urge keeping marketing and consumer acceptance as key design criteria.
A longer implementation window and flexible targets would lower compliance costs and protect brand identity.
Environmental groups lose if strict empty space limits inadvertently increase transport emissions and waste.

Chemical industry pushes for mass balance methodology in packaging rules

European Chemical Industry Council, 24 Apr 2023

The organization requests urgent clarity on mass balance calculation methods for recycled content, preferably before 2026. They want all waste types, including pre-consumer waste, to count toward recycled content targets. They argue chemical recycling must be recognized alongside mechanical recycling and call for technology-neutral recyclability requirements.
This would allow chemical companies to use existing infrastructure and count chemically recycled content toward targets.
Mechanical recyclers lose competitive advantage if chemical recycling counts equally toward targets.

Chemical Industry Seeks Mass-Balance Approach for Recycled Content Rules

European Chemical Industry Council, 24 Jul 2020

The organization requests fully harmonized EU-level rules and a mass-balance approach for measuring recycled content. They want the Commission to recognize chemical recycling technologies and avoid prescriptive definitions that discriminate against new recycling methods.
This would allow chemical recycling technologies to count toward recycled content targets alongside traditional methods.
Environmental groups lose stricter material tracking that ensures genuine recycling over accounting flexibility.

EuroCommerce urges harmonisation and infrastructure investment in packaging rules

EuroCommerce, 24 Apr 2023

The organization requests harmonized sorting instructions across the EU, investment in recycling infrastructure, and a one-stop-shop for Extended Producer Responsibility. They also want a stakeholder forum and uniform enforcement to reduce administrative burden.
This would reduce compliance costs and simplify cross-border operations for retailers.

EuroCommerce Urges Harmonised EU Rules to Boost Packaging Recycling

EuroCommerce, 6 Aug 2020

The organization calls for fully harmonised rules to ensure a well-functioning internal market. They believe decisions on reusable versus recyclable packaging should be made on a case-by-case basis. They also recommend updating existing European standards to reflect the waste hierarchy.
Harmonised definitions would lower compliance costs for retailers operating across multiple borders.
Consumers and the environment lose if packaging removals lead to significantly higher food waste.

DIGITALEUROPE urges harmonised labels and longer implementation timelines

DIGITALEUROPE, 22 Mar 2023

The association requests a 36-month transition period and the removal of conflicting national labels. They also advocate for digital QR codes rather than physical printing for material information.
This would decrease compliance costs and prevent fragmentation within the internal market.
Member States lose the ability to mandate specific national sorting instructions.

European farmers urge flexible targets for food and wine packaging

European farmers, 23 Mar 2023

The group calls for a revision of bans on single-use packaging for fresh produce. They also request excluding the wine sector from mandatory reuse and refill targets. Finally, they advocate for longer transition periods to ensure economic feasibility.
This would prevent increased production costs and protect the viability of agricultural cooperatives.

Amazon urges EU to reward e-commerce-ready packaging designs

Amazon Europe Core SARL, 17 Apr 2023

Amazon requests incentives for packaging tailored to online trade that avoids secondary boxes. They propose meeting empty space and recycled content targets through company-wide averages rather than per-unit requirements.
Averaging targets across all shipments would provide Amazon with significant regulatory and operational flexibility.
Environmental monitoring loses effectiveness if individual packages are allowed to exceed waste limits significantly.

European steel industry urges stricter standards for recyclable packaging

The European Steel Association, 24 Apr 2023

The association proposes stricter qualitative criteria for labeling packaging as recyclable and a performance grading system. They argue that recycled content targets should not apply to steel due to its high recycling rates. Additionally, they want certain industrial steel containers excluded from reuse targets.
Exempting steel from specific targets avoids costly logistical changes and economic disruption.
Competitors producing lighter materials may face substitution risks under these specific targets.

Consultation response

The European Steel Association, 6 Aug 2020

EUROFER welcomes PW prevention measures that take into account the wider scope of a circular and resource efficient economy, ensuring a net decrease in carbon emissions. It is worth to look at design for high-quality recycling, guaranteeing high-quality input in the recycling operations. Therefore,…

European agri-cooperatives demand exemptions from packaging rules

European agri-cooperatives, 23 Mar 2023

The group requests exemptions for fruit, vegetables, and wine from packaging bans and reuse targets. They also want bio-based materials recognized and longer transition periods for implementation.
These exemptions would protect current business models and avoid high costs of changing equipment.
Consumers may face higher food prices and more waste without protective packaging.

EFPIA warns pharmaceutical safety requires specific packaging exemptions

European Federation of Pharmaceutical Industries and Associations, 21 Apr 2023

EFPIA asks that the regulation accounts for the decade-long process to change medical packaging. They seek exemptions for labelling and recyclability to protect product stability and safety.
Maintaining current packaging avoids a massive bureaucratic burden and complex regulatory re-approvals.
Circular economy initiatives lose because pharmaceutical plastic waste will likely remain non-recyclable.

Finnish Forest Industries Urges Complementary Reuse and Recycling Rules

Finnish Forest Industries Federation (Metsäteollisuus ry), 20 Apr 2023

They argue that recyclable and reusable options should be complementary solutions for sustainability. They request exempting paper-based packaging from reuse targets if recycling goals are met.
This protects the industry's massive investments in fiber-based recycling technologies and infrastructure.
Climate advocates lose if the shift to reuse inadvertently increases fossil-based plastic consumption.

German car industry urges flexibility in EU packaging rules

Verband der Automobilindustrie, 21 Apr 2023

The VDA requests exemptions for legacy spare parts packaging to avoid damaging sensitive components. They also urge a reconsideration of ambitious plastic recycling targets and transport re-use mandates.
Exemptions would prevent unnecessary costs and material waste from repacking stored automotive components.
Small packaging manufacturers may face disadvantages when competing for scarce and expensive recycled plastics.

Orgalim Urges Realistic Recycled Content Rules and Harmonisation

Orgalim – Europe's Technology Industries, 24 Apr 2023

Orgalim calls for harmonised EU requirements and realistic targets for recycled content based on availability. They demand sufficient transition periods and the removal of unnecessary administrative burdens like the Declaration of Conformity.
Harmonised rules and lower administrative requirements would reduce compliance costs and prevent market fragmentation.
National governments lose the power to implement stricter or unique local environmental labelling schemes.

DIHK urges lower SME bureaucracy in packaging rules

Deutsche Industrie- und Handelskammer, 12 Apr 2023

DIHK proposes a single EU-wide registration system and uniform labeling to simplify trade. They call for de minimis thresholds and longer transition periods to protect smaller enterprises.
Harmonized rules would significantly reduce administrative expenses and prevent companies withdrawing from markets.
Environmental goals could be undermined by exemptions to packaging volume minimization requirements.

FoodDrinkEurope urges realistic timelines and flexible recycling rules

FoodDrinkEurope, 24 Apr 2023

FoodDrinkEurope requests a 2030 deadline for recyclability and a five-year transition for design rules. They propose calculating recycled content across entire product portfolios rather than per unit.
Flexibility in calculations would protect manufacturing optimization and prevent price increases for consumers.
Environmental groups lose the stricter accountability provided by mandatory unit-level recycled content targets.

Consultation response

FoodDrinkEurope, 6 Aug 2020

Please refer to the document in the Annex for the full FoodDrinkEurope contribution to the Packaging and Packaging Waste Directive Inception Impact Assessment. The end goals of the future PPWD and the new Circular Economy Action Plan (CEAP) should be to reduce and limit the environmental footprint…

Austrian Economic Chamber Urges Major Overhaul of Packaging Rules

Wirtschaftskammer Österreich, 24 Apr 2023

The organization requests a fundamental revision to protect marketing strategies. They advocate for five-year transition periods and rejecting mandatory reuse targets.
This would protect branding freedom and reduce significant administrative and financial burdens.
Environmental efforts suffer if mandatory reuse targets for beverage packaging are deleted.

Consultation response

Wirtschaftskammer Österreich, 4 Aug 2020

Vielen Dank für die Gelegenheit, Feedback zu den Anforderungen an Verpackungen und anderen Maßnahmen zur Vermeidung von Verpackungsabfällen zu geben. Unsere Stellungnahme finden Sie in der beigefügten Datei.

Neste calls for non-fossil targets in EU plastic packaging rules

Neste Oyj, 14 Apr 2023

Neste proposes adding new non-fossil targets for virgin plastics to support climate goals. They also suggest letting renewable materials help meet recycling targets during supply shortages.
The proposal would create regulatory incentives and market demand for Neste's renewable products.
Fossil fuel suppliers face reduced demand as the industry moves away from oil.

Consultation response

Neste Oyj, 6 Aug 2020

Neste Corp. (www.neste.com) is the world’s largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the polymers and chemicals industries. Our business is focused on combating climate change and driving circular economy, and we are committed to…

MedTech Europe urges seven-year transition for medical packaging rules

MedTech Europe, 3 Apr 2023

MedTech Europe requests a seven-year transition period to implement new packaging requirements. They advocate for material-neutral exemptions and alignment with existing medical device regulations.
This avoids supply disruptions and reduces costs associated with immediate redesign and recertification.
Environmental groups lose as the transition to a circular economy is significantly delayed.

Consultation response

MedTech Europe, 5 Aug 2020

MedTech Europe - the European trade association for the medical technology industry including diagnostics, medical devices and digital health - welcomes the opportunity to contribute to the initial roadmap consultation regarding the review of the requirements for packaging and other measures to…

MEDEF urges flexibility and technological neutrality in packaging rules

Mouvement des Entreprises de France, 24 Apr 2023

MEDEF requests flexibility for member states to reach targets using their own methods. They advocate for technological neutrality instead of mandatory reuse or deposit systems.
This maintains predictability for industrial investors and reduces administrative reporting costs.
Environmental organizations lose from weakened EU-wide mandates for reuse and compostable packaging.

Finnish technology industry urges flexibility in EU packaging rules

Technology Industries of Finland (Teknologiateollisuus ry), 24 Apr 2023

TIF wants reuse and recycling to be treated as complementary strategies. They request exemptions for specialized packaging and removal of administrative conformity declarations.
Flexible rules and harmonized standards would reduce compliance costs and operational burdens.
Groups advocating for a strict waste hierarchy lose when companies bypass reuse requirements.

Paper industry urges evidence-based approach to EU packaging regulation

Confederation of European Paper Industries, 21 Apr 2023

The industry requests involvement in drafting Design for Recycling Guidelines through CEN, a mandatory 90% collection target for all packaging by 2030, and evidence-based policy decisions on reuse targets that consider lifecycle impacts and technological implications.
This would protect their role in packaging standards and avoid penalties for collection failures beyond their control.
Mandatory reuse targets could harm parts of the fibre-based packaging industry and reduce renewable packaging use.

German engineering association VDMA warns against EU packaging bans

Verband Deutscher Maschinen- und Anlagenbau e.V., 24 Apr 2023

VDMA requests harmonized EU regulations to replace national rules and opposes bans on specific packaging formats. They advocate for gradual recycled content targets and reusability exceptions for custom industrial transport packaging.
Uniform standards and exemptions would protect established business models and maintain industry jobs.

Swedish forest industry urges incentives for renewable packaging materials

Swedish Forest Industries Federation, 30 Jan 2023

SFIF wants incentives for renewable materials and science-based reuse targets. They propose applying recycled content quotas only to packaging primarily made of plastic.
This would allow wood-based industries to expand by substituting fossil-based packaging.
Food distributors and consumers may suffer from increased waste due to bans.

Consultation response

Swedish Forest Industries Federation, 14 Jul 2020

Swedish Forest Industries welcome the new Circular Economy Action Plan, as we believe it will be beneficial in achieving the overall targets for the European Green Deal. Reduce waste and create better conditions to improve reuse and recycling of goods are necessary to achieve the transition to…

Coldiretti warns packaging rules threaten Italian agricultural production

Confederazione Nazionale Coldiretti, 21 Apr 2023

Coldiretti requests using a directive instead of a regulation to preserve national recycling successes. They seek exemptions for wine and beer and a broader exclusion for flower pots. They also urge revising the ban on packaging for small produce.
This would allow Italian producers to avoid new administrative costs and preserve traditional branding.
Consumers could face higher food prices and increased risks of contamination and waste.

SUEZ Urges Recycled Content Targets for All Packaging Materials

SUEZ Group, 24 Apr 2023

SUEZ calls for mandatory recycled content targets for all materials, including paper and glass. They argue deposit return systems should be flexible and that compostable packaging use should be strictly limited.
Mandating recycled content across all materials would boost demand for SUEZ's industrial recycling services.
Producers of compostable packaging face restricted market access if their products are strictly limited.

Consultation response

SUEZ Group, 27 Jul 2020

SUEZ is committed to help reducing packaging wherever this is reducing the environmental footprint of the packaged product from cradle to cradle. SUEZ therefore welcomes the actions the EU Commission wishes to take and fully supports the measures listed in the roadmap, notably the following:…

APPLiA demands harmonised packaging rules and digital labelling options

APPLiA (Home Appliance Europe), 3 Mar 2023

APPLiA seeks a harmonised approach to keep markets open and trade flowing. They request a five-year implementation time and preference for digital labels over paper versions. Reusable targets should only apply when reasonable from a technical and environmental perspective.
Extended transition periods and digital labels would reduce manufacturing costs and administrative burdens.
Member States lose autonomy to enforce specific national labelling and waste sorting requirements.

European Brands Association Urges Harmonised Rules and Labelling Delays

AIM - European Brands Association, 24 Apr 2023

The group requests a 36-month transition period for new labels. They demand that packaging rules protect brand identity. They also advocate for harmonised EU recycling symbols.
This would lower compliance costs and protect the distinct design of branded products.
Environmental protections are weakened by delayed implementation rules and extended transition periods.

Consultation response

AIM - European Brands Association, 31 Jul 2020

AIM, the European Brands Association, fully supports the objective of the Green Deal towards a clean, circular and climate neutral economy. Focusing on eco-design for packaging from a holistic point of view has long been a priority for branded goods manufacturers, and at the forefront of many…

German chemical industry demands exemptions for industrial packaging

Verband der Chemischen Industrie e.V., 19 Apr 2023

VCI requests excluding industrial packaging and recognizing chemical recycling as a valid method. They also propose calculating recycled content averages across entire companies.
This would reduce regulatory costs and allow flexibility for complex industrial logistics.
Environmental efforts suffer as large streams of industrial waste would remain unregulated.

Consultation response

Verband der Chemischen Industrie e.V., 4 Aug 2020

Thank you for the opportunity of giving feedback on requirements for packaging and other measures to prevent packaging waste. Our statement can be found in the attached file.

Danish food producers urge stronger EU-wide packaging harmonization

Landbrug Fødevarer - Danish Agriculture and Food Council, 20 Apr 2023

The group demands uniform EU rules to stop national labeling requirements from blocking exports. They also urge removing mandatory reuse targets for food packaging to prevent hygiene risks and food waste. Finally, they propose stopping high-quality food plastic from being used in non-food items.
Harmonized rules would reduce export barriers and protect the quality of food products.
Environmental groups lose if the reduction of plastic waste through reuse targets is abandoned.

Consultation response

Plastics Europe, 5 Aug 2020

Please see the attached document for full feedback.

Metsä Group defends fibre packaging against mandatory reuse targets

Metsäliitto Cooperative, 24 Apr 2023

The group wants single-use and reusable packaging treated as "complementary solutions." They urge the EU to base decisions on "life cycle impact assessments." Finally, they request that "recyclability should be required" instead of mandatory reuse.
This allows the company to continue selling single-use fibre products without restriction.
The reusable packaging industry loses market growth if single-use fibre options remain dominant.

German steel industry calls for recognition of permanent materials

Wirtschaftsvereinigung Stahl, 24 Apr 2023

The association proposes introducing a 'Permanent Material' definition for metals that can be recycled multiple times. They also demand material-specific waste reduction targets to ensure fair effort sharing across industries.
The industry would avoid new compliance costs for their already efficient recycling systems.
Manufacturers of single-use items lose competitive advantage against materials labeled as permanently recyclable.

NABU Demands Stricter EU Rules to Curb Packaging Waste

Naturschutzbund Deutschland e.V., 19 Apr 2023

NABU calls for more ambitious recyclability criteria and mandatory reuse targets that include cardboard transport packaging. They demand that all recycling targets be met through mechanical processes alone. The organization also proposes a ban on packaging used solely for marketing purposes.
Stricter standards would help NABU achieve its environmental goals of resource efficiency and climate protection.
Chemical recycling firms and the paper industry would lose their current regulatory advantages and exemptions.

Consultation response

Zero Waste Europe, 11 Apr 2023

Please find Zero Waste Europe's feedback in the attached document.

Consultation response

Naturschutzbund Deutschland e.V., 6 Aug 2020

Der NABU erachtet die von der Europäischen Kommission geplanten Maßnahmen als sinnvoll und dringend notwendig, um die negativen ökologischen Folgen von Verpackungen und Verpackungsabfällen zu minimieren (z.B. CO2-Emissionen durch Abfallverbrennung, aquatische und terrestrische Umweltverschmutzung…

Consultation response

Wirtschaftsvereinigung Stahl, 6 Aug 2020

Die Wirtschaftsvereinigung Stahl begrüßt die Anstrengungen der Kommission, Verpackungsabfälle zu verringern und das Recycling zu fördern. Mit der Europäischen Verpackungsrichtlinie als regulatorischem Pfeiler des Verpackungsrecyclings ist es gelungen, große Mengen an Verpackungen in den…

Consultation response

Zero Waste Europe, 4 Aug 2020

The Rethink Plastic alliance welcomes the review of the requirements for packaging and measures to prevent packaging waste. Our main comments on the inception document are attached.

Cosmetics Europe urges harmonisation and chemical recycling recognition

Cosmetics Europe, 21 Apr 2023

Cosmetics Europe seeks explicit recognition for chemical recycling to meet recycled content targets. They also advocate for harmonised labelling and flexibility in packaging design to prevent product standardisation.
These measures would protect brand identity while providing the industry with investment security.
Member States would lose the power to implement specific national environmental labels.

Consultation response

Cosmetics Europe, 3 Aug 2020

Cosmetics Europe represents the cosmetics and personal care industry in Europe. Ranging from antiperspirants, fragrances, make-up and shampoos, to soaps, sunscreens and toothpastes, cosmetics and personal care products play an essential role in in all stages of our life. European citizens use…

ECOS Urges Stricter Standards to Prevent Packaging Greenwashing

Environmental Coalition on Standards, 24 Apr 2023

ECOS calls for a right to use personal containers and expanded bulk sales. They demand specific minimum reuse cycles to prevent single-use items from being rebranded as reusable.
Stricter definitions prevent companies from evading environmental taxes through deceptive packaging labels.
Producers of low-quality plastics would lose the ability to bypass single-use regulations.

German municipal utilities urge EU to adopt packaging Directive

Verband Kommunaler Unternehmen e.V., 13 Feb 2023

The organization requests that the rules be implemented through a Directive rather than a Regulation. They also support mandatory recycled content and stricter requirements for compostable plastics.
A Directive preserves their established national waste management systems and avoids reorganization.
Producers of compostable plastics face tighter restrictions as their materials disrupt recycling.

Repsol urges EU to recognize chemical recycling for packaging

Repsol, S.A., 24 Apr 2023

Repsol calls for chemical recycling to be legally equivalent to mechanical methods. They request a clear calculation methodology immediately to provide legal certainty for investments.
This allows the company to leverage existing infrastructure instead of building expensive new plants.

Packaging Industry Urges Infrastructure Investment Alongside New EU Rules

The European Organisation for Packaging and the Environment, 8 Mar 2023

The organization requests mandatory collection targets and obligations for Member States to invest in sorting and recycling infrastructure. They argue that sustainability requirements on packaging alone will not succeed without infrastructure capable of handling recyclable and reusable materials. They also call for exemptions for already-packaged products and clear timelines for secondary legislation.
This would give them more time to adapt production and reduce costs from redesigning packaging.
The proposal does not clearly identify disadvantaged groups in this feedback.

Consultation response

Veolia Environnement, 6 Aug 2020

Veolia is the global leader in optimised resource management. With over 163 000 employees worldwide, the Group designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries. Through its three complementary business…

Consultation response

The European Organisation for Packaging and the Environment, 29 Jul 2020

EUROPEN - The European Organization for Packaging and the Environment - supports the general objective for the revision of the Packaging and Packaging Waste Directive, which is a well-functioning Internal Market through fully harmonised rules on packaging while tackling the environmental impact of…

Stora Enso urges renewable materials shift in EU packaging rules

Stora Enso Oyj, 20 Apr 2023

The company requests that the regulation promote circular renewable materials over fossil-based alternatives, establish 90% mandatory separate waste collection targets, and maintain exemptions for cardboard transport packaging from reuse obligations. They argue current provisions may inadvertently shift markets toward less sustainable plastic or energy-intensive materials.
This would protect their fiber-based packaging business from displacement by plastic alternatives.
Reusable plastic packaging manufacturers lose market share in transport and grouped packaging segments.

Consultation response

Tetra Pak Group, 5 Aug 2020

Tetra Pak supports the EU Commission’s objectives for the revision of the Packaging and Packaging Waste Directive (PPWD) to ensure the internal market for packaging, compliance with recycling targets and the reduction of packaging waste. At the same time, we believe that the next revision of the…

UPM advocates for bio-based plastic parity and recycling exemptions

UPM-Kymmene Oyj, 2 Mar 2023

UPM seeks to limit recycled plastic mandates to products made mostly of plastic. They want bio-based content to count toward targets and recycling-based exemptions.
This would allow UPM to utilize its bio-based products and avoid technical difficulties.
Reuse service providers lose market share if high-recycling single-use packaging is exempted.

Coca-Cola urges priority access to recycled materials in packaging reform

The Coca-Cola Company, 24 Apr 2023

Coca-Cola seeks mandatory deposit systems and priority access to high-quality recycled materials. They propose that recycling targets apply as a manufacturer average across all products. The company also calls for reuse targets to account for local infrastructure differences.
This would secure a dedicated supply of recycled material and lower compliance risks.
Non-beverage industries like fashion would lose access to high-quality recycled plastic feedstock.

McDonald’s urges EU to reject mandatory reusables for takeaway

McDonald’s Global Franchising Limited, 24 Apr 2023

McDonald’s recommends that reusable models should not be implemented for takeaway and delivery. They request equivalence of treatment between recycled single-use packaging and reusable tableware.
This prevents a massive increase in greenhouse gas emissions and operational washing costs.
Environmental advocates lose a key regulatory mandate to phase out single-use disposables.

Independent Retail Europe Urges Group-Level Packaging Waste Targets

Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe), 24 Apr 2023

The group requests that reuse targets apply at the group level rather than individual store level. They call for longer transition periods and legal certainty regarding hygiene standards for consumer-provided containers.
Aggregating targets would preserve the competitiveness of small retailers against large integrated supermarket chains.
Consumers could face higher prices and reduced product variety in smaller local shops.

Consultation response

European Recycling Industries' Confederation, 23 Jul 2020

The European Recycling Industries’ Confederation (EuRIC) strongly welcomes the Inception Impact Assessment on the review of the requirements for packaging and other measures to prevent packaging waste and fully supports the initiative’s aim to tackle the limited competitiveness of secondary…

Consultation response

Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien, 5 Aug 2020

A.I.S.E. supports the revision of the existing requirements for packaging and the consideration of other measures to prevent unmanaged packaging waste. A.I.S.E. calls for a revision that helps steering tangible progress, while stimulating innovation and competitiveness of the EU industry in a…

Ecommerce Europe Urges One-Stop-Shop for EU Packaging Rules

Ecommerce Europe, 24 Apr 2023

The group requests a digital one-stop-shop for registration and reporting to streamline producer responsibility across Member States. They propose that the 40% empty space limit be calculated as a company-wide average rather than for individual parcels. Additionally, they argue that waste prevention measures should contribute toward reaching mandatory reuse targets.
This would significantly lower the administrative and financial costs associated with complying with diverse national rules.
Environmental groups lose if flexible averaging allows businesses to avoid strict packaging reduction for specific products.

Huhtamäki warns EU packaging rules threaten food security and hygiene

Huhtamäki Oyj, 31 Mar 2023

Huhtamäki demands a science-based approach prioritizing paper packaging over plastic reuse systems. They also seek mandatory take-back schemes and achievable recycled content targets.
Protecting paper-based systems avoids the replacement of their products with plastic alternatives.
European consumers face higher prices and risks to food safety and hygiene.

Confcommercio urges EU to protect Italian packaging recycling model

CONFCOMMERCIO - IMPRESE PER L'ITALIA, 14 Mar 2023

Confcommercio calls for a review of the proposal's structure to protect existing national recycling systems. They request that reuse targets be balanced with recycling models through cost-benefit analyses and financial incentives.
Preserving national models avoids costly infrastructure updates and logistical burdens for retailers.
Consumers and the environment face higher health risks and increased resource consumption.

AESGP urges healthcare-specific flexibility in EU packaging rules

Association of the European Self-Care Industry, 24 Apr 2023

AESGP demands packaging rules remain coherent with existing healthcare safety legislation. They seek exemptions for all medical device materials and request digital labeling. The industry also wants longer transitional periods to ensure legal certainty.
This approach protects their market access while lowering administrative costs for proving packaging minimization.
Environmental goals could be undermined if industry-led exemptions delay the reduction of non-recyclable materials.

PepsiCo urges broader refill definitions and priority plastic access

PepsiCo, 17 Apr 2023

PepsiCo requests that refill-at-home solutions be counted toward reuse targets using a volume-based calculation. They also propose calculating recycled content as a company-wide average to support chemical recycling for snack bags. Additionally, they seek priority access to recycled plastic collected via deposit systems.
This allows the company to meet targets more easily while securing essential raw materials.
Other industries would lose access to the high-quality recycled plastic they currently use.

Kemira warns packaging rules could favor unsustainable fossil-based plastics

Kemira Oyj, 31 Mar 2023

Kemira argues recycling must be valued equally to reuse and that mandatory reuse targets should consider food safety. They request that recycled plastic content targets apply only to all-plastic packaging.
This protects Kemira's chemical business from unfeasible requirements for its fibre-based packaging solutions.
The European paper industry suffers from regulations that favor fossil-based plastic replacements.

Consultation response

PepsiCo, 30 Jul 2020

PepsiCo strongly supports the strengthening of the Essential Requirements and the work being done to identify measures for waste prevention as part of the revision of the Packaging and Packaging Waste Directive (PPWD). The attached note includes several elements we hope will be considered as the…

EU wine body urges flexible reuse and digital labeling

Comité Européen des Entreprises Vins, 24 Apr 2023

They want specific wording for wine reuse targets and postponed deadlines. The group promotes digital labels to provide tailored recycling information to consumers.
Flexible rules avoid high costs and logistical burdens for small export-driven producers.
Environmental targets suffer as long-distance exports make bottle reuse schemes less efficient.

WWF Germany Urges Ambitious Packaging Waste Reduction Targets

WWF Deutschland, 21 Apr 2023

Raise waste reduction targets to 10% by 2030 and 20% by 2040. Recyclability requirements should increase to 90% to achieve high-quality recycling. Strictly limit empty space for product and e-commerce packaging.
These measures would help stop environmental degradation and preserve natural livelihoods.
Manufacturers and e-commerce companies would lose flexibility in packaging design and marketing.

European Meat Industry Urges Exemptions for Recycled Packaging Mandates

Association de l'Aviculture, de l'Industrie et du Commerce de Volailles dans les Pays de l'Union Europeenne asbl, 24 Apr 2023

The associations request exemptions from mandatory recycled plastic content for fresh meat. They also advocate for harmonized labels to avoid higher production costs.
Avoiding these rules prevents food safety risks and reduces packaging expenses.
Environmental groups lose as the meat industry delays transition to circular packaging.

AnimalhealthEurope seeks permanent exemptions for veterinary medicine packaging rules

AnimalhealthEurope, 21 Apr 2023

The group requests a permanent exemption from recyclability requirements for all primary veterinary medicine packaging. They also advocate for replacing paper leaflets with digital versions to decrease waste.
This prevents massive regulatory costs and delays from re-validating medicine packaging materials.
Recyclers lose because medical packaging components remain difficult to process or contaminate streams.

Consultation response

Confédération des Petites et Moyennes Entreprises, 24 Apr 2023

Madame, Monsieur, Je vous prie de trouver ci-joint la note de position de la Confédération française des petites et moyennes entreprises (CPME) relative à la proposition de règlement portant sur les emballages et les déchets d'emballages. Cordialement, M. Cregut

Finnish Commerce Federation urges equal status for recyclable packaging

Kaupan liitto ry - Finnish Commerce Federation, 21 Apr 2023

The federation requests that recycling remain an equal alternative to reusable packaging. They propose delaying new reuse targets until 2028 to gather scientific evidence.
This would prevent the loss of significant investments made in Finnish recycling.
Mandatory reuse targets would impose unreasonable financial costs on consumers and producers.

Consultation response

Union of European Beverages Association, 24 Apr 2023

Dear all, Please find attached UNESDA's position on the proposal for a Packaging and Packaging Waste Regulation. Kind regards, UNESDA Secretariat

UNESDA urges EU to protect food-grade recycling loops

Union of European Beverages Association, 3 Aug 2020

The industry wants a legal framework prioritizing the recycling of beverage containers into new bottles. They request the Commission avoid absolute waste reduction targets and ensure internal market harmony.
Dedicated access to high-quality recycled material would help companies meet mandatory recycling targets.
Sectors using recycled plastic for other purposes would face a significant supply shortage.

Consultation response

European Paper Packaging Alliance, 24 Apr 2023

EPPA would like to highlight that: The current PPWR proposal on reuse targets is not achieving the best environmental, economic, and hygiene outcomes. To achieve the Green Deal objectives, the PPWR must be refined to include single-use paper packaging as a central pillar to achieve the EUs circular…

European Dairy Association urges exemptions from EU packaging reuse targets

European Dairy Association aisbl, 21 Apr 2023

They request deleting reuse targets and excluding dairy from deposit return systems. They want recycled plastic requirements delayed until food-safe recycling technologies are installed. The group also proposes keeping single-use packaging for condiments and coffee creamers.
This would protect the industry from high costs and hurdles of washing containers.
Environmental initiatives lose ground as the sector seeks to avoid single-use plastic bans.

Consultation response

European Dairy Association aisbl, 5 Aug 2020

• The European Dairy Association (EDA) welcomes the Commissions effort to review the Packaging and Packaging Waste Directive, including the Essential Requirements, with a focus on ensuring a European framework for investments in new and cutting-edge packaging solutions, supporting the reduction of…

Consultation response

Landwirtschaftskammer Österreich, 23 Jun 2020

Packaging waste from food is directly linked to our "modern" way of living: with long value chains, convenience food, food on the go, fast food etc. It is necessary to introduce legal rules to reduce packaging waste to force the industry to innovate and not just take the cheapest solution. But it…

Brewers demand fair competition in EU packaging waste rules

The Brewers of Europe, 24 Apr 2023

The group demands all beverage categories face identical reuse targets and deposit requirements. They insist transition periods only begin after secondary legislation is finalized. Reusable kegs must be included when calculating official reuse targets.
Uniform rules would prevent competitors from gaining a price or handling advantage.
Wine and spirits producers would lose their current exemptions from recycling schemes.

MOL Group urges market-driven approach to new packaging rules

MOL Hungarian Oil and Gas Company, 17 Feb 2023

MOL Group requests that recycling rules include innovative chemical technologies and allow for-profit waste system operators. They argue against mandatory material composition labelling which they claim confuses consumers.
This protects their chemical recycling investments and permits profit from waste management infrastructure.
Developing member states could face disproportionate burdens from uniform waste reduction targets.

Consultation response

MOL Hungarian Oil and Gas Company, 5 Aug 2020

CONTRIBUTION OF MOL GROUP MOL Group welcomes the objective of the initiative to establish a well-functioning market for secondary raw materials through fully harmonised rules on packaging while tackling negative impacts on environment and health from packaging and packaging waste. MOL Group…

Teva Pharmaceuticals warns packaging rules could impact medicine supply

Teva Pharmaceuticals Europe BV, 24 Apr 2023

Teva warns that changing primary packaging requires three-year stability studies and approvals. They argue medical devices should be excluded to ensure patient safety and supply. They also propose replacing paper leaflets with digital versions to cut waste.
Exemptions would prevent supply delays and avoid expensive, multi-year product stability testing.
Environmental groups lose potential waste reductions if medical packaging remains excluded from rules.

LEGO Group Urges Harmonised EU Rules and Digital Labels

The LEGO Group, 24 Apr 2023

The LEGO Group supports replacing national laws with a single EU Regulation to stop market fragmentation. They request material-specific recycling criteria and a shift toward digital labels to streamline global supply chains.
Harmonisation would eliminate the need for market-specific packaging, reducing production waste and costs.
Consumers without digital access might struggle to find sorting instructions if physical labels are simplified.

DuPont urges harmonized rules and medical packaging exemptions

DuPont de Nemours International SARL, 24 Apr 2023

DuPont supports a Regulation to ensure harmonization and avoid fragmented national rules. They request extending medical packaging exemptions to include raw materials and components. They also propose digital labelling and calculating recycled content targets as an average.
Harmonized rules and flexible targets would reduce administrative burdens and compliance costs.

Consultation response

European Insulation Manufacturers Association, 6 Aug 2020

Eurima (European Mineral Wool Insulation Manufacturers) supports the efforts of the European Commission on the revision of the requirements for packaging and packaging waste. Our industry is committed to constantly improve the packaging of our products by reducing the use of “fossil based/virgin…

Ecologistas en Acción demands total ban on toxic chemicals in packaging

Ecologistas en Accion, 24 Apr 2023

The group calls for a total ban on hazardous chemicals in all packaging, including recycled materials. They also want labels to list all ingredients and clearly identify substances of very high concern.
This would ensure recycled products are safe and prevent toxic chemicals from circulating in consumer goods.
Commercial interests face potential losses as health protections are prioritized over trade and competition.

Waste managers back mandatory recycled content in packaging rules

FEAD, 24 Apr 2023

The industry requests mandatory recycled content targets and prioritization of mechanical recycling. They strongly oppose granting the beverage industry priority access to recycled materials.
Mandatory targets for recycled materials would boost demand and drive industry investment.
Beverage producers lose the chance to monopolize recycled plastics and exclude other sectors.

Sporting goods industry urges flexible timelines for packaging labels

Federation of the European Sporting Goods Industry, 27 Mar 2023

FESI calls for extended deadlines for new labels to prevent the destruction of existing inventory. They also recommend using digital QR codes to provide consumers with harmonized sorting information.
This would lower operational costs and preserve the structural integrity of reusable packaging.

Consultation response

FEAD, 6 Aug 2020

Please, find attached FEAD’s full feedback to the EC Roadmap on Packaging Waste. FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the EC initiative on the review of the…

Eastman urges EU to recognize all plastic recycling technologies

Eastman Chemical Company, 24 Apr 2023

Eastman wants the EU to recognize chemical recycling alongside mechanical methods. They suggest including all plastic waste types in recycled content calculations. The company also promotes a 'mass balance' system for tracking materials.
This would secure the commercial viability of Eastman's chemical recycling investments.

IKEA urges harmonised EU packaging markings and rules

Inter Ikea Systems BV, 24 Apr 2023

IKEA requests harmonised markings and producer responsibility rules to reduce administrative burdens. They argue reuse targets should only apply if based on solid environmental evidence.
This would decrease operational complexity and reduce administrative costs across their global value chain.
Member States lose the authority to maintain or introduce specific national environmental labelling systems.

Flexible Packaging Europe demands harmonized rules and flexible recycling targets

Flexible Packaging Europe, 20 Apr 2023

FPE urges the EU to prioritize market harmonization and provide clear deadlines for new design-for-recycling criteria. They request that recycled content targets be calculated as a producer average rather than per packaging unit. Finally, they demand product-specific impact assessments for proposed bans and reuse targets.
Portfolio-wide averaging would allow them to maintain market access for specialized food packaging.
Environmental protections may be weakened if recyclability standards ignore a lack of collection infrastructure.

Haleon calls for harmonised rules and delayed packaging deadlines

Haleon, 13 Mar 2023

Haleon recommends amending the proposal to ensure that national requirements cannot go beyond EU rules. They also request at least ten years for medicine packaging to comply with new recyclability standards.
Harmonised legislation allows the company to trade across the EU without modifying products.
Individual Member States lose authority to mandate specific national environmental labelling requirements.

Consultation response

Flexible Packaging Europe, 31 Jul 2020

Flexible Packaging Europe (representing the flexible packaging industry in Europe) welcomes the opportunity to share its views on the inception impact assessment regarding the review of packaging and packaging waste rules. As the circular economy becomes a cornerstone of the EU’s industrial base,…

Municipal Waste Europe Demands Producers Pay Full Waste Collection Costs

Municipal Waste Europe, 31 Mar 2023

MWE requests that producers pay the full cost of collecting and treating waste. They propose creating a stakeholder forum to advise on technical recycling rules. They also seek flexibility to skip mandatory deposit systems where recycling is high.
This would protect local budgets by ensuring municipalities are fully reimbursed for services.
Packaging producers would face higher costs to cover the complete treatment of their products.

Henkel Urges Design Freedom and Clearer Packaging Rules

Henkel AG & Co. KGaA, 6 Apr 2023

Henkel requests clear technical definitions and exemptions for industrial pallet wrapping. They also advocate for chemical recycling and mass balance methods.
This would provide investment security while protecting the company's brand identity.
Environmental advocates may lose out if industrial sectors are exempt from reuse requirements.

Consultation response

Henkel AG & Co. KGaA, 5 Aug 2020

Henkel fully supports the European Commission’s ambition for a transition towards a more sustainable and circular economic system in packaging. Thus, we are welcoming the review of the Packaging and Packaging Waste Directive in order to fully realize the potential of a Circular Economy, notably…

Consultation response

Cooperativas Agro-alimentarias de España, 24 Apr 2023

Please find attached the position of Cooperativas Agro-alimentarias de España on the PPWR proposal.

Reloop demands stricter glass recycling rules and data transparency

RELOOP, 24 Apr 2023

Reloop requests including glass in mandatory deposit-return systems and establishing a negative list of non-recyclable packaging. They also demand public access to national waste data to ensure better accountability and scrutiny.
Enhanced data transparency would allow the group to hold governments accountable for waste performance.
Glass producers would lose their economic advantage over other materials like plastic and metal.

Sciaena demands tougher waste prevention targets in packaging rules

Sciaena - Ocean # Conservation # Awareness, 24 Apr 2023

Sciaena calls for prioritizing waste prevention and reuse over recyclability targets. They advocate for banning harmful chemicals and unnecessary single-use items. The group demands a 15% waste reduction target by 2030.
Stricter rules would better protect marine ecosystems from plastic and chemical pollution.
The packaging industry loses the ability to sell multi-material and layered disposables.

Beverage carton alliance seeks mandatory collection and reuse exemptions

The Food and Beverage Carton Alliance, 20 Apr 2023

ACE requests a 90% mandatory collection target and exemptions from reuse targets for juice products. They also want recycled content targets to be conditional on material availability.
This would create a level playing field and prevent unfeasible recycled content requirements.
Glass manufacturers lose potential market growth if juice remains exempt from reuse requirements.

Consultation response

The Food and Beverage Carton Alliance, 24 Jul 2020

Please see the attached document for full feedback.

German Metal Industry Demands Recognition for Permanently Recyclable Materials

WirtschaftsVereinigung Metalle, 21 Apr 2023

The association requests a legal definition for infinitely recyclable 'permanent materials'. They seek to exempt aluminum coffee capsules from compostability mandates. They also argue that English should be accepted for all technical documentation.
This would protect the market position of aluminum cans and reduce compliance costs.

Japan Business Council urges clearer rules and longer packaging deadlines

Japan Business Council in Europe, 24 Apr 2023

JBCE requests transitional periods to avoid supply chain disruptions. They seek exemptions for sensitive industrial goods like semiconductors. They want chemical recycling and bio-based plastics included in targets.
This would reduce compliance burdens and prevent damage to high-precision equipment.
Member States lose the power to implement stricter national environmental labelling.

Freshfel Europe opposes discriminatory packaging ban for fresh produce

Freshfel Europe - the forum for the European fresh fruits and vegetables chain, 21 Apr 2023

Freshfel urges policymakers to reconsider the ban on single-use packaging for fresh fruits and vegetables. They advocate for sector-led commitments and innovation instead of mandatory restrictions.
This would prevent operational disruptions and maintain the shelf-life and safety of perishable produce.
Consumers face higher health risks and reduced food quality, while environmental efforts suffer from increased waste.

EuPC calls for harmonized rules and realistic recycling targets

European Plastics Converters Association, 21 Apr 2023

The association supports a unified EU law to prevent conflicting national rules. They want recycled content calculated as a yearly average to help businesses adapt. They also request a safety net for potential shortages of recycled materials.
These changes would reduce administrative costs and provide flexibility during material shortages.
National governments lose the ability to set stricter environmental rules for their markets.

ANEC Demands Stricter Bans on Toxic Chemicals in Packaging

The European Consumer Voice in Standardisation, 17 Mar 2023

The group demands more ambitious targets for preventing unnecessary packaging waste. They also call for a mandatory phase-out of hazardous chemicals in materials. Legislation must prioritize reuse systems over recycling to protect human health.
Consumers would benefit from safer products and more convenient waste reduction options.
Manufacturers of low-quality recycled materials face higher costs to meet safety standards.

Consultation response

Freshfel Europe - the forum for the European fresh fruits and vegetables chain, 5 Aug 2020

Packaging is an essential element of the European fresh fruit and vegetable supply chain. The fresh produce sector uses packaging throughout the supply chain from production, wholesale, logistics, trade and at retail level to provide safe, high quality and fresh products to consumers. Freshfel…

Consultation response

The European Consumer Voice in Standardisation, 31 Jul 2020

In ANEC’s view, the "essential requirements" of the Packaging Directive are vague, do not give clear instructions to business and cannot be enforced. The associated CEN standards were intended to provide more detailed provisions and clarity, but the influence exerted by the European packaging…

Metal Packaging Europe urges recognition of highly recyclable materials

Metal Packaging Europe External Affairs ASBL, 24 Apr 2023

MPE requests a 'highly recyclable' status for permanent materials and universal deposit return systems. They also seek to ensure plastic content targets do not apply to metal packaging components.
This classification would allow the metal industry to avoid costly reuse mandates and plastic-related compliance burdens.
Environmental groups lose if reuse targets are weakened by broad exemptions for single-use metal packaging.

Federchimica defends Italian recycling model against strict reuse mandates

Federazione Nazionale dell'Industria Chimica italiana, 21 Apr 2023

Federchimica requests flexibility for member states to choose effective waste management technologies. They also request immediate legal certainty for chemical recycling methods.
This would preserve Italy's cost-effective waste system and protect existing industrial investments.
Consumers and international traders may suffer from trade barriers and health risks.

Natural Mineral Waters Europe demands priority access to recycled plastic

Natural Mineral Waters Europe aisbl, 24 Apr 2023

The group requests priority access to recycled materials to maintain a closed loop for beverage bottles. They also urge the Commission to bring forward deposit system deadlines and make reuse targets more flexible for producers.
Secured access to recycled PET helps water producers meet legal targets while lowering material costs.
Non-beverage industries lose access to high-quality recycled plastic for their own manufacturing processes.

German pharmaceutical industry seeks exemptions for medical packaging

Bundesverband der Pharmazeutischen Industrie e.V., 6 Apr 2023

BPI proposes differentiating packaging types while requesting longer transition phases for medical applicators. They also advocate for recognizing chemical recycling and using QR codes.
Exemptions would prevent significant cost increases and protect the viability of EU manufacturing.
Patients could face higher prices for medicines if compliance costs are passed on.

Waste-to-Energy plants urge focus on recycling quality

Confederation of European Waste-to-Energy Plants, 5 Aug 2020

CEWEP emphasizes that the elimination of toxic substances should take priority over simply increasing recycling volumes. They argue that Waste-to-Energy plants act as essential gatekeepers by treating contaminated materials that would otherwise pollute the recycling stream.
This perspective secures a permanent role for incineration in the circular economy infrastructure.
Low-quality recycling operations might lose out if strict toxic substance standards are enforced.

Consultation response

Natural Mineral Waters Europe aisbl, 31 Jul 2020

EFBW would like to share its views on the roadmap of the upcoming review of Packaging & Packaging Waste Directive (PPWD). All drink containers used by natural mineral and spring water producers, be it PET, glass or aluminium, are fully recyclable while overpackaging is absent from this sector.…

Consultation response

Sulapac oy, 24 Apr 2023

Sulapac welcomes the EUs efforts to both combat packaging waste and accelerate the EU transition to a circular economy. This will not only require strong recycling, re-use and recycled content targets but also measures to reduce the harmfulness of packaging waste. Sulapacs mission is to develop…

European glass industry urges material-specific waste reduction targets

European Container Glass Federation, 20 Apr 2023

The federation requests material-specific targets to ensure all materials contribute equally. They want performance criteria to recognize product presentation to protect brand identity. They advocate for keeping glass out of mandatory deposit return schemes.
This would protect the sector's profitability and help maintain its strong export position.
Environmental groups lose if policy triggers a shift from circular glass to plastic.

German waste industry urges mechanical recycling priority in EU law

BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V., 24 Mar 2023

The group wants packaging design to prioritize mechanical recycling over chemical methods. They also advocate for mandatory participation in collective producer responsibility systems.
This ensures long-term investment security for their existing mechanical recycling facilities.
Chemical recycling companies lose out as their technology is relegated to a subordinate role.

SNE seeks specialized nutrition exemptions from EU packaging waste rules

Specialised Nutrition Europe, 20 Feb 2023

SNE requests exemptions for specialized nutrition from recyclability, recycled content, and reuse requirements. They argue that infant and medical foods need the same protections as medicines.
This would ensure patient safety and security of supply for vulnerable groups.
Environmental groups lose because exemptions reduce the amount of packaging being recycled.

Polystyrene manufacturers warn packaging targets risk hygiene and bankruptcies

EUMEPS, 14 Feb 2023

EUMEPS calls for lowering reuse targets for transport packaging and large household appliances to realistic levels. They demand that the waste hierarchy be replaced by a matrix considering transport distances and hygiene. Additionally, the regulation should permit chemical recycling as a complement to mechanical methods.
This would protect business models and prevent costs from redesigning tailored packaging.
Consumers face hygiene risks and increased food waste from unsuited reusable food packaging.

Valmet Challenges EU Packaging Data and Reuse Mandates

Valmet Oyj, 23 Mar 2023

The organization requests that restrictions on certain single use packaging be deleted unless evidence is presented. They argue reuse targets should be indicative and set at an EU level.
The company maintains its market for fiber-based solutions and avoids negative economic impacts.
Efforts to achieve a low-carbon circular economy could be slowed by prioritizing single-use packaging.

German Biogas Association warns against biodegradable plastic packaging

German Renewable Energy Federation, 24 Apr 2023

The GBA argues that anaerobic digestion is not a suitable recycling method for any packaging. They highlight that biodegradable plastics offer no biogas potential and can damage plant machinery.
Excluding these materials prevents operational damage and ensures the production of high-quality organic fertilizers.
Makers of biodegradable packaging lose because their products are classified as impurities and incinerated.

Czech Chamber of Commerce Urges Delay of Packaging Waste Rules

Hospodářská komora České republiky, 24 Apr 2023

The organization requests suspending the regulation until all future legal details are submitted. They propose splitting the act into technical standards and national waste goals. They also demand fairer reduction targets reflecting a country's economic activity.
This approach would prevent business uncertainty and protect national industrial competitiveness.
The recycling industry faces potential closure and job losses under mandatory reuse targets.

Consultation response

EDANA AISBL, 22 Apr 2023

EDANA, the international association serving the nonwovens and related industries, supports the ambition of the Commission Proposal on Packaging and Packaging Waste Regulation (PPWR) to ensure packaging is designed for circularity, including through the promotion of recycled content uptake. At the…

European Bioplastics urges inclusion of biobased content in targets

European Bioplastics, 19 Apr 2023

The association requests that biobased materials count toward recycled content targets. They also seek a 10-year grace period for new, innovative packaging materials.
This would lower compliance costs and give the industry more time to develop infrastructure.
Fossil fuel companies would lose market dominance as bio-based materials gain competitive regulatory advantages.

Consultation response

Visita, 14 Apr 2023

Visita position Visita welcomes common rules for packaging and packaging waste in the EU as it is a basis for a well-functioning internal market as well as it protects an effective environmental and climate policy. Visita supports the proposal that the economic operators who put reusable packaging…

Consultation response

European Bioplastics, 5 Aug 2020

Attached is feedback submitted on behalf of European Bioplastics. We believe that bioplastics are a major driver in the evolution of plastics and that they contribute significantly to a more sustainable society. Our mission is to advance the economic and regulatory framework in Europe to allow for…

Polish cosmetics industry seeks flexible design and digital labeling

Polski Związek Przemysłu Kosmetycznego, 24 Apr 2023

The Union wants to maintain the definition of contact-sensitive packaging for cosmetics. They request that recycled content targets apply to a company's total portfolio. The organization calls for digital labeling options and freedom in packaging shapes.
This allows brands to maintain unique packaging shapes while lowering compliance costs.
National authorities would lose the power to implement specific domestic sorting instructions.

European Panel Federation opposes recycled content for wood packaging

European Panel Federation, 21 Mar 2023

The federation opposes recycled content targets for lightweight wood packaging for food. They argue that plywood cannot technically be manufactured using recycled wood materials. They request that wood waste collection be mandated to support the board industry.
This would protect wood packaging manufacturers from being forced out of the market.
Energy recovery companies would lose access to wood waste diverted toward recycling.

Consultation response

Polski Związek Przemysłu Kosmetycznego, 6 Aug 2020

The cosmetics industry in Poland shares the European Commission views with regards to the impact of climate change by 2050. The Polish Union of the Cosmetics Industry welcomes the European Commission’s European Green Deal announcement and its goals. The Union considers the following elements are…

Consultation response

European Panel Federation, 3 Aug 2020

Please find here attached the contribution from the European Panel Federation.

Consultation response

International Paper, 21 Apr 2023

The virtues and value of corrugated cardboard packaging in two key statements EU corrugated leads the world in all-round performance. Fully recyclable and massively recycled in the EU today, corrugated packaging made from renewable resources is safe and sustainable, fit-for-purpose and already…

European e-pharmacies seek exemptions from strict packaging rules

European Association of E-Pharmacies, 21 Apr 2023

They request exemptions from space limits to maintain medicine safety standards. Mandatory reuse quotas must be based on proven carbon footprint reductions.
This prevents administrative burdens and preserves specific shipping safety requirements.
Environmental groups lose progress if shipping sectors are granted packaging exemptions.

Consultation response

ALDI Nord Holding Stiftung Co. KG, 20 Apr 2023

Our ambition in the ALDI Nord Group of Companies (ALDI Nord), one of the leading pan-European discount retailers, is to make sustainable products affordable. This includes initiatives to make all kinds of packaging reusable, recyclable and containing recycled content. 80% of ALDI Nords product…

Consultation response

Otto GmbH & Co. KGaA, 19 Apr 2023

Please find attached our position paper.

German confectionery industry calls for realistic EU packaging rules

Bundesverband der Deutschen Süßwarenindustrie, 30 Mar 2023

The industry demands investment in sorting infrastructure and exemptions for seasonal or gift packaging. They emphasize that food safety and hygiene must always take priority over reduction targets.
Flexible regulations would help companies avoid excessive administrative costs and maintain product variety.
Environmental goals are undermined by requests to delay design standards and exempt specific products.

CO2 Value Europe urges EU to defossilise packaging production

CO2 Value Europe AISBL, 29 Mar 2023

CO2 Value Europe requests new quotas for packaging to include alternative carbon feedstocks. They want legislation to include defossilisation targets and recognize carbon capture and utilization.
These changes would create market demand and legal recognition for CCU technologies.
Fossil fuel suppliers lose market share as packaging shifts to non-fossil carbon.

Ecopreneur.eu Urges EU to Maintain High Packaging Waste Ambition

Ecopreneur.eu, 18 Dec 2022

The group urges legislators to preserve ambitious targets and prioritize reuse over recycling. They also call for phasing out hazardous substances and ensuring all companies comply.
Sustainable businesses would benefit from new market opportunities and rewards for circular innovations.
Companies failing to comply will face higher recycling fees and environmental taxes.

Consultation response

Bundesverband der Deutschen Süßwarenindustrie, 30 Jul 2020

BDSI welcomes the opportunity to contribute to the consultation on the Review of the requirements for packaging and other measures to prevent packaging waste. The BDSI represents the economic interests of over 200 mostly medium-sized German confectionery companies. The German confectionery…

Portuguese NGO ZERO calls for more ambitious packaging targets

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 24 Apr 2023

ZERO demands increasing the waste prevention target to 15% and setting higher reuse goals. They request mandatory inclusion of glass in deposit return systems and stricter chemical safety rules.
Stronger environmental rules allow the group to push for stricter national conservation laws.
Packaging manufacturers and retailers face higher operational costs from stricter reuse requirements.

Consultation response

Ball Beverage Packaging Europe Limited, 24 Apr 2023

Ball Beverage Packaging welcomes the European Commission's Packaging and Packaging Waste Regulation (PPWR) published on November 30th 2022 and recognizes the effort to help make Europe less dependent on primary resources and external suppliers and put the packaging sector on track for climate…

Consultation response

The European Federation of Corrugated Board Manufacturers, 21 Apr 2023

FEFCO acknowledges the European Commissions proposal for the Packaging and Packaging Waste Regulation. We support maintain the internal market legal basis and introducing harmonised labelling requirements for packaging across EU. Additionally, FEFCO welcomes the packaging minimisation measures and…

Consultation response

TotalEnergies Corbion B.V., 20 Apr 2023

TotalEnergies Corbion supports the overall objective of recycled content targets in packaging. However, the proposed Regulation despite the initial announcements fails to tackle the most urgent matter of reducing GHG emission in the packaging (and material) sector, which is relevant if the EU wants…

Consultation response

Kaneka Europe Holding Company N.V., 28 Mar 2023

In respect to the revision of the packaging and packaging waste directive, we are delighted to see the proposal of the EU Commission to regulate compostable packagings across Europe, according to well-defined criteria to ensure the environmental benefits of these innovative materials. We are…

Consultation response

JDE Peet's, 2 Mar 2023

JDE Peet's is committed to the continued reduction of packaging waste and the promotion of a circular economy. In line with the circular economy objectives, we are designing 100% of our packaging to be reusable, recyclable or compostable by 2030. To further bolster circularity, significant…

Consultation response

Braskem Netherlands, 7 Feb 2023

Almost 40% of European plastics consumption comes from packaging, but currently, more than 98% of the European plastics production derives from fossil fuels. Braskem therefore calls on the European Parliament and Member States to include biobased content targets for plastics, alongside recycled…

Consultation response

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 6 Aug 2020

Europe’s action on reducing natural resource consumption is long overdue, and the huge amounts of packaging waste being produced every year is a clear sign that we have failed to implement the policies that will deliver on making the waste hierarchy a reality. Focusing on recycling will not do the…

Consultation response

The European Federation of Corrugated Board Manufacturers, 17 Jul 2020

This is a joint feedback from several associations in the paper & board value chain: CITPA, CEPI, ACE, ECMA, EMPHA, FEFCO, PRO CARTON. The paper & board value chain supports the Commission's ambition to contribute to the circular economy through the review of the requirements for packaging and…

Consultation response

Extended Producer Responsibility Alliance, 23 Apr 2023

EXPRA POSITION PAPER ON PPWR The Extended Producer Responsibility Alliance (EXPRA), representing 32 non-profit national EPR organizations across Europe and beyond, supports the Commissions proposal to review the current packaging and packaging waste directive (PPWD). We believe that it is of…

Consultation response

Minderoo Foundation Limited ATF The Minderoo Foundation Trust, 21 Apr 2023

Minderoo welcomes the Commission's proposal for a revision of EU legislation for regulation on Packaging and Packaging Waste (PPWR proposal), to prevent negative environmental impacts of packaging and bolster reuse and recycling. The European Union has shown a commitment to transitioning towards a…

Novamont calls for greater role for compostable packaging in PPWR

Novamont SpA, 21 Apr 2023

Novamont requests a 60% minimum bio-based content for compostable packaging and expanded mandatory composting lists. They also seek a five-year derogation for innovative polymers to establish sorting technologies.
These changes would protect Novamont's competitive position and increase the market for bioplastics.
Conventional plastic recyclers face risks from compostable materials potentially contaminating their waste streams.

Consultation response

Extended Producer Responsibility Alliance, 6 Aug 2020

The Extended Producer Responsibility Alliance (EXPRA), representing industry-owned, non-profit packaging and packaging waste recovery and recycling organisations, welcomes the opportunity to provide feedback on packaging waste prevention and essential requirements as part of the EU consultation on…

Consultation response

Novamont SpA, 31 Jul 2020

NOVAMONT FEEDBACK ON THE CONSULTATION ON THE REVISION ON ESSENTIAL REQUIREMENTES: FOCUS ON BIODEGRADABLE & COMPOSTABLE PLASTICS PACKAGING The review of the Packaging and Packaging Waste Directive (PPWD) in 2018 required the European Commission to examine the feasibility of reinforcing the…

Consultation response

BGP Products Operations GmbH – a Viatris Company, 24 Apr 2023

Viatris is a global healthcare company, supplying 36.8 billion doses of medicine annually in Europe. Our portfolio comprises more than 1,400 approved molecules across a wide range of therapeutic areas, spanning generics, complex generics, and branded medicines. We work diligently to reduce our…

Consultation response

Delivery Platforms Europe, 24 Apr 2023

Delivery Platforms Europe represents the leading delivery platforms in Europe. We aim to work with policymakers to develop policy solutions that benefit the sustainable development of the platform economy in Europe including ensuring a better use of packaging and reducing waste. We support the…

Consultation response

Andreas STIHL AG & Co. KG, 17 Feb 2023

As a manufacturer of forestry and gardening machines we support the replacement of the Packaging and Packaging Waste Directive by a regulation with binding rules in all MS (member states of the EU). Currently, more and more MS have enacted binding, country-specific and complex legislation (e.g.…

Paint industry urges EU to protect functional packaging

European Council of the Paint, Printing Ink and Artists' Colours Industry, 6 Aug 2020

CEPE requests that new rules safeguard packaging functions like product protection. They recommend using existing chemical regulations and qualitative definitions for recyclability.
Qualitative standards would protect innovation and prevent overly restrictive design mandates.
Sustainability goals are harmed if inadequate packaging causes product spoilage and resource waste.

HCWH Europe urges tougher EU rules on healthcare packaging waste

Health Care Without Harm Europe, 24 Apr 2023

The organization proposes a 15% waste prevention target and including medical device packaging. They also want to eliminate hazardous chemicals and strengthen producer responsibility.
Reducing waste would lower high financial and environmental costs for hospitals.
Producers would bear the full financial burden of packaging recovery and treatment.

Consultation response

GroentenFruit Huis, 21 Apr 2023

Fresh Produce Centre is an industry body with members who are important players in the production, producer organisations trade, export of fruit and vegetables. They supply a complete assortment to the European retailers and food service, EU consumers. We represent 80% of the Dutch business, we…

Consultation response

European Fruit Juice Association, 21 Apr 2023

AIJN The European Fruit Juice Association, thanks the EU Commission for the opportunity to react to its Proposal on a Packaging and Packaging Waste Regulation. Since 1962, AIJN represents manufacturers and processors of fruit juices, fruit nectars and other similar products falling under the EU…

Consultation response

Tobacco Europe AISBL, 21 Apr 2023

Tobacco Europe welcomes the opportunity to provide feedback to the review of rules on reducing packaging waste. Tobacco Europe is fully committed to the EU Green Deal objectives and the respective efforts striving for the reduction of waste in general and packaging waste in particular. We welcome…

Consultation response

Danish Dairy Board Brussels s.a., 21 Apr 2023

Attached DDBB statement on the proposal for a regulation on packaging and packaging waste.

French waste association urges industry role in EU packaging rules

Fédération Nationale des Activités de Dépollution et de l'Environnement, 19 Apr 2023

FNADE requests that the recycling industry helps draft technical delegated acts. They suggest adding mandatory collection targets and minimum recycled content for all materials. The association also seeks clearer definitions to prevent market volatility and uncertainty.
Greater certainty would protect business plans and prevent disruption of the recycling market.
Paper, cardboard, and metal packaging manufacturers would face faster mandatory recycled content requirements.

Consultation response

Verband der deutschen Lack- und Druckfarbenindustrie e. V., 5 Aug 2020

Bitte beachten Sie die angehängte Datei.

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 5 Aug 2020

Feedback on the review of the requirements for packaging and other measures to prevent packaging waste FNADE, the French association for waste management, welcomes the European Commission's initiative to reduce and better recycle packaging waste. First of all, this initiative will have to ensure…

Consultation response

Health Care Without Harm Europe, 4 Aug 2020

Health Care Without Harm (HCWH) Europe welcomes the opportunity to provide feedback on packaging requirements and other measures to prevent packaging waste. Our detailed contribution can be found in the PDF attached.

Consultation response

TOMRA Systems ASA, 24 Apr 2023

TOMRA, the leading solutions provider for the collection and sorting of waste for reuse and recycling, welcomes the Packaging and Packaging Waste Regulation proposal by the European Commission, which sets ambitious but achievable goals during a timeframe to enable investment. Harmonisation across…

Consultation response

International Flavors & Fragrances, 24 Apr 2023

IFF, an innovator in sustainable solutions in the food, beverage, health, biosciences and fragrances industries welcomes the publication of the proposal on PPWR and its ambition to make packaging more sustainable by reducing overpackaging, and increasing recycling rates and re-use. IFF calls on the…

Consultation response

Amcor, 24 Apr 2023

Please find attached our reply to the consultation.

Consultation response

Steel for Packaging Europe, 24 Apr 2023

APEAL, representing the steel for packaging sector, fully supports Commissions objective that all packaging on the EU market be reusable or recyclable in an economically viable way by 2030, as stipulated by the Green Deal and the Circular Economy Action Plan (CEAP) 2.0. Our sector welcomes the…

Consultation response

DIE PAPIERINDUSTRIE e.V., 24 Apr 2023

Der Verband DIE PAPIERINDUSTRIE e. V. und seine Mitglieder unterstützen ausdrücklich das Bestreben der EU-Kommission, mit einer Verordnung über Verpackungen und Verpackungsabfälle zu einer klimaneutralen Kreislaufwirtschaft beizutragen. Zugleich besteht an einigen Stellen elementarer…

Consultation response

Reusable Packaging Europe, 6 Aug 2020

PLEASE FIND ATTACHED OUR FULL POSITION Reusable Packaging Europe (RPE) is the European association which represents the interests of companies active in the area of reusable transport packaging systems, primarily in the pooling of Reusable Packaging Containers (RPCs). Inspired by the EU Green…

Consultation response

European Organisation of the Sawmill industry, 5 Aug 2020

The natural qualities of timber make wooden packaging an environmentally friendly packaging solution. Wood pallets and wood-based packaging are almost completely made out of wood. And wood’s strong environmental credentials have been captured in various Life-Cycle Assessment studies and…

Consultation response

Steel for Packaging Europe, 24 Jul 2020

“APEAL, the Association of European Producers of Steel for Packaging, welcomes packaging waste prevention measures that take into account the wider scope of a circular and resource efficient economy, ensuring a net decrease in carbon emissions. One needs to look at design for high-quality…

Consultation response

Amcor, 9 Jul 2020

Amcor is a global leader in developing and producing high-quality, responsible packaging for a variety of food, beverage, pharmaceutical, medical-device, home- and personal-care and other products. We work with leading companies around the world to protect their products and the people who rely on…

WECF calls for stricter toxic chemical rules in packaging

Women Engage for a Common Future, 24 Apr 2023

The group demands stricter regulations on harmful chemicals to protect health and the environment. They seek gender-sensitive risk assessments and the total avoidance of hazardous substances in packaging materials.
This would help the organization achieve its core goal of ensuring a toxic-free future.
Chemical and packaging companies would face much tougher restrictions on their production processes.

Consultation response

Associazione delle Imprese del farmaco, 24 Apr 2023

Farmindustria, the Italian Association of Pharmaceutical Companies representing about 200 member companies operating in Italy, welcomes the opportunity to share our feedback on the Commission Proposal on the Packaging and Packaging Waste Regulation. Farmindustria supports the European Green Deal…

Consultation response

FRUCOM - European Federation of the Trade in Dried Fruit, Edible Nuts, Processed Fruit & Vegetables, Processed Fishery Products, Spices and Honey, 24 Apr 2023

FRUCOM represents European Union importers, and growers, processors, and traders, of edible nuts, dried and processed fruit and vegetables, and processed fish and seafood products. FRUCOM welcomes the publication of the Proposed Regulation on packaging and packaging waste, amending Regulation (EU)…

Consultation response

FLexible Packaging Initiative, 20 Apr 2023

The Flexible Packaging Initiatives POSITION PAPER ON PPWR is in attachment.

Consultation response

Comité Colbert, 19 Apr 2023

Please find in attachment the collective contribution of Comité Colbert, Unifab and Febea on certain aspects of the proposal.

Consultation response

ALPLA Werke Alwin Lehner GmbH Co KG, 22 Mar 2023

The ALPLA Group, with its 190 locations and 23,300 employees in 46 countries worldwide, is one of the leading global plastic converters and a growing recycler. We develop and produce innovative rigid plastic packaging solutions, while ensuring that our products become lighter, more durable and by…

Consultation response

European Portable Battery Association, 24 Apr 2023

See enclosed our position.

Consultation response

IK Industrievereinigung Kunststoffverpackungen e.V., 24 Apr 2023

Artikel 7 (Minimum recycled content in plastic packaging): Ten German and international business associations from the entire value chain as well as the Wuppertal Institute for Climate, Environment and Energy support a more flexible use of recyclates without weakening the intended security of…

Consultation response

Allianz Verpackung und Umwelt e.V., 21 Apr 2023

AGVU Position on the draft PPWR Despite being a very positive and constructive step towards the EU circular packaging economy, the EU Commissions proposal also contains problematic aspects: key decisions will be moved to the level of delegated and implementing acts. This not only effectively…

Consultation response

Assomela, 20 Apr 2023

Assomela, the Italian association of apple producers, supports the efforts to harmonize the packaging market in Europe and supports the will to increase sustainable packaging solutions. The Italian apples sector is highly concerned about the discriminative targeting of the fresh produce sector in…

Consultation response

European Carton Makers Association, 18 Apr 2023

Please find attached the feedback from the European Carton Makers Association (ECMA)

French waste operator Syctom opposes mandatory deposit return schemes

Syctom Agence métropolitaine des déchets ménagers, 17 Apr 2023

Syctom requests an explicit ban on non-recyclable packaging and more flexibility for national collection systems. They propose making deposit return schemes optional and lowering the exemption collection target to 80%.
This prevents disruption to current public sorting operations and avoids the costs of implementing new systems.
Environmental goals may suffer as lowering collection targets reduces the pressure to maximize packaging recovery.

Consultation response

Federación española de Industrias de Alimentación y Bebidas, 14 Apr 2023

Se adjunta documento con la posición de la Federación Española de Industrias de Alimentación y Bebidas a la propuesta de Reglamento de envases y residuos de envase. Un cordial saludo.

Consultation response

European Carton Makers Association, 28 Jul 2020

Please see attached document for full feedback from ECMA

Consultation response

Syctom Agence métropolitaine des déchets ménagers, 21 Jul 2020

Le Syctom, Service public de traitement des déchets pour 85 communes d'Ile de France dont Paris (6 millions d'habitants) soutient sans réserve les mesures proposées. Les coûts de traitement des déchets non recyclables ne peuvent augmenter indéfiniment sans peser sur les finances des collectivités…

Consultation response

OceanCare, 24 Apr 2023

OceanCare welcomes the Commissions proposal for the revision of EU rules on packaging and packaging waste. The proposed conversion from a Directive to a Regulation is a welcome signal that the EU is willing to streamline and strengthen its actions on packaging and packaging waste. In that regard,…

Bioenergy Association warns against favoring reuse over recyclable packaging

Bioenergia ry - Bioenergy Association of Finland, 24 Apr 2023

Reuse and recycling should be treated as complementary solutions. The association warns that favoring reusable packaging risks promoting fossil-based materials over bio-based alternatives. They request flexibility for Member States to evaluate overall environmental impacts.
This protects the supply of forestry residues used for carbon-negative energy systems.
Fossil-based material cycles lose the advantage they might gain from strict reuse mandates.

Consultation response

4evergreen, 24 Apr 2023

4evergreen is an alliance of 100 manufacturers, designers, brand owners, researchers and recyclers who want to contribute to a climate neutral society by perfecting the circularity and sustainability of fibre-based packaging. The goal is to reach a 90% recycling rate for fibre-based packaging by…

Consultation response

European Recycling Platform SAS, 21 Apr 2023

European Recycling Platform (ERP) appreciates the opportunity to provide feedback on the European Commission's proposal for a new Regulation on Packaging and Packaging Waste (PPWR). We support the proposal's ambition to further harmonise the European internal market and to create a level playing…

Consultation response

Fibre Packaging Europe, 12 Apr 2023

Fibre Packaging Europe (FPE) acknowledges the European Commissions proposal for a Packaging and Packaging Waste Regulation and looks forward to supporting an evidence-based regulatory approach during the next stages of the legislative process. FPE recognises that recyclable and reusable options are…

European potato trade group urges exemptions from packaging bans

European Potato Trade Association, 28 Mar 2023

Europatat requests a science-based approach to packaging restrictions. They specifically oppose the ban on small-format packaging for fresh potatoes. They also want clear timelines for food safety exemptions.
Harmonized rules would prevent market fragmentation and avoid higher costs for operators.
Consumers face increased food waste and health risks if produce protection decreases.

Consultation response

Brown-Forman Netherlands BV, 9 Feb 2023

Brown-Forman is a global spirits producer, and a proud member of SpiritsEurope. We support legislation via a Regulation, to protect the Single Market. Additional national requirements should be strictly limited. We believe the spirits industrys greatest opportunity to contribute to…

Consultation response

CITEO, 6 Aug 2020

Citeo strongly welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to review requirements for packaging and other measures to prevent packaging waste. Citeo shares the Commission’s findings on the need for clearer and more specific requirements on…

Consultation response

Arnika, z.s., 24 Apr 2023

Arnika's mission is to promote environmental health, prevent toxic pollution within the European and global context. Arnika aims to eliminate the use and releases of POPs and other toxic chemicals in the Czech Republic as well as globally. Based on our experience with the contamination of consumer…

Consultation response

innocent drinks, 24 Apr 2023

The attached file provides innocent drinks submission to the PPWR public consultation.

Consultation response

European Power Tool Association, 24 Apr 2023

European Power Tool Association (EPTA) statement on the European Commissions proposal for a Regulation on packaging and packaging waste EPTA, the European Power Tool Association, represents 25 European power tool manufacturers and 90% of all corded and cordless power tools sold in Europe. Power…

Consultation response

CEPI Eurokraft, 21 Apr 2023

CEPI Eurokraft, the European Association for Producers of Sack Kraft Paper for the Paper Sack Industry and Kraft Paper for the Packaging Industry, acknowledges the European Commissions proposal for the Packaging and Packaging Waste Regulation. However, the Regulation should aim to make packaging…

Consultation response

European Cultural and Creative Industries Alliance, 21 Apr 2023

The European Cultural and Creative Industries Alliance (ECCIA) supports the European Commissions Green Deal and its global ambition towards a more sustainable and circular economy. We recognize that minimizing the environmental impact of packaging and packaging waste is one of the key alleys for…

Consultation response

MM Kotkamills Oy, 6 Aug 2020

We thank for the opportunity to give our feedback on the Roadmap on Review of the requirements for packaging and other measures to prevent packaging waste. Kotkamills is a Finnish forest indsutry company. We also manufacture packaging boards for flexible boxboards as well as for food packaging. We…

Consultation response

Asociación Aguas Minerales de España, 24 Apr 2023

Comentarios de la Asociación de Aguas Minerales de España (ANEABE) a la consulta pública de la Comisión Europea sobre la propuesta de Reglamento sobre envases y residuos de envases.

Consultation response

TomatoEurope Processors Association, 24 Apr 2023

Please find our position paper enclosed.

Consultation response

Bundesverband Großhandel, Außenhandel, Dienstleistungen e. V., 24 Apr 2023

Dear Sir or Madam, Please find attached the response of the Federation of German Wholesale, Foreign Trade and Services (BGA).

Consultation response

FruitVegetablesEUROPE, 24 Apr 2023

FruitVegetablesEUROPE and its members are committed to achieve the EU's climate neutrality target by 2050, advocating that the new EU packaging law should maintain the competitiveness of the European agri-food market with science-based solutions and an economic and social impact assessment with…

European Safety Federation seeks safety-specific rules for protective packaging

European Safety Federation, 24 Apr 2023

The federation wants safety equipment packaging classified as contact sensitive. They also request harmonized EU labels and longer transition periods.
This would reduce regulatory costs and prevent the loss of product stock.
National governments lose the power to set distinct environmental labeling systems.

Consultation response

Verband Metallverpackungen e. V., 21 Apr 2023

Verband Metallverpackungen e.V. (VMV) is the German Metal Packaging Association representing the manufacturers of rigid metal packaging. The product range represented includes, for example, food cans and closures, promotional packaging, aerosol cans, tinplate packaging for paints and coatings and…

Consultation response

Mondi Group, 19 Apr 2023

Mondi supports Commission proposal, but it still requires key improvements to reach full potential Mondi is a global manufacturer of a wide range of fibre-based and flexible packaging solutions, employing approximately 21.000 colleagues globally. Improvements in recycling infrastructure The main…

Consultation response

European Snacks Association, 6 Apr 2023

The European Snacks Association asbl (ESA) is Europes only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers, as well as national trade organisations. Our members support the objectives of promoting a transition to a circular…

Consultation response

Citeo, 31 Mar 2023

Citeo, the French EPR organisation for households packaging and graphic paper, would like to share its analysis on the Packaging and Packaging Waste Regulation proposal, built together with Citeos experts on prevention, reuse, recyclability and environmental claims. We welcome the harmonisation…

Consultation response

Genossenschaft Deutscher Brunnen eG, 31 Mar 2023

Die deutschen Mineralbrunnen begrüßen, dass die Europäische Union eine Verbesserung der ökologischen Performance von Verpackungen anstrebt und hierzu eine umfassende Novellierung der Regulierung von Verpackungen und Verpackungsabfällen initiiert hat. Dabei wird auch die Umwandlung der aktuellen…

EGMF Urges Harmonised EU Rules for Packaging and Labelling

European Garden Machinery industry Federation, 30 Mar 2023

They request uniform labels and digital QR codes for disposal information. Companies should register for waste management in one country only. They also request a forty-eight-month implementation delay for the industry.
Standardisation would lower operational costs by ending the need for country-specific packaging.
End users could lose access to information if labels are omitted.

Consultation response

European Snacks Association, 5 Aug 2020

The European Snacks Association asbl (ESA) is Europe's only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers, as well as national trade organisations. ESA members are involved in the manufacture of potato crisps, corn…

Consultation response

Sappi Europe SA, 24 Apr 2023

Sappi, a leading provider of renewable fibre-based products, supports the goals of the Packaging and Packaging Waste Regulation (PPWR) proposal. However, we offer the following suggestions to improve the proposal: - We recommend that the proposal be evaluated against the Innovation Principle to…

Consultation response

Društvo Ekologi brez meja, 24 Apr 2023

We welcome the Commissions proposed renovation of PPWD with open hands, especially the explicit reuse and prevention targets that are so rarely proposed yet key for a successful move towards more circular packaging. They should be higher though, as for example a 5 % decrease will only undo a few…

Consultation response

Food Packaging Forum Foundation, 24 Apr 2023

The proposed Packaging and Packaging Waste Regulation offers an important opportunity for implementing the EUs ambitious goals as laid out in its Farm To Fork Startegy (F2F), Chemical Strategy for Sustainability (CSS) and its Circular Economy Action Plan (CEAP) regarding the reduction of adverse…

Consultation response

PRO MEHRWEG - Verband zur Förderung von Mehrwegverpackungen e.V., 24 Apr 2023

The Reuse Alliance (Mehrweg-Allianz) is a coalition of Deutsche Umwelthilfe e.V. (DUH), the Association of German Beverage Wholesalers (BV GFGH), Private Breweries in Germany (Private Brauereien Deutschland), the Association of German Retail of Beverages(VDGE), Foundation for Reuse (SIM) and the…

Consultation response

Health and Environment Justice Support, 24 Apr 2023

This is a submission on behalf of the German NGO Alliance Exit Plastik. Members of Exit Plastik, who developed this paper are: a tip: tap e.V., Bund für Umwelt und Naturschutz Deutschland e.V., Forum Umwelt und Entwicklung, Greenpeace e.V., HEJSupport e.V., Küste gegen Plastik e.V., Surfrider…

Consultation response

Styrenics Circular Solutions, 24 Apr 2023

SCS fully supports the objectives of the PPWR proposal, including preventing or reducing adverse impacts on the environment, and in particular increasing recycling and the use of recycled materials while reducing other forms of recovery and disposal after all options to prevent waste have been…

Consultation response

Energy Drinks Europe, 24 Apr 2023

As per the attached file.

Consultation response

FEDERACIÓN ESPAÑOLA DE ASOCIACIONES DE PRODUCTORES EXPORTADORES DE FRUTAS, HORTALIZAS, FLORES Y PLANTAS VIVAS, 24 Apr 2023

Adjunto se remiten las observaciones de FEPEX a la consulta de la Comisión relativa a la propuesta de Reglamento del Parlamento Europeo y del Consejo sobre los envases y residuos de envases.

Consultation response

Foreign Investors Council, 24 Apr 2023

The Foreign Investors Council position document on the European Commissions proposal for a Regulation on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC The Foreign Investors Council (FIC) is the association of the most…

Consultation response

ProFoodItalia, 24 Apr 2023

ProFood condivide lobiettivo di migliorare la sostenibilità dei sistemi di confezionamento, distribuzione ed utilizzo degli alimenti, in cui il packaging gioca un ruolo fondamentale. ProFood condivide limpegno verso leliminazione degli sprechi, lutilizzo di over packaging e la dispersione di…

Consultation response

ASSUC- European Association of Sugar Traders, 24 Apr 2023

ASSUC is the voice of European sugar traders, representing over sixty sugar trading companies across Europe through its membership. ASSUC strongly calls on the European Commission to remove sugar from the list of products under point four Annex V, banning single-use portion packaging for…

Consultation response

PRO MEHRWEG - Verband zur Förderung von Mehrwegverpackungen e.V., 21 Apr 2023

Pro Mehrweg e.V. (Association Pro Reuse) consists of and represents associations and companies of the German beverage industry, beverage wholesalers and retailers, their supplier industries, as well as environmental associations and individuals. The association acts as a platform for all those who…

Consultation response

Bundesverband E-Commerce und Versandhandel Deutschland e.V., 21 Apr 2023

Der bevh begrüßt das Vorhaben der EU, die Regelungen zu Verpackungen EU-weit zu vereinheitlichen und damit den europäischen Binnenmarkt zu fördern, wobei eine weitere Vereinheitlichung insbesondere auch bezüglich der Registrierungsanforderungen in den einzelnen Mitgliedsstaaten unbedingt notwendig…

Consultation response

European Coffee Federation, 21 Apr 2023

The European Coffee Federation (ECF) welcomes the European Commissions proposal to update the EU legislative framework for packaging and packaging waste (PPWR) by giving Member States and businesses adequate support to achieve waste reduction targets to diminish the environmental impact of…

Consultation response

COSMED, 21 Apr 2023

COSMED, the French cosmetic association for SMEs, thanks the Commission for the possibility to comment the proposal for a regulation on packaging and packaging waste. First of all, COSMED support this proposal for a regulation on packaging and packaging waste to harmonize rules in European Union…

Consultation response

European Vending & Coffee Service Association, 19 Apr 2023

Please find attached the position of the European Vending & Coffee Service Association (EVA) on the proposal for a Packaging & Packaging Waste Regulation (PPWR). Please also fine in the link below a joint letter signed by more than 120 European Associations calling for the internal market legal…

Consultation response

Li Service, 10 Mar 2023

Our comments and proposals are in the attached document

Consultation response

European Compost Network ECN e.V., 13 Feb 2023

The European Compost Network (ECN) welcomes the opportunity to comment on the Commissions public consultation on the revision of the packaging and packaging waste directive. First of all, the ECN acknowledges the efforts of the Commission in addressing the increase of packaging and packaging waste…

Consultation response

EUROPEAN CHEMICAL REGIONS NETWORK, 30 Jan 2023

Ensure that circular business models are incentivized considering their environmental benefits and facilitate a secure and high-quality supply of secondary raw materials by: - Strengthening the role of the chemical sector in the processing of waste and the high-quality use of renewable raw…

Consultation response

Intergraf European Federation for Print and Digital Communication, 5 Aug 2020

Intergraf, the European federation for the printing industry, welcomes the European Commission’s review of the essential requirements of packaging. A key part of the value chain and the circular economy, the printing industry brings together the materials, ink, and packaging design which make the…

Consultation response

Društvo Ekologi brez meja, 3 Aug 2020

At EBM we welcome the goals  of the review and will stress a few points. One of its specific objectives is to ensure a reduction in packaging waste generation. Waste prevention has been a priority since the introduction of the waste hierarchy in the WFD, yet it never received much attention — and…

Consultation response

Suomen Biokierto ja Biokaasu ry, 24 Apr 2023

The Finnish Biocycle and Biogas Association promotes nutrient recycling and the use and development of biogas technology and its knowledge in the society. We welcome the Circular Economy Action Plan and the aim to contribute to the circular economy through the review of the requirements for…

Consultation response

Bundesverband Holzpackmittel, Paletten, Exportverpackung (HPE) e.V., 24 Apr 2023

Holzpackmittel und -paletten sind ein unverzichtbarer Bestandteil aller Lieferketten, da sie als tertiäre Transportverpackungen für das Funktionieren des Binnen- und Weltmarktes sowie für die Versorgung der Menschen mit Lebensmitteln, Arzneimitteln und Gütern des täglichen Bedarfs sowie für die…

Consultation response

Asociación multisectorial de empresas de la electrónica, las tecnologías de la información y la comunicación de las telecomunicaciones y de los contenidos digitales, 24 Apr 2023

AMETIC welcomes the harmonization efforts in the Proposal Regulation for packaging and packaging waste and a more circular economy. However, some measures in the PPWR proposal raise concerns regarding their technical feasibility and practicality. A well-designed regulation is key to support the…

Consultation response

European Domestic Glass, 24 Apr 2023

Please see attached contribution

Consultation response

SERRED, 24 Apr 2023

SERRED, the European association representing, defending and promoting the interests of industrial packaging reconditioners, welcomes the European Commissions ambitions to reduce packaging waste via its proposal for a Packaging and Packaging Waste Regulation (PPWR). We agree with the proposals…

Consultation response

Kimberly-Clark Corporation, 24 Apr 2023

Kimberly-Clark is a global leader in the development and production of Absorbent Hygiene Products (AHPs), including baby nappies, period products, adult diapers, and tissue paper for private and professional use. As a user of packaging for our products, we fully support the PPWR proposals goal to…

Consultation response

Federation of The European Cookware, Cutlery and Housewares Industries, 24 Apr 2023

The Federation of European Manufacturers of Cookware and Cutlery (FEC) supports the Packaging and Packaging Waste Regulation (PPWR) proposal, which aims to ensure the efficient functioning of the internal market for packaged goods while reducing the impact of packaging waste on the environment and…

Consultation response

Polska Izba Przemysłu Chemicznego, 24 Apr 2023

Stanowisko PIPC znajduje się w załączonym pliku.

Consultation response

Federation Europeenne Des Emballeurs Et Distributeurs De Miel - European Federation of Honey Packers and Distributors, 24 Apr 2023

F.E.E.D.M. Statement EU proposal for a revision of the EU legislation on Packaging and Packaging Waste F.E.E.D.M. welcomes this public consultation and the opportunity to provide comments on the Commissions proposal for a revision of the EU legislation on Packaging and Packaging Waste. F.E.E.D.M.…

Consultation response

PLASTALLIANCE "The European Plastics Alliance", 23 Apr 2023

Dear Sir or Madam, Please find attached the position of Alliance Plasturgie et Composites du Futur PLASTALLIANCE concerning the PPWR. Yours sincerely Joseph Tayefeh General Secretary

Consultation response

Asociación Nacional de Fabricantes de Zumos y Gazpachos, 23 Apr 2023

The National Association of Juice and Gazpacho Manufacturers - Zumos y Gazpachos de España - is the business organization that integrates the main producers of fruit juices and gazpachos of our country representing them and being their voice. The fruit juices and gazpachos sector share the…

Consultation response

Associazione Nazionale Industrie Metalli non Ferrosi, 22 Apr 2023

Assomet welcomes the objectives of the proposal for a Regulation on Packaging and Packaging Waste (PPWR) of increasing the sustainability and circularity of packing products. As a permanent material, aluminium may be a key contributor to these objectives based on the material properties and the…

Consultation response

Deutscher Brauer-Bund e.V., 21 Apr 2023

Sehr geehrte Damen und Herren, in Deutschland werden ca. 80 Prozent des Bieres in Mehrweggetränkeverpackungen verkauft. Bezieht man in diese Betrachtung Fassbier mit ein, erhöht sich dieser Wert nochmals beträchtlich. Es handelt sich damit um das größte und erfolgreichste Mehrwegsystem in Europa.…

Consultation response

Fédération Européenne des Recycleurs de Verre, 20 Apr 2023

As European federation of glass recyclers, we support the ambitious initiative of the Commission to revise the Packaging and Packaging Waste Directive and to opt for a future Regulation. In the document annexed, please find specific comments related to the specific properties of glass and to our…

Consultation response

European Aluminium Foil Association, 20 Apr 2023

The European Aluminium Foil Association (EAFA) welcomes the Commission proposal for a Regulation on Packaging and Packaging Waste (PPWR) repealing Directive 94/62/EC. We welcome the retention of the internal market legal basis (Article 114 TFEU) and the choice of a Regulation as the legal…

Consultation response

Groupement Européen des Producteurs de Champignons, 19 Apr 2023

The GEPC, European mushrooms growers' group, representing 90% of the European production of cultivated mushrooms, would like to pinpoint the difficulty to comply with the draft regulation proposal regarding the measure of restriction of use of packaging for single use in the fresh fruit an…

Consultation response

Mehrwegverband Deutschland e.V., 6 Apr 2023

The German Association for Reusable Packaging (Mehrwegverband Deutschland e.V.) is non-profit organisation founded in 2022 and consists of 70 members, mainly companies and organisations that - are system operators of reusable packaging solutions for food, E-commerce, take-away or body- and homecare…

Consultation response

European Parquet Federation, 30 Mar 2023

FEP the European Parquet Federation is welcoming the European Commission proposal to revise the Packaging and Packaging Waste Directive, and the possibility to comment it. FEP is viewing this revision of the Packaging and Packaging Waste Directive as a unique opportunity to set common requirements…

Consultation response

Danish Brewers' Association, 27 Mar 2023

Please find enclosed a joint statement by the Nordic Brewery Associations concerning the Commission's proposal for a regulation on packaging and packaging waste.

Consultation response

bvse-Bundesverband Sekundärrohstoffe und Entsorgung e.V., 14 Mar 2023

bvse e.V. (Federal Association for Secondary Raw Materials and Waste Disposal) comments on the European Commission's proposal for a Regulation on packaging and packaging waste - COM (2022) 677 final (see attachement).

Consultation response

European Aerosol Federation, 10 Mar 2023

All aerosol dispensers independently of the container material should be covered by the same legal provisions. In the Annex II Table 1, the format aerosols is correctly included in the categories No 5 Metal / Steel and No 7 Metal / Aluminium. However the format aerosols is missing in the categories…

Consultation response

Fachverband der Chemischen Industrie Österreichs, 6 Aug 2020

FCIO welcomes the European Commission’s European Green Deal and supports the overarching goals of the European Union to become CO2 neutral by 2050. We consider the following principles as critical elements for the discussion on essential requirements for packaging: - The initiative should…

Consultation response

Bio-based and Biodegradable Industries Association, 4 Aug 2020

BBIA represents producers of compostable packaging sold, produced and distributed in the UK. We welcome the revision of the Packaging and Packaging Waste Directive with a view to reducing packaging waste. We suggest the guidelines adopted by WRAP in the UK (see…

Consultation response

VÖA - Vereinigung öffentlicher Abfallwirtschaftsbetriebe, 24 Apr 2023

The European Commission's goal of reducing packaging and packaging waste is welcomed by the VOA - Association of Public Waste Management Companies. It is questionable whether a regulation is an appropriate instrument to achieve the desired goals. From the waste management sector's point of view,…

Consultation response

Afaïa, 24 Apr 2023

Représentant plus dune centaine de metteurs en marché de matières fertilisantes et intrants innovants des cultures végétales durables, AFAÏA est le syndicat professionnel français des acteurs de la filière des supports de culture, paillages, amendements organiques, engrais organiques et…

Consultation response

ASSOCIATION DE LA TRANSFORMATION LATIERE, 24 Apr 2023

Lassociation de la transformation laitière ATLA représente les entreprises privées et coopératives de la transformation laitière française. Nous remercions la Commission Européenne pour cette opportunité de participer aux discussions sur cette proposition législative. Nous soutenons la volonté…

Consultation response

Deutscher Fruchthandelsverband e.V., 24 Apr 2023

Dear Sir or Madam, The German Fruit Trade Association represents the interests of companies from all trade sectors in the supply chains for fresh fruit and vegetables. We would like to thank you for the opportunity to comment on the draft regulation on packaging and packaging waste amending…

Consultation response

Union nationale interprofessionnelle des jus de fruits, 24 Apr 2023

Unijus, l'Union nationale interprofessionnelle des jus de fruits, soutient la position de son syndicat européen (AIJN) sur la PPWR, notamment sur les questions relatives au réemploi des emballages. Unijus représente les fabricants et les transformateurs français de jus et nectars de fruits, et…

Consultation response

EUROMCONTACT, 24 Apr 2023

EuromContact strongly supports the general objective for the revision of Directive 94/62/EC on Packaging and Packaging Waste to transform it into a regulation and tackle the environmental impact of packaging and packaging waste. The contact lens and lens care manufacturers have substantially…

Consultation response

Asociación española de industriales de plásticos, 24 Apr 2023

Please find attached the input of ANAIP (Spanish Association of Plastics Converters) to the EC proposal for the Packaging and Packaging Waste Regulation (PPWR).

Consultation response

COMITE DE LIAISON ENTREPRENEURIAT-AGRICULTURE-DEVELOPPEMENT, 24 Apr 2023

Please see document in attachment.

Consultation response

ASEGRE - Asociación de Empresas Gestoras de Residuos y Recursos Especiales, 24 Apr 2023

La Asociación de Empresas Gestoras de Residuos y Recursos Especiales ASEGRE como representativa de las actividades de gestión de residuos industriales en general y de residuos de envases industriales en particular, considera que el reglamento sobre envases y residuos de envases contempla que los…

Consultation response

European Specialist Sports Nutrition Alliance, 24 Apr 2023

This submission is made by the European Specialist Sports Nutrition Alliance (ESSNA), the trade association representing the voice of the active and sports nutrition sector in Europe. ESSNA and its members are already taking a leading role in accelerating the industry's transition to…

Consultation response

Asociación Española de Plásticos Biodegradables y Compostables, 24 Apr 2023

Adjuntamos los comentarios de ASOBIOCOM sobre sobre la propuesta de la Comisión de Reglamento de Envases y Residuos de Envases. Agradecemos la posibilidad de enviarlos. La Asociación Española de Plásticos Biodegradables y Compostables (ASOBIOCOM), tiene como objeto los plásticos biodegradables y…

Consultation response

Stichting Global Organization for PHA, 24 Apr 2023

The Global Organization for Polyhydroxyalkanoates (GO!PHA) is a non-profit science, advocacy, and networking platform promoting the proliferation of PHA biopolymers. PHA Biopolymers are renewable and biodegradable, home and industrially compostable, and an excellent replacement for many plastic…

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THE HELLENIC COSMETIC TOILETRY & PERFUMERY ASSOCIATION, 24 Apr 2023

The Hellenic Cosmetic, Toiletry and Perfumery Association is the Greek Association for Cosmetics, founded in 1964, with 72 members cosmetic producers and distributors, mainly SMEs and member of the Cosmetics Europe Association. We welcome the European Commissions proposal on the Packaging and…

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FEDERACIÓN ESPAÑOLA DEL ENVASE DE MADERA Y SUS COMPONENTES, 24 Apr 2023

FEDEMCO - La Federación Española del Envase de Madera y sus Componentes agradece la posibilidad de formular comentarios sobre la Propuesta de Reglamento del Parlamento Europeo y del Consejo sobre envases y residuos de envases, que modifica el Reglamento (UE) 2019/1020 y la Directiva (UE) 2019/904,…

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Verband der Wellpappenindustrie e.V., 24 Apr 2023

Sehr geehrte Damen und Herren, im Anhang finden Sie die Stellungnahme des Verbandes der Wellpappenindustrie. Zusammenfassen nehmen wir wie folgt Stellung: Wissenschaftliche Studien belegen, dass Mehrwegverpackungen im Transport und Versandhandel keine pauschalen ökologischen Vorteile gegenüber…

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The Japan Refrigeration and Air Conditioning Industry Association, 24 Apr 2023

The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) supports the Commission's proposal to repeal the existing EU Packaging Waste Directive and to renew the regulation on packaging and packaging waste as a legislative act. We believe that this revision will explicitly limit…

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, 24 Apr 2023

Madame, Monsieur, Nous vous prions de bien vouloir trouver en pièce jointe notre contribution au projet de règlement du Parlement Européen et du Conseil relatif aux emballages et aux déchets d'emballages. Nous vous en souhaitons bonne réception et restons à votre disposition pour tout complément…

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Industrieverband Papier- und Folienverpackung e.V., 24 Apr 2023

The Industry Association for Paper and Film Packaging (IPV) welcomes the overarching goals of the proposed regulation to contribute to a climate-neutral recycling economy with a regulation on packaging and packaging waste (PPWR). Please find attached our detailed feedback.

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FFI Fachverband Faltschachtel-Industrie e.V. (German Folding Carton Association), 24 Apr 2023

[siehe beigefügte Datei]

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Féderation INternationale des fabricants et transformateurs d'Adhésifs et Thermocollants sur papiers et autres supports, 23 Apr 2023

FINAT is the European association for the self-adhesive label industry. We welcome the opportunity to provide feedback on the European Commissions proposal to revise the Packaging and Packaging Waste Directive. FINAT represents over 500 member companies established in more than 50 countries,…

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The European Adhesive Tape Association, 23 Apr 2023

Afera, the European Adhesive Tape Association, welcomes the opportunity to provide feedback on the European Commissions proposal to revise the Packaging and Packaging Waste Directive. Afera counts 120 members in 20 countries covering the complete value chain of the adhesive tape industry and…

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European Beer Consumers Union, 23 Apr 2023

The European Beer Consumers Union is a non-political and non-religious organization that represents over 175,000 beer consumers across 18 organizations in 16 countries. The primary mission of EBCU is to advocate for a diverse beer sector, promote high-quality beer, and ensure consumers are…

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Industrieverband Garten e.V., 23 Apr 2023

Der Industrieverband Garten (IVG) e. V. begrüßt angesichts des hohen Verpackungsaufkommens und des damit verbundenen Ressourcenverbrauchs die Bestrebungen der Kommission, verpflichtende Vorgaben zur Verringerung von Abfällen aufzustellen. Auch die Absicht, eine vereinheitliche…

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, 21 Apr 2023

MIWA welcomes the European Commission's Packaging and Packaging Waste Regulation proposal and its aim to transition the packaging sector and waste towards a circular economy system. This position addresses key concerns and offers the following recommendations for co-legislators to consider during…

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International Release Liner Association, 21 Apr 2023

The attached file represents the views of the membership of the International Release Liner Association (IRLA) in respect of the consideration of release liners, particularly in the context industrial and professional uses, as non-packaging items and the Association calls upon the Commission,…

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Adolf Würth GmbH &Co. KG, 21 Apr 2023

Würth Einschätzung und Positionierung zum Vorschlag der Neuregelung der Verpackungsverordnung. Das wachsende Aufkommen von Verpackungsabfällen durch neue Konsumgewohnheiten sowie Hindernisse bei der Wiederverwendung von Verpackungen haben im Rahmen des Aktionsplans Kreislaufwirtschaft in der EU…

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Wirtschaftsverband Papierverarbeitung, 21 Apr 2023

Der Wirtschaftsverband Papierverarbeitung (WPV) e.V. begrüßt die übergeordneten Ziele des Verordnungsvorschlags, zu einer klimaneutralen Kreislaufwirtschaft beizutragen. Vorgaben zur Recyclingfähigkeit von Verpackungen sowie eine Verringerung des Materialeinsatzes in Verpackungen können positiv zur…

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Consorzio Italiano Compostatori, 21 Apr 2023

The Italian Compost and Biogas Association (CIC) welcomes the possibility to comment on the draft document revising the packaging and packaging waste directive released by the EU Commission on November 30th 2023. Since 30 years, CIC represents in Italy the industrial sector that recycles bio-waste…

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The International Confederation of Paper and Board Converters in Europe, 21 Apr 2023

The European Federation of Paper & Board Converters (CITPA) and its member associations welcome the Commissions ambition to contribute to a climate neutral circular economy through the proposal for a Packaging and Packaging Waste Regulation (PPWR). The new legislation should also ensure that…

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Ahlstrom Oyj, 21 Apr 2023

Ahlstrom welcomes the European Commissions ambitious proposal for a Regulation on Packaging and Packaging Waste. We wish to highlight further improvements to ensure all targets and measures are science based. Reuse and recyclability should be complementary alternatives to choose from to achieve the…

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Polish Association of Cosmetic and Detergent Industry, 20 Apr 2023

Rozporządzenie ws. opakowań i odpadów opakowaniowych (PPWR), którego propozycja została opublikowana przez Komisję Europejską, będzie miało niezwykle istotny wpływ na funkcjonowanie firm reprezentowanych przez Polskie Stowarzyszenie Przemysłu Kosmetycznego i Detergentowego (PSPKD). Co do zasady…

Engine manufacturers urge harmonised EU rules for packaging waste

European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, 19 Apr 2023

EUROMOT stresses the need to ensure that Member States shall not further implement individual national measures. They argue that requirements for re-use for transportation packaging must be realistic and proportional for individual industry sectors. Finally, substance requirements should remain under REACH to avoid double regulation.
Uniform requirements would prevent market fragmentation and reduce administrative burdens for industrial manufacturers.
National authorities would lose the power to set stricter local waste targets.

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European Association of Steel Drum Manufacturers, 18 Apr 2023

SEFA is the Association representing the steel drum industry in Europe. Our members produce steel drums and other types of industrial sales packaging for various industries such as the lubricant and chemical industry, or the agrochemical and food sectors. Steel is a permanent material which means…

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European Bioeconomy Bureau, 14 Apr 2023

The feedback from the European Bioeconomy Bureau (formerly the ECBPI) is attached. References to the statements made are available if required by the Commission

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International Confederation of Plastics Packaging Manufacturers, 13 Apr 2023

The purpose of our statement is to highlight key concerns about the PPWR and to provide background information that we would like to discuss in more detail. In addition, we propose certain changes to the text of the regulation in the appendix to the statement in order to address some of the points…

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Bund Getränkeverpackungen der Zukunft GbR, 6 Apr 2023

Bund Getränkeverpackungen der Zukunft (BGVZ) is an association of beverage producers, retailers, packaging and recycling companies. The majority of BGVZ's shareholders are operating on the market in Germany as well as in other European member states. In summary, we would like to comment as follows…

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Sterile Barrier Association, 20 Mar 2023

The Sterile Barrier Association (SBA), the European trade association for companies, who produce Sterile Barrier Systems (SBS) and associated equipment and accessories for the healthcare industry, strongly supports global efforts to minimise the negative environmental impact caused by packaging. In…

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Roundtable for Reusable Crates Trays and Pallets, 22 Feb 2023

The RCTP welcomes the ambitious proposal of the European Commission for a review of the Packaging and Packaging Waste Regulation (PPWR). Please find below the RCTP's main concerns: Define reuse: Crucial for a successful transition to reuse is to define the properties of Packaging (art. 3) and…

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Milchindustrie-Verband e.V., 21 Feb 2023

In Deutschland arbeiten die dualen Systeme seit Jahrzehnten mit einem Müllsammelsystem inklusive der Sortierung und Verwertung von Verpackungsabfällen aus den privaten Haushalten. Dieses System wird kontinuierlich erweitert und verbessert. Die deutsche Milchindustrie ist der größte Zahler von…

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IK Industrievereinigung Kunststoffverpackungen e.V., 7 Feb 2023

For us, the German plastic packaging manufacturers, the proposed regulation offers an opportunity for the sustainable transformation of the entire packaging industry. Our members have invested in the recyclability of their products and stand ready with innovative solutions that combine high…

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Bundesgütegemeinschaft Kompost e.V., 17 Jan 2023

Die BGK lehnt die Entsorgung von so genannten kompostierbaren Verpackungen und Kunststoffen über die biologische Abfallbehandlung (Kompostierung, Vergärung) strikt ab. Einzige Ausnahme sind Bioabfall-Sammelbeutel, wenn diese von den öffentlich-rechtlichen Entsorgungsträgern in Absprache mit der…

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IK Industrievereinigung Kunststoffverpackungen e.V., 6 Aug 2020

IK represents the plastic converting industry in Germany in the field of plastic packaging production with about 300 member companies, mostly SMEs. The branch produces a revenue of 15 bn Euro and employs about 90,000 people. We welcome the European Commission's goals of climate neutrality and a…

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Féderation INternationale des fabricants et transformateurs d'Adhésifs et Thermocollants sur papiers et autres supports, 6 Aug 2020

FINAT is the European association for the self-adhesive label industry. We welcome the opportunity to provide feedback on the European Commission’s initiative, “Review of the requirements for packaging and other measures to prevent packaging waste,’’ and in particular regarding updates to the…

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APK AG, 6 Aug 2020

APK AG welcomes the initiative of the European Commission (EC) to examine the feasibility of reinforcing the Essential Requirements (ER) for packaging with a focus on 'improving design for reuse and promoting high quality recycling'. In this context and in the context of the EU Plastics Strategy,…

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Estonian Food Industry Association, 5 Aug 2020

Eesti Toiduainetööstuse Liit toetab Euroopa Liidu Green Deal poliitika eesmärke liikumaks puhtama keskkonna, tõhusama ressursikasutuse ja süsinikuneutraalse majanduse suunas. Toetame tootjaid ühendavate organisatsioonide ettepanekut, et 2030. a peaksid kõik ELi turul olevad pakendid olema…

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associazione italiana delle bioplastiche e dei materiali biodegradabili e compostabili, 3 Aug 2020

Assobioplastiche is the Italian association representing the bio-based, biodegradable and compostable plastics sector. The following feedback is related to the study “Effectiveness of the Essential Requirements for Packaging and Packaging Waste and Proposals for Reinforcement” commissioned by the…

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Chemical Recycling Europe, 3 Aug 2020

Chemical recycling is one of the key solutions contributing to the circular economy of plastics. In addition to increasing the recycling rates of some plastics currently not being recycled, it is creating recycled content of virgin-quality which will be essential to fulfil the strong demand…

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Associação Portuguesa para a Defesa do Consumidor, 29 Jul 2020

Os contributos da DECO no documento anexo

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Wirtschaftsverband Papierverarbeitung, 21 Jul 2020

WPV Position Paper INCEPTION IMPACT ASSESSMENT: Review of the requirements for packaging and other measures to prevent packaging waste

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Det Økologiske Råd, 9 Jul 2020

In Green Transition Denmark, we clearly support circular economy and the thought that waste is reduced and goods are re-used and recycled as much as possible. However, it is very important to be aware of the limitations – hazardous chemicals. This can in many cases be a big problem, e.g. when old…