ALPLA Werke Alwin Lehner GmbH Co KG
ALPLA
ALPLA is a family-owned business that seeks balanced profitable growth and a reinforced global presence.
ID: 820189240173-22
Lobbying Activity
Response to Circular Economy Act
5 Nov 2025
Creating a level playing field for mechanical recycling of plastic packaging waste in the European Single Market: Representing family-run companies of the plastic packaging value chain, ALPLA, REMONDIS, and Werner & Mertz welcome the European Commission's initiative to create a well-functioning market for secondary raw materials in the EU. We consider the European Circular Economy Act (CEA) to be a crucial opportunity to secure the competitiveness of European companies and provide reliability for long-term investments. For our alliance alone, investment decisions of around 1.2 billion are currently at stake. It is essential to establish an environment of stable and predictable demand for high-quality recycled materials within the European market. Ensuring that this demand supports EU-based recycling capacities will safeguard value creation, compliance, and innovation for the entire value chain within Europe. The current market is undermined by uneven competition and insufficient enforcement of standards for imported recyclates. We recommend targeted policy measures, most notably financial incentives for post-consumer recycled plastics made of EU waste, harmonized eco-modulated EPR schemes, stricter import controls, and a mandatory quota for recycled content in public procurement. Please see our position paper attached.
Read full responseResponse to EU rules for the calculation and reporting of recycled content in single-use plastic bottles
19 Aug 2025
ALPLA is a global leader in the development and manufacturing of rigid plastic packaging solutions. The company operates 200 manufacturing plants across 46 countries, employing over 24,000 people worldwide. ALPLA specializes in innovative packaging systems, bottles, closures, and injection-molded parts for industries such as food & beverage, cosmetics and pharmaceuticals. With more than 30 years of experience in recycling, ALPLA has built a robust mechanical recycling network and invests approximately 50 million annually in circular economy initiatives. We are grateful for the opportunity to comment on the draft text and welcome that in recital 5 the Commission is explicitly stating that chemical recycling should complement mechanical recycling, which is in general preferable from an environmental point of view. Nevertheless, we think that without further clarifications and calculation rules, in its current version the draft would lead to severe market distortions and rebound effects on climate and environmental policy goals. ALPLA therefore advocates for clear definitions, complementary and transparent calculation methodologies and protection against competitive disadvantages through non-EU imports, see our proposed solutions outlined in the enclosed statement.
Read full responseMeeting with Stéphane Séjourné (Executive Vice-President) and
2 Jul 2025 · EU Clean Industrial Dialogue on Circularity
Response to Modernisation Fund - first evaluation of the operating rules
26 May 2025
The ALPLA Group, with its 200 locations and 24,350 employees in 46 countries, is a leading global plastic converter specialized in PET and PO rigid packaging and a leading global recycler, developing and producing safe, affordable and sustainable rigid plastic packaging solutions worldwide. As a global family of pioneers the principle of our actions is to meet our responsibility for people, communities, and the environment. While we have not yet had direct experience with the EU Modernisation Fund, we would like to encourage the European Commission to ensure that the fund is accessible not only to SMEs but also to larger companies making substantial investments in circular productssuch as plastic packaging with recycled content and the production of made-in PCR.
Read full responseMeeting with Katarina Barley (Member of the European Parliament)
8 Jan 2025 · Werksbesichtigung; Politische Rahmenbedingungen für eine funktionierende Kreislaufwirtschaft für Kunststoffe
Meeting with Sabine Verheyen (Member of the European Parliament)
28 Aug 2024 · PPWR
Meeting with Svenja Hahn (Member of the European Parliament)
17 May 2024 · Exchange on Package and Packaging Waste Regulation and corporate Sustainability Due Diligence and amending Directive (EU)
15 Apr 2024
First of all, we would like to thank the EU Commission for the opportunity to comment on the draft proposal for a Commission Regulation amending Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food and amending Regulation (EC) No 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food as regards recycled plastic and other matters related to quality control and manufacturing of plastic materials and articles intended to come into contact with food. ALPLA generally supports the efforts to increase quality control under Regulation (EU) No 10/2011 and Regulation (EC) No 2023/2006 on plastic food-contact materials (FCM). Consumer health should not be put at risk. Keeping that in mind, we would like to point out a few necessary adaptations of the draft regulation in order to ensure that the regulation does not exceed the intended scope of application. Please see our key messages in the following and further explanation in the attachment. Key messages It needs to be clarified that the new rules for a high degree of purity (Article 3a) as well as the general requirements for substances (Article 8) do not apply to mechanically recycled PET obtained through authorized processes listed in Regulation (EU) 2022/1616. In order to do so, the term substance, which is not sufficiently defined in the draft regulation should be replaced by the term monomer or other starting substance in the articles 3a and 8). This would heavily contribute to the clarification. If, against our understanding, the articles 3a and 8 where indeed applicable to recycled plastics obtained through authorized processes listed in regulation (EU) 2022/1616, we would like to express our deepest concerns regarding the draft regulation of the Commission as it would put the whole recycling industry in Europe at risk.
Read full responseResponse to Measures to reduce microplastic pollution
16 Jan 2024
The ALPLA Group, with its headquarters in Hard, Austria, and 190 locations with 23,300 employees in 46 countries worldwide, is one of the leading companies in plastic conversion. We develop and produce innovative rigid plastic packaging solutions, while ensuring that our products become lighter, more durable and by 2025 fully recyclable. We have more than 25 years of experience in recycling operations with our own recycling plants. In order to achieve the ambitious goal of zero pellet losses, we have already implemented a plan for our plants. The programme is based on the voluntary guidelines introduced by the Austrian government to prevent plastic raw materials from entering waterbodies, but ALPLA expanded the initiative to its plants globally. By 2022, we introduced a Zero Pellet Loss policy in 47 of our plants, initiating major changes in our logistics by installing custom-built vacuum cleaners and drainage systems, among other initiatives. We therefore welcome the proposal to reduce microplastics pollution in the environment. However, we would like to flag the following concerns/suggestions: Currently, there is an unclarity of responsibility for restoring compliance, e.g. when it comes to the clean up of pellets/flakes released during transport, since there are usually several business operators/carriers involved in the logistics. We suggest adding incoterms to the definitions in order to improve clarity. This is especially important when Member States develop any rules and penalties. Otherwise, the current proposal could shift the liability to organisations which have no control of transport/handling of pellets/flakes. Further, the obligations of economic operators must be limited to the loading and unloading area in their site and to supply the means of cleaning and the correct disposal possibilities of granules to allow the truck drivers to meet their obligations (ref: Annex III). A deviation from the requirements under the Risk Assessment Plan Annex I should be in order where the nature and size of the installation as well as the scale of the operation permit it. Regarding containment of pellet losses, it is almost impossible to install storm water drainage or filtration systems for existing sites. Since some of the plastics have a density which is lower than waters density and some a higher density than water, the feasibility of effectively draining the plastics is very questionable. Therefore, it would make sense to introduce the obligation to implement a sewage treatment system only for newly build loading and unloading areas from 2030 onwards. Finally, according to the definition of EU carrier and non-EU carrier, it is also not clear if international sea fright is covered in the scope of regulation. Since unintentional releases during sea fright are a main cause of microplastics pollution, the regulation should tackle this release as its priority.
Read full responseResponse to Revision of EU legislation on end-of-life vehicles
4 Dec 2023
The ALPLA Group, with its headquarters in Hard, Austria, and 190 locations with 23,300 employees in 46 countries worldwide, is one of the leading companies in plastic conversion. We develop and produce innovative rigid plastic packaging solutions, while ensuring that our products become lighter, more durable and by 2025 fully recyclable. We welcome the fact that the ELV-R also provides for mandatory recycled content target of 25% PCR for the automotive sector and the 25% of this should be closed loop i.e., recycled from end-of-life vehicles. Concerning the PCR target however, we would like to point out the following: the forecast model by Conversio/IK in the attachment shows that there could be a too high demand of PCR, especially rPO, in 2030 due to the ambitious PCR targets of the Packaging and Packaging Waste Regulation (PPWR). To our knowledge, PCR originated from plastic packaging waste can be used in automotive sector but not the other way around. This means that the PCR target set in ELV-R could further accelerate the lack of PCR in the market. This would be especially problematic for packaging sector since plastic packaging is for fast-moving consumer goods with low cost. We therefore call for an impact assessment on the PCR market by PPWR especially in relation to ELV-R. Depending on the finding, the PCR target under ELV-R should be adjusted in the future. For example, the closed loop target 25% could be increased in the future.
Read full responseResponse to Drinking water - conformity assessment procedure
16 Nov 2023
In Europe drinking water from the tap is not always available in terms of quantity and quality. PET bottles are for many Europeans the only possibility source. Contaminated ground water, no water during droughts, or other reasons in time and location. Drinking Water out of the PET or rPET bottle would, even if not targeted by this regulation be referenced by the limits in this regulation. If impurities leaching out of PET bottles are technically not possible to be reduced and are inline with the food contact regulations; EC1935/2004, EC10/2011 and EC2022/1616 but above the limits of the drinking water directive, then this bottled water would be declared unacceptable by the local consumer organizations. For the EU authorities or local authorities, it will be almost impossible to requalify PET or rPET if the consumer organizations have rated this water undrinkable with limits out of the drinking water directive. The limits in the drinking water regulation have to be fine-tuned with food contact regulations to allow the supply of drinking water to the EU population with PET and rPET bottled water. Limits of the drinking water regulation need to be aligned therefore.
Read full responseMeeting with Claudia Gamon (Member of the European Parliament)
22 May 2023 · Packaging & Packaging Waste
Response to Initiative on EU taxonomy - environmental objective
3 May 2023
The ALPLA Group, with its headquarters in Hard, Austria, and 190 locations with 23,300 employees in 46 countries worldwide, is one of the leading companies in plastic conversion. We develop and produce innovative rigid plastic packaging solutions, while ensuring that our products become lighter, more durable and by 2025 fully recyclable. We have more than 25 years of experience in recycling operations with our own recycling plants. We are investing 50 million annually in the expansion and development of recycling infrastructures to increase the average share of post-consumer recyclate (PCR) in our products to 25% by 2025. As a family of global pioneers the principle of our actions is to meet our responsibility for people, communities and the environment. Therefore, we commit ourselves to the Science Based Targets initiative, aiming to limit average global warming to 1.5 degrees Celsius (Paris Agreement 2015). Please see the attachment.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
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 2025 fully recyclable. We have more than 25 years of experience in recycling operations and invest 50 million annually in the expansion of our recycling infrastructures to increase the average share of post-consumer recycled content (PCR) in our products to 25% by 2025. We consider the proposal of the Commission for a Packaging and Packaging Waste Regulation (PPWR) to be an important step towards a circular economy. However, wed like to emphasise that there is a need for clarification and further improvements on certain regulatory aspects. Our comments are aimed in particular at creating a fair and dynamic market environment that promotes the rational use and a high-quality, energy-efficient circular economy of packaging materials while preventing ecological setbacks, especially in terms of climate protection. We like to point out the following aspects: 1. Legal requirements, such as minimum recycled content quotas (Art. 7), reuse quotas (Art. 26) and deposit return systems (Art. 44), must be applied equally to all packaging materials to ensure material neutrality. 2. Reuse and recycling are complementary solutions to achieve true circularity in packaging. All recyclable and reusable packaging must therefore be evaluated equally according to its actual environmental footprint instead of setting strict reuse targets for example for transport packaging (Art. 26). 3. Recycled content targets (Art. 7) are useful and can promote the upscaling of recycling. However, these targets must be realistic and achievable by means of environmentally beneficial mechanical recycling. 4. EPR fees must be modulated for all packaging based on recyclability criteria, recycled content and CO2e footprint to avoid material discrimination and promote a level playing field. Please find our detailed argumentation in our attached position paper.
Read full responseMeeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and European Aluminium AISBL and
22 Nov 2022 · Draft proposal of a Regulation on Packaging and Packaging Waste (PPWR)
Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)
18 Oct 2022 · Circular economy and the revision of the EU packaging rules
Response to European Statistical System – making it fit for the future
15 Mar 2022
ALPLA is a worldwide active (178 plants in 45 countries) leading company in rigid plastic packaging design and production. ALPLA has also own recycling plants in 6 countries and is part of joint ventures in 2 countries focusing mechanical bottle-to-bottle recycling.
Since our focus is to make our packaging solutions more sustainable and circular, reliable statistics on the plastics packaging value chain and waste are essential for businesses like us to develop own strategies and positions.
For the timely, relevant and reliable official data that are comparable across Member States, we would like to point out that some of the policy frameworks/EU initiatives (examples listed in the following) are/will be requiring businesses to report/share data. We hope that these data are/will be analyzed efficiently while treated as confidential information. Further, consolidated information and its statistics should be available to all the stakeholders including businesses.
• Single Use Plastics Directive (recycled content and collection rate for beverage bottles etc.)
• Packaging and Packaging Waste Directive (collection rate of packaging waste, recycling rate, recyclability, recycled content, rotation of reusable packaging etc.)
• Circular Plastics Alliance (inputs and outputs to/from converters/recyclers)
• Corporate Sustainability Reporting Directive (to be enforced soon for large undertakings)
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
22 Feb 2022
ALPLA has over 25 years of experience in PET/PO packaging recycling. With our recycling plants, we ensure that plastics remain in the material cycle. We are also a competent partner for processing recycled post-consumer plastics (PCR) into new, high-quality packaging. We hereby point out enabling measures for circular (plastic) packaging and products as well as the reduction of plastic waste.
Introduce eco-modulation of EPR fees based on recyclability, recycled content, and environmental footprint for all (packaging) materials:
In many EU countries, the distributors of packaging already make a significant financial contribution to promote recycling with their Extended Producer Responsibility (EPR) fees. Instead of a plastic tax, where the revenues are not earmarked and flow into the general budget, market-based incentives to reward recyclability, recyclate use and a low environmental footprint for all materials are preferable. Eco-modulation of EPR fees is ideally suited for this purpose, as it is a system without legal prohibitions or restrictions. Distributors of non-recyclable or difficult-to-recycle packaging (and products) without recyclate content and with a high ecological footprint would have to expect higher costs if the EPR fees were eco-modelled accordingly. These revenues can be used directly to improve collection and sorting systems. The inclusion of the ecological footprint also leads to the selection of environmentally friendly packaging (and products).
Invest in intelligent waste management systems and ban landfilling/incineration of recyclable plastic packaging:
Used plastic packaging is valuable raw material. European Member States must ensure that these materials are collected and sorted in separate streams and sent to state-of-the-art recycling facilities. One element to increase collection rates is deposit or similar systems that are convenient for consumers and give value to plastic products. Separate collection must also be introduced in public spaces. In addition, we need to ensure that recyclable plastic packaging in residual waste streams is sorted out for recycling if the material fulfils quality requirements of recycling processes. Quality of the plastics packaging in residual waste highly depends on whether the residual waste contains bio-waste or not. We need a legal framework that helps the recycling industry to supply its plants with high-quality material.
Define closed-loop recycling and foster recycling technologies with a lower environmental footprint:
The waste hierarchy should differentiate between closed-loop and open-loop recycling while prioritising closed-loop recycling. To do so, closed-loop recycling needs to be defined (see the attached position paper for further details regarding closed loop recycling of rigid packaging). At the same time the WFD should favour the least energy- and resource-intensive recycling processes. If a product can be recycled mechanically, this route should be preferred to other more energy-intensive processes.
Ensure high-quality material input for EU plastics recycling plants:
Where is the EU single market approach when it comes to EU internal cross-border waste shipment? It is currently possible to transport the same material (waste) from northern Germany to the south for 800 km labelled with an “A” on the lorry, but if we cross the border from Germany to Austria for 30 km, we need extensive paperwork/notifications leading to higher costs. There is no different hazardousness potential since there are EU wide regulations on waste treatment and mutual recognition is a pillar of the EU. Europe needs the resources coming from waste. And the use of these resources is bound to highly sophisticated technology and the necessary plants to fulfil the environmental protection goals. These plants need high investment and therefore they must get the highest possible quality input streams from different EU member states without high administrative burden.
Read full response18 Jan 2022
ALPLA is a worldwide active (178 plants in 45 countries) leading company in plastic packaging design and production, we are also recyclers with nine mechanical recycling plants operating worldwide. First of all, we support the position papers by IK, PRE, EuPC and PCEP. Further, we have specific comments described in the following six bullet points.
1. Most of hazardous substances detected in recycled PET are introduced via approved/allowed components of the packaging. The introduction of such problematic component is not controlled at the upstream stage either by No 10/2011 nor any other legislations.
Such problematic components should be effectively recorded e.g. during the authorization process of novel technologies and to be added to a list of detrimental and disqualifying packaging features/components. This should be part of Design for Recycling (DfR), Recyclability evaluation standards and should be referred by DG ENV in the PPWD update. The draft regulation should create a framework for recyclers or/and existing NIAS/DfR consortiums to be able to share such data and this should be correlated between DG Santé and DG ENV.
2. The monitoring requirement under the Novel technology process is not feasible and will hinder the development of new technologies in mechanical recycling. If any test is required, guidelines for methodology should be established upfront e.g. to specify which substances should be identified by recyclers. Or otherwise, that should be defined by the EC/EFSA case by case for each technology.
Article 12 3(c) – “below the limit of their detection” such analysis not feasible for recyclers. We propose to delete after “even if…”
Article 13 1 batch testing of input does not make sense since huge variations in identified peaks are expected. E.g. usually only 1 g of sample is required for GC or HPLC analysis. Such small volume of sample never be a representative of 30 ton input.
The identification of multiple peaks require further additional analysis for the quantification which causes longer waiting time for the samples to be on hold. This means additional investment for storing samples is required (see the cost estimate attached).
If recyclers to run own laboratory, this will also require special human resources and not all the analysis may be covered internally.
3. Uncertainty in legal liabilities/consequences and investment in novel technologies when the technology is determined to be unsuitable after up to 7 years although placing of market is allowed in the meantime. A maximum time limit should be clarified and legal liability at unsuitable technology providers should be considered.
4. By considering the development of reusable packaging pooling schemes in Germany and other DRS, we propose to expand the definition of closed loop recycling in the Annex and to establish a similar process as the mechanical PET recycling. Since the material is circulated in more controlled environment, risk of incidental contamination remaining in final products should be lower.
5. Definition converter (Article 2, 16), the requirement for converters (Article 8) and the DOC template (Annex, Part B): the definition “converter” may be not correct since converters do not produce any materials (e.g. pellets). However “Post-processing” covers recycled plastic converted into recycled plastic materials and articles.
Consequently the requirement under Article 8 and the DOC for converter seems to be for recyclers/compounder compounding some additives/color.
We ask for a clarification of a role of producers of final articles under the new regulation.
6. Use of recycled plastic behind functional barrier to be applied as novel technologies. Since functional barrier is not a recycling technology and can have consequences in No 10/2011, we propose to put certain definitions or to list existing functional barrier approach in the Annex I.
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
22 Oct 2021
ALPLA welcomes the initiative to clarify the role of biobased (BBP), biodegradable and compostable plastics (BDCP).
While it´s important to assess the full life-cycle environmental impacts of bioplastics, future role of other type of renewable carbons such as utilization of CO2 (CCU) should be also assessed.
Whether BBP and BDCP are effectively sustainable alternatives over conventional plastics needs to be assessed especially in relation to the existing recycling infrastructure of plastic packaging. It is important to assess and address potential advantages of using BBP and other renewable carbons in combination with recycled resins. It is also important to establish effective waste collecting processes to separate BDCP from the recycling stream. Such collection process should be friendly to consumers. Finally the existing norms for industrial composting should be reviewed and revised to reflect the realistic situation in the composting facilities.
Existing labels such as industrial composting is confusing not only for consumers but even for people within the industry. A harmonization of existing logos (such as meta-labelling) should be considered by taking into account not only the aspect of home/industrial compostable but also the renewable carbon including the bio-based material. This means to consider a development of certificates and labels that indicate the share of renewable carbon (total share of recycled material, biomass and CO2) contained in products. However, if any mandatory labelling requirements to be considered, it should be implemented in a way not to create any further disruptions to the internal market of the EU. The artwork changes come with extremely high compliance costs along with additional use of energy.
Read full responseResponse to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals
31 May 2021
ALPLA is one of the leading companies involved in plastic packaging. Around 21,600 employees worldwide produce custom-made packaging systems, bottles, caps and moulded parts at 178 sites across 45 countries.
REACH is a necessary measure to protect human health and to minimize environmental contamination. REACH Authorisation is however known to be challenging especially for SMEs in terms of the application cost. Plastic recycling companies are our important partners and are often SMEs, simplifications of the process as well as options to define a certain threshold per substance etc. should be considered.
Read full responseResponse to Revision of EU legislation on hazard classification, labelling and packaging of chemicals
31 May 2021
ALPLA is one of the leading companies involved in plastic packaging. Around 21,600 employees worldwide produce custom-made packaging systems, bottles, caps and moulded parts at 178 sites across 45 countries.
Hazard classification and labelling are very important measures for industries to communicate its hazard to end-users. So far the development of this measure seem to be focusing on the (virgin) chemical substance produced by manufacturers. However, considering the ambition from the Green Deal, the CLP measures should also consider the business model of recycling and reuse in the future.
For recycling, more clear guidance is necessary especially for smaller sized recyclers where information in terms of their waste stream is often limited. For reuse model, for example, (household) chemicals refilled by consumers may need different approach to the hazardous communication.
Read full responseResponse to Revision of EU rules on food contact materials
19 Jan 2021
For the issue "Exchange of safety and compliance information in the supply chain", this is especially important when FCM uses recycled plastic material and if they are coming from outside of the EU or developing area in the EU. Recyclates coming from such region may have competitive price but they are generally weak in exchanging safety information. Since majority of suppliers can be SMEs, some harmonized, simplified and digitalised system is necessary. Introducing of such technology/standard may also give competitiveness to recyclates produced according to the defined rules. However, when any digitalised system will be established, one should also consider that recycled content methodology and chain of custody approach has been discussed in the industry that integration of system can be considered e.g. RAL-Gütegemeinschaft für PET-Getränkeflaschen (https://www.wertstoff-pet.de/en/about-us/). In terms of compliance information existing activities e.g. digital watermarking technology and its data management should be also reviewed.
For the issue "Rules do not encourage development of safer and more sustainable alternatives", safety assessment specific to reuse applications can be considered e.g. washing quality standard since the current rules put focus on safety on recycled plastics. We will also need clarification on the legal requirement on FCM recyclates when they are produced outside of the EU i.e. questions regarding authorization by the EC on recycling facilities outside of the EU. In relation to this, more clarification on the relationship between FCM legislation and REACH regulation would be also necessary. Finally, some harmonized assessment procedure for recycled plastics in general can be considered since the current approach is established per polymer and plastics other than PET (and HDPE) such as PEF, PEN etc. are not covered.
For the issue "Shifting the focus onto final materials", more clear and harmonized guidance/procedure for NIAS as well as common explanation for substances are necessary.
For the issue “one-substance, one-assessment” approach, it should be noted that under the microplastics restriction proposal, microplastics is regarded as PBTs like substance - this gives an idea that all microplastics are PBTs although this is not yet assessed and confirmed. When any assessment around microplastics will be established in relation to FCM, it should be based on facts and such rating of microplastics should not directly influence the decision.
Read full response