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Citeo

Founded in 1992, Citeo is a not for profit and driven-mission company in charge of the extended producer responsability (EPR) for packaging and graphic papers in France, with the entrustment of 30,000 companies.

Lobbying Activity

Response to Circular Economy Act

31 Oct 2025

Citeo would like to provide feedback to the European Commission in order to leverage its expertise in the circular economy for the development of ambitious, pragmatic Circular Economy Act that can ensure a competitive and circular European economy. Citeo underlines the importance of ensuring legal certainty and clarity in the long term, and not to give in to deregulation, in order to secure investments and build a strong European and decarbonized market. Citeo supports the following measures: - Strengthening EPR schemes through harmonization of minimum requirements: o Opposition to State-Run PROs where EPR fees become public revenue because it contradicts the polluter-pays principle and lack environmental accountability. o Modernizing EPR by integrating 3R/4Rs strategy in the concept of EPR in the Waste Framework Directive by entrusting PROs with the deployment of operational projects in the field of reduction and reuse, financing annual support programmes for producers to reduce waste generation and improve product design or encouraging PROs to provide financial support to foster reuse with the establishment of annual funding envelopes dedicated to reuse. - Reshaping EPR models to improve performance of the scheme: o Replacing the role of the State acting as a coordinator by setting clear guidelines and political orientations, be an arbitrator between stakeholders of the value chain and applying sanctions defined. o Bolstering transparency by integrating independent audits led by third-parties on treatment of datas and financial flows of the EPR scheme. o Linking cost coverage exclusively to system performance to achieve European objectives. Any increase beyond EU threshold of 80% cost coverage should be conditional upon the operational responsibility entrusted to PROs and their leverage over collection and sorting system. o Deploying citizens engagement through awareness and behavioural changes driven by PROs. EU legislation should explicitly recognize the responsibility of PROs to inform and engage citizens with campaigns funded through EPR schemes. o Integrating the ecomodulation principle in the EPR minimum requirements to incentivize eco-design by, not only favouring most recyclable products and/or packaging but also rewarding reduction to reflect the 3Rs strategy and acting as a complementary tool. o Enhancing the effectiveness of EPR by reducing administrative burden for small and medium enterprises (SMEs) with a simplified declaration for companies placing less than a defined threshold of tonnes on the market helping to prevent free-riding. - Simplifying, digitalizing, and expanding EPR schemes: o Endorsing a voluntary EU-wide One-Stop-Shop tool for producers with the integration of the registration process and enabling producers to report their identification numbers (EPR numbers) corresponding to the different EPR schemes they are required to report to. o Supporting data harmonization for interoperability where possible: Calls for EU-level standardization of data to enable streamlined reporting and support digital tools. o Expanding the use of the Digital product Passport model to all products and packaging in Europe as a tool to develop transparency throughout the value chain. - Reinforcing the strategic autonomy of the EU with high-quality secondary raw material market through EPR: o Boosting EU secondary raw material market using EPR to favor EU-sourced recycled content via proximity-based bonuses. o Ask the European Commission to conduct a study to explore the possibility given to EPR schemes to provide priority access of recycled materials. - Carry out a recycling rate calculation methodology reform to reduce disparities and comparability of data between Member States. The methodology should also refer to all recycling methodologies, including chemical recycling.
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Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles

8 Aug 2025

Citeo welcomes the publication of the methodology of calculating the integration of recycled content with mass balance approach, which is essential for the development of an EU secondary material markets. We underline the following points: Support for the prioritization of mechanical recycling where quality allows, while recognizing the complementary role of chemical recycling to improve overall recycling performance. Endorsing the recognition of a fuel-use excluded approach which is essential to ensure only material contributing to circularity is counted and endorses the strict limitation to post-consumer plastic waste. Necessity for a regulatory framework governing claims related to the use of materials derived from mass balance. Support for the limit of using mass balance accounting method only when the proportion of eligible material in the output is not known to favour physical traceability by economic operators whenever possible. Endorsing the methodology proposed at the stage where eligible material in liquid form is processed by a stream cracker. The two-step calculation method outlined includes safeguards to ensure that eligible material is diverted to fuel-use. The introduction of a dual-use factor is very positive and allows the final use of output to be assessed based on verifiable evidence provided by economic operators. It is essential to ensure traceability and uphold credibility of the fuel-use excluded allocation methodology. Needs for clarification regarding the applicability of the method to upgrading steps performed on eligible liquid material prior to the entry into the steam cracker. Supporting the establishment of a verification procedure to be adjusted for traceability improvements: while we support verification procedure entailed in ensuring traceability, transparency and accountability throughout the supply chain, we regret that third-party verification process is not required for all possible cases and is only required for mass balance accounting method. For our complete feedback, please see attached.
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Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

14 May 2025 · Circular economy

Meeting with Grégory Allione (Member of the European Parliament)

18 Mar 2025 · RDV Citéo - économie circulaire

Response to 8th Environment Action Programme – Mid-term Review

24 Jan 2024

Citeo expresses support for the European ambition towards a circular economy and acknowledges the progress made through legislative measures. To further enhance the European regulatory framework for the circular economy, Citeo endorses, through its contributions, ongoing negotiations, including : - The proposed Regulation on Packaging and Packaging Waste (PPWR), which will introduce essential new measures, including, reduction, reuse, improvement of collection and recyclability. - The proposed Green Claims Directive, which will define a regulatory framework to substantiate, communicate and verify environmental claims. In order to fulfil the objectives of circular economy outlined in the 8th EAP, Citeo aims to outline specific actions within the 3R strategy (reduce, reuse and recycle) in order to progress further in promoting circular economy at EU level : On reduction, Citeo endorses the emphasis on reducing unnecessary packaging and adopting formats that minimize the quantity of packaging in relation to the product's weight, aligning with the Commission's proposal PPWR. However, Citeo finds it important to accompany brand owners in terms of waste generation by developing clear guidelines, per type of packaging and per sector. On reuse, Citeo believes a coordinated response at European level is needed to build a functional reuse ecosystem. By way of means, Citeo aims to enhance the following elements: the scalability of reuse systems, the implementation of efficient deposit return systems, the standardization of packaging, the establishment of a mutual financing scheme, the promotion of consumer awareness, and the cultivation of collaborative ecosystems. On recycling, Citeo advocates for mandatory targets on recycled content that go beyond plastics, encompassing all types of packaging in order to foster fair competition conditions and encourage the reduction of virgin materials. Citeo argues for a broader revision of the Waste Framework Directive (WFD), calling for a redesign to encourage a paradigm shift. Waste should be viewed as a resource, aligning with the circular economy principle. On collection systems, Citeo supports the implementation of mandatory deposit systems. More broadly, Citeo advocates for the minimum harmonization of collection systems in Europe by introducing harmonized minimum requirements to determine the model for selective collection, through the revision of the WFD. On waste, Citeo advocates for the extension of the scope of the Carbon Border Adjustment Mechanism (CBAM) to other materials such as polymers.
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Response to Measures to reduce microplastic pollution

16 Jan 2024

Citeo welcomes the proposal for a regulation on preventing plastic pellets losses to reduce microplastic pollution, which pursues the objective of restricting microplastics added unintentionally in products and addressing intentional emissions of microplastics, and which considers for this purpose all the microplastic chain. However, we call for further clarification of several provisions. 1/The definition of pellets must be clarified (article 2 (a)) The proposed definition « a small mass of preformed polymer-containing moulding material » is relatively vague. As industrial pellets are concerned, it would be relevant to specify a size criterion of 0,01mm - 1cm, as proposes the French decree n°2021-416 of April 16, 2021 on preventing losses of industrial plastic pellets into the environment, to ensure that the scope of the regulation can consider the relevant category of pellets and prevent from directing the production towards smaller or bigger sizes of pellet to avoid complying regulation. The decree is available under this link: https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000043388114 2/The time limit for action in case of failure of an action taken for the prevention, containment and clean-up of spills and losses must be specified (article 4, point 8) The article 4 foresees that economic operators, carriers and non-EU carriers shall, in this case, take corrective actions, as soon as possible. As it constitutes a serious risk, it would be appropriate to modify « as soon as possible » par « immediately », in coherence with the article 9.1 and 3, and article 10.1. 3/The risk assessment plan for installations shall precise the level of risk for locations and operations (annexe I) Annex I dedicated to risk assessment plans, which economic operators must establish, refers to locations and operations carried out according to their level of risk: « high- and low-risk locations » et « high- and low-risk operations ». Two modifications are necessary here: (i) the proposed regulation must include an indicative grid of criteria determining the level of risk of locations and operations, subject to a review clause (ii) it must indicate that, on this basis, all economic operators must explain the criteria used to conduct their evaluation. This will allow a common reference framework to compare effectively and relevantly the different risk assessment plans sent to the competent authorities of the Member States.
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Response to Environmental claims based on environmental footprint methods

21 Jul 2023

Citeo is the French company in charge of the Extended Producer Responsibility (EPR) for household packaging and graphic papers. Citeo welcomes the EC proposal to provide harmonized rules on substantiation, communication, verification of voluntary green claims at European level. Since one of its statutory objectives is giving citizens keys in reducing the environmental impact of their consumption, Citeo would like to share some remarks to reinforce provisions of the Directive, based on its expertise in the packaging sector: - Micro-enterprises shall not be exempted from the scope of the Directive, since consumers shall have access to fair informations, regardless the product and the size of the brand. The Commision shall provide guidelines to Member States in order to accompany micro, small and medium companies ; - Recommends adopting a delegated act referring to a unique methodology to substantiate claims on packaging, with a preference for PEF methods, while encouraging ongoing work to improve this methodology and take into account impacts on biodiversity. Waiting such delegated acts, substantiation requirements should be reinforced; - The Directive should specify environmental claims are provided in a clear, proportionate, and unambiguous manner; -The Digital Product Passport (Ecodesign Regulation proposal) is an opportunity to provide information on the circularity of products and packaging; - Citeo welcomes the third-party verification but recommends it should be done in a "reasonable timing" to limit operational challenges.
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Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles

30 May 2023

Citeo underlines the risk of misunderstanding and legal uncertainty with the existence of definitions of recycled plastic in two legal instruments. In order to calculate the weight of the beverage bottle, Citeo believes all the components should be taken into account and not only the plastic parts of the beverage bottles. Notwithstanding, the simplification of calculation and declaration, considering all components would avoid any side effect on recyclability with a material switch that might occur if non-plastic part, such as paper sleeve, are exempted. These components have no impact on the attainment of the targets, but their exclusion might encourage economic operators to use paper-based label rather than plastic label. The implementing act should already provide minimum requirements on chain of custody, and especially controlled blending, as it is already effective even in mechanical recycling. As transparency is a prerequisite for the verification of recycled content targets, incorporation of recycled content should be subjected to verification and auditing process by third parties. It would allow the correct implementation of eco-modulation on incorporation of recycled plastic content as included in the Packaging and Packaging Waste Regulation. For more information, see Citeo's feedback attached.
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Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur for opinion)

4 May 2023 · Packaging and packagingwaste

Response to Initiative on EU taxonomy - environmental objective

3 May 2023

Citeo, the French company in charge of the Extended Producer Responsibility for household packaging and graphic papers, is delighted to be supporting the European Commission in shifting the European Union into a real internal circular economy loop. Citeo fully endorses the EUs vision for a finance that accelerate the circular economy, urging for the material to transform from waste to economically, socially, and environmentally beneficial resource, with the aim to reach the target of 100% of packaging reusable or recyclable by 2030. Citeo would like to provide feedback on the Annex II and the Manufacture of plastic packaging goods and activity considered as contributing to substantial contribution to the transition to a circular economy (1.1) Citeo would like to underline first, the reason why the scope of this activity is limited to plastic and does not cover other material which face also challenges in terms of circularity and are also relevant to contribute to the transition to a circular economy. In addition, Citeo stresses that the draft delegated act does not address waste prevention and reduction of packaging. Regarding design for reuse: - Citeo fully endorses that the taxonomy promotes the design for reuse which is a way forward to improve the circularity of packaging in Europe. - Citeo supports that the delegated act provides for a defined governance, rules on the product and ensures open and equal access and condition for all economic operators. Regarding the use of circular feedstock: - Citeo fully supports taxonomys strong promotion of the use of circular feedstock. Citeo welcomes the fact that only post-consumer plastic is considered and a distinction between contact sensitive and non-contact sensitive is made. - However, Citeo underlines that it would also be relevant to go one step further by making a distinction of the origin of the post-consumer plastic waste, either industrial and commercial post-consumer packaging or household post-consumer packaging. - Citeo supports the aim of the draft regulation to foster the development of new complementary recycling technologies to mechanical ones, such as chemical recycling. Regarding the use of bio-waste feedstock: - Citeo calls for vigilance with the use of bio-waste feedstock a as mean to increase the circularity of packaging. - Citeo recognizes the environmental benefits to exclude primary biomass and to solely include industrial bio-waste and municipal bio-waste, it enshrines the recognition of biobased packaging. - Citeo questions the limitation to bio-waste feedstock. - Citeo is against the recognition of biodegradability and compostability as recyclability. Regarding the recyclability of the packaging: - Citeo is in favour of fostering the recyclability of packaging. - Citeo would like to raise attention that, although a unit of packaging shall be designed to be recyclable, so that it can be sorted and recycled at the end of life, it shall be foster in applications replacing the same virgin material rather than in the same or similar packaging application. - Citeo support that the taxonomy recognizes the obligation for separation of its components. However, it should only be done within the existing sorting and recycling processes and not by consumers because it might increase the risk of errors. - Citeo isnt in favour of the proposed definition of the recyclable at scale -based on the number of inhabitants - that could generate side effects due to the different habits of consumption across Europe. Regarding the use of compostable materials in packaging applications: - Citeo supports taxonomys position regarding the use of compostable materials in packaging applications since compostability should be limited to packaging collected to biowaste. - Citeo advocates to only refer to home-composting. - If one favours compostability over recyclability, it should answer to the same requirements.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

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 aimed by the proposal. We have raised some concerns regarding different measures: - On prevention: Citeo believes integrating waste prevention from the product design stage is a driver tool to incentive producers to develop ecodesign measures in their products portfolio. Waste prevention plans should be expanded, and every company shall refer to one, either one developed individually or with the help of a PRO as part of a service given to producers within EPR scheme. - On reuse: we welcome the harmonised definition of reusable packaging, and we are in favour of defining requirements per type of packaging through EU standards. We believe the chain of responsibility should be further clarified. Considering Citeos work on standardisation of packaging formats, we consider standard formats are part of the solutions to reach reuse targets and should be deployed within the PPWR. We believe PROs could play a key role in terms of reporting reuse data as becoming a collective structure. - On recyclability: we support the definition taking into consideration different levels of recyclability. We believe intermediate levels could be included to take into account hindering substances of recycling schemes. In addition, we raised strong concerns with regard to the recyclability at scale definition, which might call into question already existing or coming recycling schemes such as ones for PS packaging. - Compostability: Citeo believes compostable packaging should be limited to light packaging collected with biowaste and excluded for any other packaging. Only home composting should be considered since industrial composting is underdeveloped EU-wide and brings no interest in regard to circular economy, CO2 emissions and impact in nature if it leaks in the environment. - On recycled content: we support recycled content targets based only on post-consumer recycled plastic. We recommend giving priority at this stage to the approach adopted under the SUP Directive that sets targets at Member State level to not disadvantage small and medium enterprises. We stress the need of available tools to reach the targets which might not be possible otherwise. To do so, we are in favour of introducing a right of preference and consider the calculation methodology of mass balance. - On labelling: we share the willingness of the Commission to harmonize labels at European level in a context of multiplication of labels on packaging across the European Union. The design of such label should be based on a specific methodology to ensure it is effective and well understood by consumers. - On DRS: Citeo is in favour of the harmonisation of minimum requirements for recycling DRS for plastic bottles and cans in order to help the collection of packaging falling under its scope. The proposal for regulation should address particular DRS systems compliant with the minimum requirements. In this regard, DDRS, to the extent of Citeos knowledge, might constitute a new relevant technology in the future with some developpments that still need to be addressed.
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