CITEO
CITEO
Pioneer of sustainable development since the early 1990s in France, Citeo has developed its expertise by creating a new future for household packaging and graphic papers.
ID: 430607416969-79
Lobbying Activity
Response to Early Warning Report on Waste
1 Aug 2022
Citeo, the French mission-driven company in charge of the extended producer responsibility (EPR) for household packaging and graphic papers, would like to share its analysis of collection, sorting and recycling in France with the Commission, as part of the early warning report aimed at assessing the performance of Member States in this area.
1. France transposed Waste Framework Directive targets and goes one step further with single-use plastic reduction targets, reuse targets, and ambitious collection and recycling targets.
2. On waste reduction and waste prevention:
- Waste prevention targets have been included in the National Waste Prevention Programme (2021-2027) that sets out the strategic orientations of public policy on waste prevention, contributing in the achievement the Waste Framework directive prevention targets;
- As part of Citeo’s extended producer responsibility commitments and in order to reduce single-use plastic and all types of unnecessary packaging elements, Citeo developed the ‘Less methodology’, which is a tool for guiding companies towards ecodesign-reduction actions from requestioning the functions of each packaging elements to concrete examples of reduction solutions.
3. Regarding reuse, and given the legislative constraint to reach 5% of reused packaging placed on the market in 2023 and to dedicate 5% of Citeo’s fees to reuse models, Citeo works on standardisation for reuse projects to develop reuse model in a sustainable way.
4. France is on track to reach the EU 75% recycling target for all type of packaging by 2025:
- In 2021 the recycling rate of household packaging increased and reached 72%, exceeding the 2017 level (+ 4 points). The recycling of graphic paper is also up (+4.4 points in comparison with 2017), reaching 62% .
- In assessing the achievement of EU targets, the Commission needs to take into account the fact that the new calculation methodology will result in a decrease of reported recycling rates in all member states.
Read full responseMeeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)
7 Jul 2022 · Revision of the Packaging and Packaging Waste Directive
Response to Sustainable Products Initiative
22 Jun 2022
Citeo, the French company in charge of Extended Producer Responsibility (EPR) for household packaging and graphic papers, would like to share its views on the proposal for a regulation on ecodesign for sustainable products presented by the European Commission on 30 March 2022, as part of the Sustainable Product Initiative, the Circular Economy Action Plan and the European Green Deal.
Citeo welcomes this draft regulation setting new rules for almost all products on the EU market as a major opportunity to enhance product sustainability. As a matter of fact, it establishes the framework for ecodesign requirements to significantly improve products circularity, energy performance and other aspects of environmental sustainability.
However, the initiative should complement the implementation of Union legislation on waste and Citeo would like to reiterate the need of consistency with the revision of the Packaging and Packaging waste Directive (PPWD). As such, Citeo would like to draw attention to the Commission that, when establishing rules for groups of products, the Commission should prioritize horizontal requirements for packaging through the revision of the Packaging and Packaging Waste Directive.
Although it is very positive that requirements will continue to be set on a product-by-product basis taking into account individual specificities and characteristics of the different products, the PPWD should be the only legislation covering packaging design requirements, regardless of product
category. It is important to secure a coherent approach on the sustainability of the packaging.
Last, the proposed Ecodesign Regulation provides for the creation of a digital product passport increasing the availability of sustainability information. Citeo would like to stress the relevance of including information on the sustainability of the packaging through the digital product passport as a complete life cycle analysis include the analysis of the product and the packaging since their are intimately linked.
It would permit to get access on information such as the reusability of the packaging, its recyclability, or on the appropriate sorting instructions. Citeo would like to take this opportunity to stress the HolyGrail 2.0 project in which Citeo is involved and which is based on digital watermarks. For reasons detailed in its feedback (see attached) Citeo believes digital watermarks would be appropriate to provide information on both the product and on the packaging.
Read full responseMeeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)
4 Mar 2022 · EU circular economy implementation and extended producer responsibility
Response to Waste Framework review to reduce waste and the environmental impact of waste management
22 Feb 2022
In 2020, the French recycling rate is estimated at 68.2%, slightly lower than the revised 2019 recycling rate of 68.8% . It could be explained by the health crisis in 2020 led to malfunctions in the selective collection system, which collection system, degrading recycling performance.
At European level, the share of waste recycled has slightly increased in the EU-27, from 37% of total waste treated in 2010 to 38% in 2018 . However, and according to a European Commission’s report recycling rate is above 50% in only eight Member States and is much lower in others, for example in Bulgaria and Romania where only 3% of waste is treated by recycling .
Thus, there is a clear need of further improvements and Commission’s ambition to strenghten incentives to improved waste-management and recycling performances is more than welcomed.
As the French company in charge of the Extended Producer Reponsibility (EPR) for households packaging and graphic paper, Citeo would like to share its views on the work progress regarding waste management founded on the waste hierarchy, including the reduction of total waste generation at EU level and the improvement of the separate collection. According to Citeo, the waste hierachy should continue to be a key guiding principle in order to reduce total waste generation with the following key measures :
-Clarify the definition of waste on what should be understood as waste in the light of the development of new recycling technologies;
-Amend the definition of recycling to include new recycling technologies, including chemical recycling;
-Introduce reduction targets and ensure that waste prevention measures are effectively implemented in all Member States;
-Introduce reuse targets that are compatible with national measures already adopted;
-Promote standardisation of reuse: the European Commission should consider work already underway at national level;
-Improve consumer information on sorting instructions and hamonise labelling at European level with inspiration of the French "Info-tri", which has a multi-country version without text and in monochrome;
-Citeo supports the European Commission's ambition to harmonise minimum collection requirements to improve performance. Existing infrastructures in Member States must be taken into account to ensure a high quality recycling.
-Citeo supports the Commission's ambition to strengthen derogations to separate collection provided for in the Directive. These derogations must be clarified to mention the particular case of ultra peripheral regions which do not always have industrial recycling facilities;
-Promote high quality recycling through consistent European targets and supported by other European policies such as taxonomy to reduce waste generation;
-Refer to the Waste Shipment Directive banning the export of non-hazardous waste to non-OECD countries;
-Ban landfill to promote reduction, reuse and recycling,
-Integrate incentive tools such as eco-modulation to encourage eco-design, which should be defined by the eco-organism.
Read full response14 Jan 2022
The European Commission has just launched a public consultation, opened until the 18th of January 2021, on recycled plastic materials and articles intended to come into contact with foods, and repealing Regulation n°282/2008. This initiative aims to ensure recycled plastic materials used with food are safe and contain no toxic contaminants.
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.
Within the framework of the Circular Economy Action Plan, Citeo supports the promotion of increasing recycled plastic materials and the revision of Regulation n°282/2008 on recycled plastic materials limited to certain recycling technologies, specifically to mechanical recycling of polyethylene terephthalate “PET”. Citeo endorses the fact that this new proposal covers all recycling technologies and is also capable of covering future recycling technologies.
However, uncertainties remain, and both recyclers and developers are made responsible for developing safe recycled plastic materials. In the light of the Draft Regulation, Citeo would like to draw attention to the persistence of uncertainties that could be detrimental to the development of new technologies.
Key recommendations:
- The fact that recycled plastic materials and articles produced by technologies are under conditions and for limited time placed on the market before being authorised by the European Commission is a source of risks and a great level of concerns for developers and recyclers.
- This regulation should be supported with guidelines to foster and drive recyclers and developers to perform risk assessment before placing products on the market and to develop safe novel technologies.
- Citeo suggests the Commission to clarify its procedure, the timeline, and criteria for evaluation to decrease the level of uncertainty of the assessment.
- Citeo supports the need to collect information on recycled materials with characterization, but calls for the publication of such data to be restricted to experts able to understand risk management, as it would be counter-productive for the circular economy to share it at a public level.
- Citeo welcomes the aim of the regulation to ensure food safety of recycled materials for food contact applications. Yet, on the monitoring and reporting of contaminants level, Citeo recommends developing specific guidelines for the use of recycling material behind functional barriers which will take into account, food safety of the first use and circular economy impact for recycling process at the end of life.
Please find our detailed feedback on the document attached.
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
27 Oct 2021
Citeo, the French company in charge of the Extended Producer Responsibility for household packagings and graphic papers, is delighted to be supporting the European Commission in shifting the European Union into a real internal circular economy loop.
As such, Citeo endeavours for improving the circularity of all type of packaging, while also ensuring its net environmental improvement over the product’s life cycle. In a context of increasing uncertainties caused by climate disruption, it becomes necessary to effectively address emerging and environmental issues. Among those priorities, we do believe that the development of circular consumption and production models are key factors to combat the effects of climate change and should be pushed forward in the new Circular Economy Action Plan.
In this framework, Citeo supports a better regulation on biobased, biodegradable, and compostable plastics. As a matter of fact, the recital 11 of the Single Used Plastics Directive specifically sets out that “Plastics manufactured with modified natural polymers, or plastics manufactured from bio-based, fossil or synthetic starting substances are not naturally occurring and should therefore be addressed by this Directive. The adapted definition of plastics should therefore cover polymer-based rubber items and bio-based and biodegradable plastics regardless of whether they are derived from biomass or are intended to biodegrade over time”.
In response to a question asked by MEPS, the European Commission reiterates biobased and biodegradable plastics are expressly referred to the SUP Directive. According to Mr Sinkevičius, “the inclusion of such products is in line with the objectives of the Directive and necessary to prevent and reduce the impact of certain fast-moving consumer products that are prone to be littered”.
Thus, biobased and biodegradable plastics are still considered as plastic. We first need to systematically distinguish “biobased” (referring to the origin of the raw material used to produce plastic) from “biodegradable” or “compostable” (referring to the end-of-life of specific plastics). In addition, Citeo endorses the fact that they should not be systematically understood as a synonym of sustainable and therefore be promoted above “conventional” plastics. Citeo is in favour of promoting first incentives for reducing packaging in order to limit abandoned waste and protect biodiversity, reusing as well as recycling plastics and then composting for packaging related to kitchen biowaste.
Citeo supports the following recommandations:
- The French legislation provides a definition of biobased materials characterized on a percentage of material of biological origin;
- Although BBP could open up interesting opportunities on the development of substitutes to fossil based materials, it could also be counterproductive in the fight against plastic pollution since it does not guarantee the sustainability of the product nor its harmlessness for the environement when found in nature, it could disrupt the recycling chains and it is misleading for consumers;
- Citeo recommends not favouring the promotion of biodegradable and compostable plastics (BDCP) over the promotion of reusable or recyclable alternatives;
- Citeo support harmonized definitions of biodegradable and compostable plastics as Member States have already adopted measures to prohibit biodegradable claims and limit the use of compostable packaging;
- Citeo advocates for compostable plastics with a scope limited to fruits and vegetables bags and labels, as well as coffee capsules and pods and tea bags, because they can help increase the collection of biowaste they contain or are associated to;
- Citeo suggests to align the policy framework on biobased, biodegradable, and compostable plastics with the Sustainable Products Initiative to build a consistent policy framework on recyclability.
Read full responseResponse to Calculation, verification and reporting of data on the separate collection of SUP beverage bottles
16 Jun 2021
Citeo welcomes that the new draft implementing decision makes clear that the comparability criteria apply to all collected bottles and not only to bottles collected in co-mingled collection systems and does no longer require cross-checks and the characterisation of non-targeted material and other substances. We also acknowledge the change regarding food contact which placed a discriminatory requirement on extended producer responsibility (EPR) schemes compared to deposit refund systems (DRS).
Citeo believes that equal treatment between DRS and EPR should be guaranteed. In a system like the French market, DRS will not be implemented before 2023, pursuant to Article 66 of the antiwaste and circular economy law (AGEC law). Therefore, it is essential to ensure a level playing field in the implementation of this methodology for the whole of the European Union, both for countries with an EPR system only and countries with a dual EPR and deposit for reuse-recycling system.
- We believe that the measurement point should be set before the sorting operations, as provided by the French Agency for the Environmental Transition’s (ADEME) methodology as already explained to the European Commission. Indeed, measuring the rate after sorting operations is more likely calculating a recycling rate than a collection rate.
- We suggest that the Commission consider the declaration to EPR schemes (when available for household and industrial and commercial packaging) to define the weight of single-use bottles placed on the market. This way, there would be no ambiguity in the data and the responsibility of EPR, together with national environmental agencies, would be clearly established.
You will find attached our detailed position regarding the methodology for the determination of the weight of separately collected waste single-use bottles and the methodology for the determination of the weight of single-use bottles placed on the market.
Read full responseResponse to Environmental claims based on environmental footprint methods
31 Aug 2020
Citeo strongly welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to propose a new legislation on substantiating green claims, aiming at enhancing environmental performance of products and businesses.
Building on experience in the sector of household packaging and graphic papers, Citeo would like to share its views on the use of the PEF for substantiating environmental claims and highlight some principles which should underpin an EU approach to the provision of such claims to consumers and businesses:
✓ Regarding the policy options proposed by the Commission in its Inception Impact Assessment, Citeo recommends a mix between options 2 and 3. Citeo is in favour of an EU legal framework requiring companies to substantiate environmental claims via the Environmental Footprint methods (option 3). However, the PEF has some shortcomings that need to be addressed before considering substantiating environmental claims via this methodology. Therefore, Citeo supports using the PEF in complement to other existing tools, in the context of a voluntary framework with mandatory conditions (option 2).
✓ Citeo recommends to better assess the environmental impact of packaging, as part of the product. Citeo supports the inclusion of indirect environmental impacts of packaging related to the product in the PEF, such as the potential effects of packaging on food waste.
✓ Citeo recommends using the PEF as a B2B tool enabling companies to improve their environmental performance, and not as a B2C communication tool. However, Citeo is convinced of the necessity of developing a common European approach to what environmental information should be communicated to consumers and how.
Do not hesitate to contact us should you have any question on these :
- Axel DARUT - EU & International affairs advisor : axel.darut@citeo.com
- Charlotte PETIT - EU policy officer : charlotte.petit@citeo.com
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
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 the composition and the reusable and recoverable, including recyclable, nature of packaging.
The review of the Essential Requirements is necessary to ensure they are in line with:
✓ the Plastics Strategy’s commitment to ensure that plastic packaging is reusable or recyclable in an economically viable manner by 2030;
✓ the new Circular Economy Action Plan and the EU Green Deal which broadens this commitment to all packaging and commits to additional measures;
✓ the European Plastics Pact’s ambition to prevent and reduce overpackaging and packaging waste;
✓ the Circular Plastics Alliance which aims to increase the recycled content of new packaging.
Citeo fully endorses the EU’s vision for a packaging circular economy, urging for the material to transform from waste to economically, socially and environmentally beneficial resource. As such, Citeo endeavors for improving the circularity of all type of packaging, while also ensuring its net environmental improvement over the product’s lifecycle.
This contribution includes several elements we hope will be considered by the Commission:
✓ First, in order to support waste reduction at source more efficiently, Citeo recommends defining the concept of overpackaging with clear criteria.
✓ Then, a coherent definition of recyclability – but also compostability and biodegradability – enabling producers to produce packaging in a congruent way with the industrial technologies available, as well as with the existing collection and sorting systems in place in the different Member States, is a pre-requisite for improving the recyclable nature of packaging. Moreover, the development of eco-design, through specific recommendations developed at the packaging level and investments and supports in concrete and innovative solutions, should be supported. Eco-design can also be encouraged by eco-modulation schemes.
✓ Because authorities are taking a much greater interest in reusable packaging, we need to anticipate new framework at the EU level, especially with a clearer definition of reuse and the conditions in which any reusable packaging scheme is compliant with the internal market.
✓ Finally, in order to tackle the limited competitiveness of secondary materials from recycled packaging relative to virgin stock in view of its quality and availability, Citeo recommends several actions to support the promotion of secondary raw materials.
This contribution also aims to give a more comprehensive view of national actions in France, including the anti-waste law for a circular economy.
Do not hesitate to contact us should you have any question on these :
- Axel DARUT - EU & International affairs advisor : axel.darut@citeo.com
- Charlotte PETIT - EU policy officer : charlotte.petit@citeo.com
Read full responseMeeting with Daniel Calleja Crespo (Director-General Environment)
25 Feb 2020 · Circular economy action plan
Response to A new Circular Economy Action Plan
20 Jan 2020
Citeo has ten recommendations for the new circular economy action plan:
•Promoting the cross-sectoral dimension of the circular economy;
We believe that it is essential to recognize the complementarity of climate change and circular economy policies. To make this complementarity a reality we advocate for the creation of a “material” content into customs policy, like the “carbon” content.
•Ensuring eco-design norms;
As a pillar for eco-conception, design criteria should be developed by the packaging value chain,with a view to optimise the environmental impacts of the packaging over its life cycle while being addressed in a differenced eco-modulation regarding the maturity and the value chain of the materials.
•Promoting transparency and harmonised standards regarding the environmental footprint and material content of product and packaging;
Consumers need transparency on the environmental footprint and material content of products and need to be provided with sufficient and easily accessible information on the environmental profile of a product and its packaging.
•Promoting affordable Secondary Raw Materials (SRM) in Europe with a coherent circular fiscal system
In order to answer this challenge of competitivity between Primary and Secondary Raw Materials, we believe it is essential to move towards a more circular and ecological tax system within the Member states and at the EU level.
•Promoting an effective transition through targeted investments from the European Investment Bank.
In order to effectively promote a transition towards a circular economy, we believe that public investments should be targeted in the field of circular economy. Those investments should especially be focused on packaging and papers through the funds of the European Investments Bank.
•Promoting a coherent Secondary Raw Materials (SRM) market in Europe in line with existing regulations and legislations on chemicals;
In this regard the Commission should work on aligning existing regulations and legislations on chemicals (eg. REACH); waste and products in order to guarantee that products and packaging are exempted from substances of concerns.
•Adopting an harmonize recyclability approach at the EU level while ensuring a consistent framework on bio-based and biodegradable packaging;
The Commission needs to define in the legislative framework the notion of “recyclability” which requires a national collection, sorting and recycling stream, and the notion of “compostability” which “only” requires a proof of concept based on well-established laboratory tests. It seems important to add into the “compostability” definition criteria the existence of effective collection and composting infrastructures, at scale and in practice.
•Implementing a coherent framework on waste reduction and for an ambitious reusable system of packaging;
We believe that the implementation of a system based on waste reduction and a reusable system of packaging should be a priority. However, finding a business model ensuring a net environmental improvement over product’s life should not prevent free movements of goods and lead to a single-market fragmentation. The right balance between environmental preservation and industrial requirements to preserve the freedom principles of the Single Market has to be found.
•Supporting a more virtuous E-commerce sector;
As E-commerce is growing exponentially, the problem of similarly growing waste packaging comes along. Thus, we underline the need to reinforce consumers information’s by raising awareness on avoiding the consumer’s habits to tear up their packaging before sorting them in order to save some space.
•Ensuring a circular public procurement;
Public purchasers still lack simplified operational tools to effectively integrate circular economy aspects into their demands. It would, therefore, be desirable to develop harmonized tools at European level, in terms of circular economy criteria and life cycle anlysis.
Read full responseMeeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)
17 Oct 2018 · Single Use Plastics
Response to Reducing marine litter: action on single use plastics and fishing gear
24 Jul 2018
1. Litter Clean Up Costs. Imposing financial responsibility for litter clean-up costs on PROs will not solve littering. PROs should only be financially responsible for the costs falling within their remit and influence – however, they are willing to engage in a coordinated stakeholder approach to decrease littering.
2. Policy Coherence. In implementing major change, policy coherence and coordination across all initiatives, Directives and programmes is essential. Also, it is important to ensure that the principles established in the PPWD are not compromised or superseded by the SUP directive.
3. 90% Collection Target of Single Use Plastic Bottles. Singling out certain sections of plastic packaging is not consistent with the Circular Economy Package overall, and may lead to reduced incentives to recycle other packaging formats. In many cases the costs of trying to achieve a separate collection target of 90% outweigh the benefits.
4. EU–wide Plastics Tax. This proposed new tax is not an environmental initiative and does not complement the aims of the CEP.
Read full responseMeeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella), Heidi Jern (Cabinet of Vice-President Jyrki Katainen)
20 May 2015 · Circular Economy