European Recycling Platform SAS
ERP SAS
Manage compliance of Extended Producer Responsibility (EPR) obligations for producers via 40 PROs in 18 countries globally, inclunding Europe for WEEE, batteries, packaging and textiles.
ID: 194953315534-56
Lobbying Activity
Meeting with Pietro Fiocchi (Member of the European Parliament)
27 Nov 2024 · Packaging
Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
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 field for all actors involved in the pre- and post-consumer phase of packaging. While the proposal is a step in the right direction, several aspects need to be reviewed and shortcomings need to be addressed, as we explain in the paper attached.
Read full responseResponse to Waste Electric and Electronic Equipment
4 Apr 2023
European Recycling Platform (ERP) welcomes the opportunity to comment on the European Commission's proposal for a Directive amending the Waste Electrical and Electronic Equipment (WEEE) Directive to address the implications of the European Court of Justices judgment (Case C-181/20) on the financing of the collection and treatment of WEEE from users other than private households. We fully support the clarification of when and by whom the take-back of solar PV modules must be financed, including the distinction between B2C and B2B. However, we would welcome the opportunity of the revision to clarify other aspects relating to the specificities of the solar PV market. We explain what these aspects are in the attached paper, drawing on our experience in operating several take-back schemes for WEEE across the European Union.
Read full responseResponse to Evaluation of the 2012 Directive on waste from electrical and electronic equipment
3 Nov 2022
European Recycling Platform (ERP) welcomes the current evaluation of EU rules on waste electrical and electronic equipment (WEEE) and would like to thank the European Commission for the opportunity to contribute to the ongoing call for evidence. As operator of producer responsibility schemes for WEEE in 12 European countries, we know the challenges related to the implementation of the WEEE Directive and are happy to share our experience and ideas on how to improve the framework for it to better deliver on its goals. In the attached paper, we focus on the following aspects: 1. Calculation of collection rates 2. Awareness raising campaigns 3. Modulation of fees 4. Central supervising entity 5. Enforcement
Read full responseMeeting with Malte Gallée (Member of the European Parliament, Shadow rapporteur) and European Coordination Committee of the Radiological, Electromedical and healthcare IT Industry
21 Apr 2022 · Batteries Regulation (staff level)
Response to Waste Framework review to reduce waste and the environmental impact of waste management
22 Feb 2022
European Recycling Platform (ERP) welcomes the Commission’s initiative to revise the Waste Framework Directive (WFD) and would like to thank them for the opportunity to contribute to the ongoing stakeholder consultation. Given our expertise and years of experience in operating producer responsibility organisations (PRO) for waste electrical and electronic equipment, batteries, and packaging in 13 European countries, we would like to draw attention to some aspects that, in our view, need to be addressed in the revision. With our comments, we focus mainly on the extended producer responsibility (EPR) provisions in Articles 8 and 8a of the current WFD:
• Modulation of financial contributions: The revised WFD needs to address the necessary harmonisation of the modulation criteria;
• Waste management targets: The revised WFD should require that collection targets are to be calculated according to the available for collection principle and that all collection volumes, including so-called parallel flows bypassing PROs, count towards the PROs’ collection targets;
• Equal treatment of producers: While fully supporting the polluter pays principle, we suggest that PROs are allowed to charge a minimal flat fee covering fixed administrative costs;
• Incentives for waste holders: In order to increase collection results, the WFD should rather focus on an enhanced enforcement by national authorities combined with continuous and suitable communication towards consumers;
• Publicly available information: The revised WFD should make sure that information requirements are in line with national competition regulations;
• Necessary costs: The WFD should ensure cost-effectiveness by promoting competition-based EPR and avoiding single-PRO setups;
• National body independent of private interests: Any markets, including those with just a single PRO, should be required to appoint such a body;
• Minimum treatment standards: The revised WFD should require Member States to define and agree on harmonised minimum standards to be followed by all actors involved.
More information can be found in the attached position paper.
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
27 Oct 2021
European Recycling Platform (ERP) very much welcomes the initiative towards a clear EU policy framework on biobased, biodegradable and compostable plastics. Based on our experience in operating producer responsibility organizations for packaging, WEEE and batteries in 13 countries, we strongly agree that there is an urgent need for regulation on the use and labelling of these materials.
Biobased materials could support a more sustainable sourcing and reduce the dependency on fossil resources. However, it is necessary that these materials are clearly identifiable by automatic processes, e.g. via suitable markers or coding. Only this would allow for their proper separation and treatment in an own process as long as biobased materials are not fully compatible with the entire plastic waste management chain resulting in a mixed stream of fossil based and an increasing volume of renewable plastics. Otherwise, the quality of plastic recyclates is endangered in worst case leading to a thermal recovery of those mixed materials only.
The identification of biodegradable and compostable plastics is even more important as those materials are not supposed to be treated in material recycling processes but in biological processes at home or on industrial level. Separation of these materials is of utmost importance since they are not compatible with material-based recycling processes (based on today’s knowledge). Ideally and when arising as waste, biodegradable and compostable plastics are immediately segregated by consumers disposing those into the right collection channel for biotreatment (biowaste or home composting). This needs to be supported with a clear and fully harmonized labelling as well as related awareness raising campaigns. Moreover, and as it can’t be assured that consumers sort their waste correctly, also biodegradable and compostable plastics need to be identifiable by automatic processes in order to avoid that they disturb the recycling processes of fossil based and biobased plastics.
As this policy framework is developed in parallel to the already ongoing revision of the packaging directive, which aims to address the matter of compostability as well, it is important to align the two processes avoiding confusion of consumers. For example, criteria and markings of products and packaging, that are supposed to guide consumers to treat those in a bio-waste infrastructure, need to be fully aligned.
Finally and going beyond the EU waste framework directive’s Article 8a, some countries (e.g. Germany for packaging) started to define the “use of renewable materials” as one criterion for the EPR eco-fee modulation. Those initiatives addressing design aspects shall be considered as well aiming for a fully harmonized European approach not disturbing the single market.
More information on ERP can be found here: https://erp-recycling.org/.
Read full responseResponse to Modernising the EU’s batteries legislation
1 Mar 2021
European Recycling Platform (ERP) very much welcomes the European Commission’s proposal for a new Batteries Regulation and its overall objective to promote a competitive, circular and sustainable value chain for batteries in Europe. We appreciate the huge effort that has gone into this proposal and the ambition to reflect both the latest market and technology developments and the latest amendments to general waste legislation. With this paper, ERP would like to share some of its practical experience in operating producer responsibility organizations (PRO) for batteries in 12 countries and to make some proposals for amendments in order to ensure the Regulation can fully deliver on its objectives.
In a nutshell, we would like
• to ask for a specification of the definition of “portable batteries” in order to avoid overlaps with electric vehicle batteries, in particular when it comes to batteries in vehicles such as e-bikes and scooters;
• to ask for a specification of the definition of “industrial batteries” in order to assure that only battery types exclusively designed for industrial purposes are covered by the definition;
• to propose a more realistic approach for the collection targets for waste portable batteries considering the amount of waste portable batteries available for collection, thereby taking into account aspects like the increasing lifetime of batteries and exports;
• to propose abandoning the opportunity to revoke a PRO’s authorization when missing a fixed collection target as the collection rate alone is not a fair indicator for a PRO’s collection performance but must consider overall market circumstances;
• to propose requiring final users to hand over their waste batteries to producers or PROs, in order to avoid parallel flows and to ensure that all batteries available for collection find their way to those actors held responsible for collection; and
• to propose implementing effective enforcement measures for chapter VII incl. ideally cross-border means to ensure compliance with and of EPR schemes and to combat free-riding.
In the attached paper we provide further and more specific comments on the proposed provisions of this Regulation. For the sake of clarity, we structured our remarks and proposed amendments in a way that corresponds to the Articles of the Regulation.
Read full responseResponse to Revision of EU rules on food contact materials
27 Jan 2021
European Recycling Platform (ERP) welcomes the European Commission’s initiative to revise legislation on food contact materials (FCM) and the publication of the inception impact assessment.
As pan-European producer responsibility organisation (PRO) for packaging, batteries, and electrical and electronic equipment, we have helped to implement EPR in several countries of the European Union and beyond and operate at the very interface between producers, consumers, waste collectors, and recyclers. We know the challenges associated with increasing reuse and recycling of food packaging and with promoting more sustainable alternatives, and, therefore, fully agree with both the objectives and policy options proposed in the inception impact assessment.
With the attached paper, we want to encourage the European Commission to maintain the path it has taken and to put forward a corresponding proposal for a regulation. We also want to share some additional thoughts on the matter based on our long-term operational experience and expertise.
Read full responseResponse to Update of concentration limit values of persistent organic pollutants in waste
3 Aug 2020
Producer responsibility organisations like European Recycling Platform (ERP) are managing the collection and treatment of waste streams like WEEE on producers’ behalf and, therefore, are heavily affected by the above-mentioned provisions.
ERP agrees to the preliminary assessment that lowering Annex IV values of Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs) from their current baselines will result in greater amounts of WEEE becoming unavailable to be recycled and instead being diverted to disposal operations, in most cases incineration.
Lowering the sum values to 500 mg/kg of PDBEs in EEE would jeopardize the fulfilment of the European Union’s recycling targets for WEEE. This would contradict all the action that was taken during the last years and would drastically throw back the European Union on its way towards a Circular Economy.
Read full responseResponse to Modernising the EU’s batteries legislation
3 Jul 2020
European Recycling Platform (ERP) welcomes the European Commission’s plans to modernise the European Union’s batteries legislation in order to reflect latest market and technology developments, to address the lack of definitions, and to align it with the latest amendments to general waste legislation. We also welcome the idea to change the legal character of the provisions from a directive to a regulation in order to ensure the highest possible level of harmonisation across Member States.
In the attached paper, ERP shares some of its practical experience in operating producer responsibility schemes for batteries in 13 countries and provides feedback on some of the ideas and possible measures proposed by the European Commission so far, especially with regard to:
1. Scope of extended producer responsibility
2. Awareness raising and density of collection points
3. Battery marking
4. Collection targets
5. Control and auditing system for the recycling of batteries
6. Calculation method for recycling rates
Read full responseResponse to A new Circular Economy Action Plan
17 Jan 2020
European Recycling Platform (ERP) very much welcomes the European Commission’s ambitions with regard to pushing the circular economy and would like to thank for the opportunity to comment.
With this input we want to share some of the experience and expertise we gained over the past 20 years as pan-European Producer Responsibility Organisation for waste electrical and electronic equipment (WEEE), batteries and packaging, and draw attention to some aspects that we feel should be taken into account when further specifying the action plan.
With regard to the goal of including a sustainable product policy and of prioritizing reuse and repair before recycling, we would like to point out the following:
• Make sure that all sales of secondary goods are counted as reuse in the national and European Union statistics in order to get a more realistic picture and to promote second-hand markets to create a bigger market, as already today significant amounts of goods are sold as second-hand e.g. via web-based platforms (confirmed by the recent JRC study “Identification and assessment of opportunities and threats for the Circular Economy arising from E-commerce”);
• Evaluate different collection practices to allow for product reuse or parts harvesting, which would be much more expensive, but might still be acceptable if reused products/parts would be reasonably cheaper than new products – also requiring a change of consumer perception on used goods;
• Review applicable compliance legislation for secondary products which change waste status back to product status, such as chemical legislation, EMC, guarantee etc. (today they need to follow the same rules like new products);
• Evaluate the overall contribution of a well-controlled and certified export of products/parts for reuse or repair to third countries, utilizing different consumer preferences and lower labour cost, but without dumping waste to developing countries; this is related to the planned review of the Waste Shipment Regulation (see below).
With regard to the planned review of the Waste Shipment Regulation and while we agree that longer-distance shipments of waste should be avoided and, therefore, support the goal of increasing the amount of waste treated domestically, collectors/recyclers should nevertheless be able to ship waste within the European Union to the most efficient and environmentally sound treatment place avoiding unnecessary investments.
ERP also supports the goal of fostering a well-functioning and integrated internal market for secondary raw materials. We would like to point out the necessity to harmonise quality standards for secondary raw materials, particularly for plastics, in order to foster demand. The competitiveness of recycled materials can be further increased by phasing out subsidies for virgin materials. On top of that, landfilling and incineration of recyclable materials should be phased out. It can be also reasonable to foresee targeted R&D budgets to research on better sorting practices including fast analytics of substances in waste linking it to the ECHA SCIP database.
With regard to the goal of addressing other high-impact sectors such as textiles and construction, we would like to stress that the principle of extended producer responsibility (EPR) has proven over the years to be very effective to collect and recycle and we recommend an extension of this principle to those. We also support the review of the packaging essential requirements towards more recyclability and use of recycled materials and the additional attention to bio-based and biodegradable plastics possibly adjusting sorting and recycling practices.
With regard to the mentioned need to mobilise all value chains state subsidies for linear business models should be redirected to innovative circular businesses and to research and development with regard to waste prevention, recycling technologies, digitalization and information flow.
Read full responseMeeting with Daniel Calleja Crespo (Director-General Environment)
6 Jul 2018 · Package Waste Directive
Response to Reducing marine litter: action on single use plastics and fishing gear
11 Jan 2018
The European Recycling Platform (ERP) welcomes the initiative of the European Commission to tackle the leakage of single use plastics into the environment and to reduce the negative economic and environmental impacts arising from that.
As set out correctly in the inception impact assessment document, the leakage of plastics is indeed a global problem, especially when it comes to marine litter. ERP would therefore strongly encourage the European Commission not only to tackle this problem on the European level, but also to advocate on the international level for a global approach and to persuade other countries to impose waste reduction and educational measures similar to those in existence in Europe. This could be done by referring to the positive impact the introduction of producer responsibility schemes and broad educational programs in the European Union had on both the environment in terms of higher recycling rates and on consumers in terms of lower prices.
Regarding the measures proposed in the inception impact assessment document, ERP agrees that improving the collection rate of items that are already captured in collection schemes is one of the most effective ways to reduce plastics leakage into the environment. This could be achieved e.g. by increasing recycling targets and strengthening the principle of extended producer responsibility (EPR) as proposed in the files of the Circular Economy Package currently being negotiated in the trialogue. The implementation of EPR should be organized in a competitive environment following clear conformity requirements. This triggers innovation and high quality processes leading to environmental benefits and resource efficiency while aiming for reasonable cost to the consumer.
However, in order to be fully effective, these measures need to be correctly transposed into national law and to be strictly enforced by Member States assuring a level playing field and compliance of all parties.
Complementary, the principle of extended producer responsibility should be applied also to plastic items that are not yet captured in collection schemes in order to help increasing collection of these items and reducing marine litter.
ERP, as part of Landbell Group, is the only pan-European producer responsibility organisation for packaging, WEEE and batteries. The group supports producers to implement EU waste legislation and has collected more than 7 million tonnes of packaging, more than 3 million tonnes of e-waste and more than 50,000 tonnes of portable batteries, all containing significant amounts of plastics. ERP’s extensive expertise is built upon more than 15 years of experience in operating under various national compliance frameworks.
Read full responseMeeting with Daniel Calleja Crespo (Director-General Environment)
13 Mar 2017 · Circular Economy, Waste proposal, WEEE Directive
Meeting with Daniel Calleja Crespo (Director-General Environment)
13 Nov 2015 · WEEE Directive