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SOCIEDADE PONTO VERDE - SOCIEDADE GESTORA DE RESÍDUOS DE EMBALAGENS, SA

SPV

A Sociedade Ponto Verde, entidade sem fins lucrativos, tem como missão organizar e gerir a retoma e valorização dos resíduos de embalagens, através do Sistema Integrado de Gestão de Resíduos de Embalagens (SIGRE).

Lobbying Activity

Response to Circular Economy Act

5 Nov 2025

Sociedade Ponto Verde (SPV), Portugals licensed Producer Responsibility Organisation (PRO) for packaging welcomes the Circular Economy Act (CEA) as an opportunity to make EPR systems performance-based and outcome-driven. SPV is fully aligned with the objective of reducing unnecessary administrative burdens while maintaining high environmental ambition. For the CEA to succeed, it must: (i) Strengthen EPR principles, (ii) Ensure simplification without shifting costs unfairly, (iii) Provide stronger EU oversight of national implementation, (iv) Create a coherent, harmonised framework that accelerates circularity across the single market, (v)Guarantee the enforcement of EU legislation to all in equal terms, preventing free riders. 1. CEA should ensure effective and harmonised EPR enforcement across the EU, by: (i) Banning the possibility of State-run PROs, since it jeopardizes the principle of producer responsibility, and ensuring all PROs comply with the same minimum requirements. (ii) Require that fees due by PRO to operators responsible for waste collection and sorting are transparent, cost-based and earmarked to proven collection and sorting results. (iii) Ensure producer representation and consultation in PRO decision-making. (iv) Reinforce EU-level oversight and enforcement of EPR implementation. (v) Establish mechanisms to address free-riders. 2. CEA should cut duplication and simplify reporting through EU-wide harmonisation, by: (i) Reporting by Member States: Introduce harmonised criteria of data reporting for Member States, enabling data comparison and assessment of results. (ii) Registration of Producers: Introduce a unified digital platform, interoperable across Member States, for the registration of producers, providing a unique registration number for producer despite the number of Members States territories where the producer makes available the product. (iii) Reporting by Producers: Guarantee one-stop reporting (meaning once data is submitted to PROs, it should not be duplicated to public authorities) and harmonised reporting criteria within Member States (meaning the information required and how it is reported is the same in all Member States). (iv) Provide clear, EU-wide rules for authorised representatives, allowing non-EU producers to appoint one representative for the entire EU, while EU producers may directly interact with PROs. 3. CEA should link municipal performance to funding to close national implementation gaps, by: (i) Promote performance-based compensation frameworks for municipalities, ensuring financial transfers are linked to measurable results. (ii) Require transparent methodologies for setting fees due to municipalities by PRO. (iii) Encourage national best practices through EU monitoring and benchmarking. 4. CEA should boost the EU market for secondary raw materials through harmonised standards and incentives, by: (i) Prioritise harmonised EU standards for quality, traceability, and certification of secondary raw materials. (ii) Avoid duplicating or diverging from PPWR obligations (e.g. recycled content targets). (iii) Promote fiscal incentives such as reduced or zero VAT for recycling services and secondary raw materials, as well as circular economy tax credits. (iv) Remove barriers to intra-EU waste shipments for recycling, especially for pre-consented facilities. 5. CEA should promote invest in collection and sorting infrastructure to accelerate circularity, by: (i) Harmonise separate collection rules. (iii) Encourage Member States to invest in advanced sorting infrastructure. 6. CEA should improve data reliability and transparency through EU-wide digitalisation, by: (i) Establish interoperable EU-wide reporting tools. (ii) Ensure consistent methodologies for data collection and waste composition analysis. (iii) Encourage transparency of results, with annual progress reporting at both EU and national level.
Read full response

Meeting with Caroline Callens (Head of Unit Regional and Urban Policy)

2 Jun 2025 · Exchange of views on the efficiency of waste management in Portugal, targets to be met and possible reforms.

Meeting with Aurel Ciobanu-Dordea (Director Environment)

27 Mar 2025 · Exchange of views on the Extended Producer Responsibility (EPR) system in Portugal and recycling targets under the Waste Framework Directive and Packaging and Packaging Waste Regulation

Meeting with Ana Vasconcelos (Member of the European Parliament)

27 Mar 2025 · Waste framework in Portugal

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

19 Jul 2023 · Proposal for the Packaging and Packaging Waste Regulation and extended producer responsibility

Meeting with João Pimenta Lopes (Member of the European Parliament, Shadow rapporteur)

29 Mar 2023 · Embalagens e resíduos de embalagens, alteração do Regulamento (UE) 2019/1020 e da Diretiva (UE) 2019/904, e revogação da Diretiva 94/62/CE