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Stichting CEFLEX

CEFLEX

The Circular Economy for Flexible Packaging (CEFLEX) initiative is a collaboration of almost 200 European companies, associations and organisations representing the entire value chain of flexible packaging.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

Please find attached the CEFLEX submission to the call for evidence on the Circular Economy Act.
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Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles

19 Aug 2025

CEFLEX welcomes the publication and public consultation on a draft SUPD Implementing Act on rules for calculating, verifying and reporting on recycled content. Our key messages are summarised here; please see the attachment for our more detailed feedback. The draft SUPD Implementing Act, which many CEFLEX stakeholders support, represents a good foundation by establishing credit-based mass balance as the method for calculating recycled content from chemical recycling. CEFLEX supports a fuel use exempt allocation method, but not proportional nor polymer only. The absence of clarity on how recycled content is to be calculated is a key barrier to scaling of chemical recycling in the EU. Therefore, CEFLEX calls on Member States to give a positive opinion on the draft SUPD Implementing Act and the Commission to adopt it as soon as possible. As this is the first time that such rules are being established in the EU and they are as yet untested, CEFLEX welcomes the review clause in Article 10 of the draft text. The methodology should be fit for existing and new technologies, account for technological developments and consider learnings from implementation. CEFLEX urges the Commission and Member States to prioritise enforcement of the SUPD Implementing Act, particularly through adoption of rules for verification and certification of recycled content and strengthened checks at the EUs borders. CEFLEX research indicates that a range of recycling technologies, including chemical recycling, is needed to meet legal deadlines and achieve circularity for flexible packaging. Our experience is that market forces will assure complementarity between mechanical and chemical recycling.
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Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

7 Jul 2025

Ensuring that EU policy frameworks align to enable recycling of flexible packaging at scale is essential for the flexible packaging value chain The experience of CEFLEX--the Circular Economy for Flexible Packaging initiative--is that it is currently economically preferable to divert consumer flexible packaging waste to municipal incineration / waste-to-energy or landfill, instead of recycling The exclusion of municipal incineration, waste-to-energy and landfills from the EU ETS sends distorted price signals that disincentivize recycling and reuse, undermine investments in recycling infrastructure and contradict the EUs circular economy goals By contrast, inclusion of these sectors in the ETS would correct market signals, support the business case for recycling and reinforce PPWR objectives CEFLEX strongly supports the inclusion of municipal waste incinerators, waste-to-energy and landfills in the scope of the EU ETS from 2028. We respectfully urge the European Commission to fulfil its legislative mandate by presenting a proposal in 2026 that would introduce necessary corrections to avoid distorted market signals and to provide the price incentives required for a truly circular flexible packaging economy Please see our enclosed position and joint letter for further details.
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Meeting with Aurel Ciobanu-Dordea (Director Environment) and FoodDrinkEurope and

22 May 2025 · Discuss with interested stakeholders the practical aspects and challenges of ensuring compliance with Art.5(5) of the PPWR (concerning PFAS limits in food-contact packaging)

Meeting with Elsi Katainen (Member of the European Parliament)

5 Dec 2024 · Packaging and circular economy

Meeting with Jeannette Baljeu (Member of the European Parliament, Shadow rapporteur)

20 Nov 2024 · Producer Responsibility Organisations

Response to Initiative on EU taxonomy - environmental objective

3 May 2023

The Circular Economy for Flexible Packaging (CEFLEX) initiative welcomes the EUs ambition to accelerate the transition towards a circular economy in the context of the Paris Agreement and supports the efforts of the European Commission to develop an EU-wide harmonised Taxonomy to foster investments in sustainable and circular activities. We, thus, support the establishment of clear and harmonised criteria to determine whether an economic activity qualifies as environmentally sustainable. The CEFLEX initiative is a technical collaboration of around 200 European companies, associations and organisations representing the entire value chain of consumer flexible packaging. Together, we work to make all consumer flexible packaging in Europe circular by 2025. In this regard, we provide the attached feedback on the Technical Screening Criteria (TSC) included in the draft Taxonomy Delegated Act on transition to a Circular Economy (Delegated Act). Consumer flexible packaging plays a vital role in resource-efficient food distribution and consumption. About half of primary food packaging on the EU market is flexibles (in product units). However, this accounts for only one sixth (17%) of all packaging material used for food (by weight). This efficient use of material has environmental and economic advantages , preserves food quality and safety, and prevents food waste that would result in higher overall GHG emissions than the packaging. This is why significant volumes of flexible packaging will need to remain and be recycled in a circular economy.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

The Circular Economy for Flexible Packaging (CEFLEX) initiative is a collaboration of over 190 European companies, associations and organisations representing the entire value chain of consumer flexible packaging. Together, we work to make all consumer flexible packaging in Europe circular by 2025. Separate collection: CEFLEX’s insights and analysis on consumer flexible packaging mirror the Commission’s assessment that low recycling rates are, in part, due to inefficient waste collection systems. While separate collection of flexibles is currently happening in at least 18 European countries, the results of the analysis so far indicate that there is a significant amount of what we would call ‘ready-to-recycle’ flexible packaging appearing in residual waste streams where it is unlikely to be returned to the economy and used again. As around 60% of all consumer flexible packaging placed on the market is compatible with existing recycling infrastructure operating at scale it is essential that it gets collected, sorted and recycled. As a first step, companies are using design-for-recycling guidelines to increase this amount to 80% by 2025 and eventually targeting 100% by 2030. CEFLEX would welcome the Commission’s policy options to promote full implementation of and to provide guidance on existing legislation. We would particularly highlight PPWD Article 7(4) and WFD Article 11(1), which state that Member States are obliged to set up separate collection of waste, including packaging waste. To make sorting easier for consumers and more efficient in general, CEFLEX would support a collection model for lightweight packaging which includes flexible packaging being harmonized across Europe. To prevent derogations in WFD Article 10(3) being used to exclude flexible packaging from separate collection systems, CEFLEX would suggest to assess an explicit obligation to separately collect flexible packaging. In addition, CEFLEX would suggest to assess the impact of a policy option to mandate sorting of recyclables from residual waste before disposal in landfill, incineration or organic recycling for those situations where segregation of packaging is not possible. EPR: To increase visibility of actual recycling rates for flexible packaging, it is paramount that PROs are transparent on the end-of-life destination of flexible packaging, with governments exercising oversight on PROs’ reporting to ensure they operate appropriately and comparably. Full implementation of minimum requirements for Extended Producer Responsibility schemes is needed, along with an assessment of whether they need to be strengthened to guarantee transparency and oversight. Traceability and reliable data would also help to understand actual recycling. Chemical recycling: To make flexible packaging circular, current mechanical recycling technology needs to be upgraded. In addition, chemical recycling is needed at scale to achieve virgin-like quality of plastics and satisfy safety issues for food contact materials. For this to happen clarity is needed on how output of chemical recycling will be counted towards legal targets. Coherence: Assessment of policy options for the WFD revision should include checking for coherence with other relevant legislation. In particular, upcoming changes to the PPWD need to be aligned, such as the definition of recyclable and measures on recycled content. We would also support the following additional measures by the EU and/or Member States: • improve citizen participation in separate collection • ban landfilling of recyclable packaging • establish gate fees for incineration that make the economics of sending packaging material to recycling relatively more attractive • standardised quality specifications for bales coming out of sorting operations • free intra-EU movement of flexible packaging waste for recycling Please see the attached document for CEFLEX’s detailed feedback on the WFD call for evidence.
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