EUROPEN comments on circular economy package

Support minimum requirements on transparency and accountability for EPR schemes for packaging waste

Below comments should be assessed in joint consideration with our above strong calls to introduce EPR minimum requirements for packaging waste in the PPWD. Given our longstanding expertise in the packaging waste stream, our comments below regarding the EPR minimum requirements in the WFD are made in the context of packaging waste and our related specific market and value chain needs.

EUROPEN welcomes the Commission’s intention to improve the transparency of and rule enforcement for EPR schemes, which will help to avoid cherry-picking of materials and geographic scope and improve cost-efficiency among all EPR schemes. They also welcome Article 8a (5), which will facilitate full implementation and enforcement and will secure improved accountability among obliged industry, EPR schemes, waste management operators and all other actors involved in EPR implementation at national level.

EUROPEN fully supports the introduction of the net cost principle under Article 8a (4)a first indent in the WFD proposal. In order to ensure the full application of this principle, EPR schemes for packaging waste should be required to be transparent about the revenues received from the sales of secondary raw materials from their packaging. This requirement is also relevant within the context of the Circular Economy Action Plan to boost markets for secondary raw materials and there traceability. Data on secondary material pricing within EPR will serve as a measure of the economic benefit of returning materials back into the economy and as a long-term indicator for growth in this important market.