EUROPEN comments on circular economy package

Support harmonised though clarified calculation method for ‘preparing for re-use’ / recycling targets for packaging

EUROPEN welcomes the proposed harmonised method for calculating ‘preparing for re-use’/recycling targets. Robust measurement and accurate reporting will be crucial to ensure transparent and comparable data across the EU. The PPWD proposal rightly establishes the point of measurement for packaging recycling as the point of input to a final ‘preparing for re-use’ or recycling process, after sorting operations have been completed. The option to count output from sorting operations under certain conditions is fully consistent with this measurement approach.

EUROPEN welcomes the formula proposed in the PPWD Annex IV, though the definitions in the proposed ‘preparing for re-use’ calculation method (PPWD proposal Annex IV) should be clarified. For instance, in contrast to other waste statistics, Eurostat’s data on “packaging waste generated” does not mean the amount of “packaging collected” but rather all packaging “placed on the market” and Annex IV should reflect this reality5.

In addition, EUROPEN believes that Member States without EPR schemes for packaging waste must also be required to ensure that their packaging waste management systems deliver results in an enforceable, transparent and accountable manner entirely consistent with the EPR minimum requirements for packaging waste.