While EuRIC recognises the progress made towards enhancing packaging circularity, we emphasise the need for additional steps to further these efforts within the EU.
The Council’s negotiating position, maintaining the Commission’s proposal for packaging waste reduction targets, and allowing Member States to introduce their own, higher waste prevention targets, is a step forward. Concerning the 2030 and 2040 reuse targets, EuRIC strongly welcomes the exemptions for cardboard packaging and highlights that packaging with high circularity performance should also be exempted from reduction and reuse targets.
Regarding recycled plastic content targets, EuRIC welcomes the maintenance of the 2030 and 2040 targets but urgently requests greater clarity on the provisions for bioplastics. We maintain a strong stance against mixing biobased plastic feedstock with recycled content targets. We particularly endorse the Council’s decision to prevent prioritised access to recycled materials for certain producers, thus safeguarding market fairness and recycling industry competitiveness.
However, EuRIC strongly regrets the deletion of Article 7 (6) on eco-modulation based on recycled content in packaging. Acknowledging recycled content levels in packaging is essential for increasing the EU’s packaging waste recycling. It is imperative that this consideration be made mandatory across all the EU27, ensuring harmonised criteria throughout the internal market.
In the case of recyclable packaging, EuRIC regrets the watering down of the definition of recyclability at scale, based on 30-55% recycling rates. Concerning the Deposit and Return System (DRS), while we appreciate the flexibility given to Member States with the 78% obligatory collection rate exemption, we firmly believe in the necessity of setting separate collection rates for all packaging materials to increase collection.
As we approach the first trilogue in January 2024, EuRIC reiterates its commitment to working closely with all stakeholders to ensure that the final text not only provides all the key enablers for a circular economy, but also addresses key concerns for the recycling industry.
