Our industry shares the ambitious objectives of the EU Green Deal and Circular Economy Action Plan 2.0 and is fully engaged in taking action to bring packaging sustainability to the next level. For that to happen, we need a corresponding supporting regulatory framework to help us drive this change further. Over the past years, we have been actively engaging with DG Environment on the revision of this key piece of legislation, sharing our best practices and offering solutions to make this proposal both environmentally and economically successful. Yet despite our efforts, most of our key recommendations for ensuring food and products are adequately protected have not been taken on board. We therefore question whether the proposal is consistent with the ‘Better Regulation’ imperatives, principally whether an ‘evidence-based approach’ has been employed and whether the ‘evaluate-first’ principle has been met. We also believe that the ‘cost-effectiveness’ of various impacts and the ‘proportionality’ of key provision have not been adequately evaluated.
The current approach will lead to a regulatory environment that will be unworkable at best and crippling for whole sectors of the European industry at worst, from agriculture to machinery and from food processing to pharma and cosmetics to electronics, just to name a few, with significant risks of disruptions in many EU supply chains and for our trade flows. By dismissing the key role of recycling to achieve packaging circularity, it would paradoxically serve to make it harder to convert waste into viable, secondary raw materials that can be used in the market, setting back the cause of recycling while jeopardising millions of jobs and billions of euros of investments precisely at a time when Europe needs resilient and sustainable growth. For many companies, whether packaging manufacturers or users, especially SMEs, the impact of this proposal is not only unsustainable, but also existential. (...)
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Joint industry statement from the Packaging Value Chain