RPE’s reaction on European Parliament’s Non-Legislative Report on the Circular Economy Action Plan

Reusable Packaging Europe (RPE) welcomes the Non-Legislative Report by the European Parliament on the Circular Economy Action Plan. The report considers key principles for a fully circular economy, as advocated by RPE, and strongly encourages the European Commission to consistently apply the waste hierarchy in its upcoming policy initiatives.

RPE believes the report constitutes a good basis for policy action in key areas such as the sharing and circular economy, packaging and waste management and thus calls upon EU policy makers to integrate the recommendations by the European Parliament.

In RPE’s view, specific consideration should be given to the following elements in the report:

1. Consistently apply the waste hierarchy in waste and packaging legislation

An objective and consistent method of measuring environmental impact is needed to ensure the correct application of new legislation. The waste hierarchy should be applied consistently, both in formulating harmonized circularity indicators and life cycle assessments based on objective criteria, as well as in developing specific policies for the waste and packaging sector. In line with the waste hierarchy, reuse should be promoted over recycling of products, for example by reducing the layers of packaging needed to transport products and/or by setting ambitious (reuse) targets, especially where reusable alternatives exist. Prime examples are Reusable Packaging Containers used in transport packaging.

2. Exempt RPCs for the transport of (fresh) food products from targets for recyclable content

RPE agrees that recycled content in packaging should overall be increased. However, when introducing targets, the characteristics of each type of packaging should always be taken into account and the waste hierarchy should be respected. Given its high environmental footprint and lack of reusability, single use packaging should strive for a very high percentage of recycled content.
Reusable packaging for the transport of (fresh food) products, such as Reusable Packaging Containers, should not be subject to targets given (a) its typical “reuse character” and its inherent strength in reducing packaging as a concept, and (b) the mere unavailability of sufficient single origin, pure and certified food safe regrind plastics to be able to achieve high recycled content targets within Reusable Packaging Containers.

3. Efficiently promote Product-as-a-Service models with closed loops

Product-as-a-Service models (PaaS) with closed loops, as operated by RPE’s members, save resources, reduce environmental impacts and, at the same time, ensure consumer protection and food safety. Burdensome administrative and fiscal hurdles (relating to for example VAT) on circular businesses such as operated by Reusable Packaging Container pooling organizations, manufacturers and users of RPCs hamper the free movement of goods (including (fresh) food products packed in Reusable Packaging Containers) throughout the EU and therefore hamper the realization of an EU wide circular economy. Such burdens should be reduced and/or abolished to allow for a smooth free movement of Reusable Packaging Containers across the EU, as well as within the (fresh) food supply chain.

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