Essential Requirements and Extended Producer Responsibility Fee Modulation for Packaging to Meet the Objectives of the European Circular Economy Strategy

 Europe has a large and growing packaging footprint – both in the consumption of packaging and the generation of packaging waste.

This discussion paper is to be discussed amongst relevant stakeholders to issues around packaging and packaging waste. It is an early contribution to the debate. 

The key strengths of the proposals are: 

● Implementing the waste hierarchy: promoting technology which is higher in the waste hierarchy with access to more modulation possibilities (which may de facto mean that a packaging solution has interest to apply for the most rewarding scenario e.g. in case a compostable material which is also recyclable, it will prefer going for the recyclable scenario as it has the potential to benefit from more modulation options) 

● A simple criteria based model: a dynamic system organised around a limited set of key criteria defined at EU level, clearly more enforceable than current standards, and with systematic requirements for quantitative and qualitative prevention as well as separate collection; 

● Neutrality with regards materials and technology: to allow different packaging technologies to develop irrespective of their material. 

● Supporting high quality secondary markets for packaging: to help promote and stabilise a market for recyclates, as well as a more transparent system with regards chemicals contents supporting toxic free and high quality supply chains. 

● Using EPR fee structures and revenues as an instrument to incentivise system change, pulling packaging design towards waste prevention and providing investments through a “Fund for Change”