With reliable guidance by the European Commission towards an innovative circular economy for packaging materials

Position paper by Der Grüne Punkt on the draft for the EU Packaging and Packaging Waste Regulation (PPWR)

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By adapting the EU Packaging and Packaging Waste Directive into a regulation and thus providing reliable specifications and optimized legal certainty, the European Commission is paving the way for innovative and new endeavors within the value chain for packaging materials. As a pioneer in holistic plastics recycling, Der Grüne Punkt welcomes the European Commission's vision to optimize the circular economy, especially for plastics, by providing strong impetus for recyclability and usage of recyclates.


In all legal regulations, our principle is that effort and benefit must stand in a healthy balance. Der Grüne Punkt rejects administratively burdensome requirements, such as the proposed classification of the recyclability of packaging material into five different categories. This approach would impose a disproportionate burden on both producers and regulators. The approach of the German "Minimum Standard for Recyclability" is much leaner and still provides a reliable definition of recyclability that allows further innovations. Combined with the recycling fund proposed by EPR providers, through which financial impulses for improved recyclability as well as the use of recyclates are generated, obligated producers have an attractive and target-oriented model at their disposal for implementation.


Der Grüne Punkt welcomes mandatory use quotas for recyclates - also for contact-sensitive packaging. This is the only way to achieve a true circular economy. Der Grüne Punkt also calls for a clear legal framework for the chemical recycling of packaging materials: this will provide the much-needed impetus to increase both the quantity and quality of recyclates for packaging materials, especially for food.


Der Grüne Punkt also vehemently opposes the fact that the long-established funding symbol "Der Grüne Punkt" is listed by the European Commission as a potentially misleading eco-label in the draft for the EU Packaging and Packaging Waste Regulation. This specific mention is not only an unlawful discrimination against Der Grüne Punkt and its partner organizations but also not in line with the European Commission's own guidelines.


In order to make the proposed draft for the EU Packaging and Packaging Waste Regulation feasible for all stakeholders, adjustments need to be made to bring effort and benefit into a better balance. These do not change anything in the further course of the existing system, in which all suppliers who bring packaged goods into circulation should be obliged to participate in an EPR system and pay a corresponding minimum contribution - however, documentation and verification obligations would be reduced, especially for small and medium-sized enterprises.


The exact wording of the statement can be downloaded here.


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