The content of the letter is below:
To:Frans Timmermans, Executive Vice-President in charge of the European Green Deal
Thierry Breton, Commissioner for Internal Market
Didier Reynders, Commissioner for Justice Virginijus Sinkevičius,
Commissioner for Environment, Oceans and Fisheries
24 June 2021
Joint industry call for an EU approach to packaging waste labelling
Dear Executive Vice-President Timmermans,
Dear Commissioner Breton, Dear Commissioner Reynders, Dear Commissioner Sinkevičius,
The undersigned organisations call on the Commission to take urgent action to ensure a common approach for packaging waste-sorting labelling to preserve the free movement of goods within the EU and underpin sustainability measures. As representatives of the packaging industry and consumer product manufacturers, we fully endorse the need for improved waste collection and sorting to support the transition towards a circular economy. Providing relevant and consistent information to consumers on how to properly dispose of both the products and their packaging is essential to enhance collection rates and improve the quality of the material collected.However, in the course of the last year we have been confronted with a concerning trend of divergent national packaging labelling and information requirements.
This is not only counter to the work underway at EU level of moving towards greater harmonisation of waste collection and sorting, but it is inevitably resulting in major Single Market disruptions and, in turns, undermining Europe’s sustainability goals.These national labelling and information requirements force companies to create several iterations of their packaging to comply with them or to use stickers to add or cover certain markings. In addition to costs and operational impacts on production lines, these national measures can also have a negative impact on the size of packaging and its recyclability and can further confuse consumers. These concerns have recently been raised by Members of the European Parliament, who have questioned the European Commission about a harmonised approach to labelling across the EU.
The current review of the Packaging and Packaging Waste Directive (Directive 94/62/EC) represents a great opportunity to set common requirements on which information should be provided to consumers and how this should be done, including the use of digital solutions that can help provide required information without the need to increase packaging size or repackage. In parallel, the work initiated by the Commission to harmonise separate waste collection and sorting, as required by the Waste Framework Directive (Directive 2008/98/EC), will be key to the effectiveness of harmonised labelling requirements.
These developments, however, will take time to see the light and produce concrete outcomes. In the meantime, therefore, concrete and urgent action is needed to halt the proliferation of unilateral and divergent national measures. The Commission, as the guardian of the Treaty, must ensure full compliance with the free movement of goods’ principles and take decisive action to prevent or address disproportionate or unjustified measures on unilateral packaging labelling, which undermine the integrity of the Single Market for packaging and packaged goods and the transition towards more sustainable packaging solutions.
This also implies ensuring a timely and constructive cooperation on the part of Member States in resolving any Single Market incompatibilities raised by their national measures, failing which the Commission should make full use of the powers attributed to it by theTreaty to ensure the respect of its decisions.We would welcome the possibility for a delegation of the undersigned organisations to meet with you and discuss in more detail the concrete impacts that these national measures are having on so many economic and industrial sectors and on European consumers.
Yours sincerely, The undersigned organisations
Annex I - Examples of divergent national labelling initiatives which risk undermining the Single Market and hampering the intended sustainability goals
Annex II - Question for written answer to the European Commission - Harmonisation of the SingleMarket on product labelling standards
Helena Braun – Cabinet Member Executive Vice-President Timmermans
Pauline Weinzierl – Cabinet Member Commissioner Breton
Bénédicte Van Ormelingen – Cabinet Member Commissioner Reynders
Rozalina Petrova – Cabinet Member Commissioner Sinkevičius
Kurt Vandenberghe - Cabinet Member President Von der Leyen
Anthony Whelan - Cabinet Member President Von der Leyen
Ilze Juhansone - Secretary General
Alvydas Stancikas – Director Single Market Enforcement (GROW.E)
Salvatore D’Acunto – Head of Unit Enforcement II (GROW.E.2)
Nils Behrndt – Director Consumers (JUST.DDG.E)
Daniela Bankier – Head of Unit Consumer Policy (JUST.DDG.E.1)
Kestutis Sadauskas - Director Circular Economy and Green Growth (ENV.B)
Mattia Pellegrini – Head of Unit Waste Management and Secondary Materials (ENV B.3)
The full document with annex and list of signees an be downloaded below.
Outdoor businesses are already acutely aware of these issues and unfortunately, there are no simple solutions. Those organisations with well-established and robust business continuity plans are probably best equipped to deal with these problems, but even some of them are struggling right now.