Eunomia is currently working on behalf of DG Environment, European Commission on the revision of the Packaging and Packaging Waste Directive and in particular on the topic of recycled content in packaging applications.
EuPC contributed to the proposal on Recycled Content Targets by giving some comments.
Regarding the objectives set for 2040, EUPC called for an evaluation of the situation to be carried out in 2030 based on the status quo of recycled content quotas at the time.
EUPC made clear that adding any other plastic product/group/categories to the targets'list is truly a case-by-case scenario.
EuPC suggested differentiations between rigid and flexible packaging. EuPC called for considering the technical specificity while designing technical provisions.
EUPC also asked to foresee a differentiation between primary, secondary and tertiary packaging.
To conclude, EUPC highlighted that an unique approach cannot be put in force. Indeed, if a minimum recycled content target needs to be implemented, an approach based on a sound impact assessment while carefully considering possible unintended consequences has to be taken.