RECOUP Signs PPWR Policy Position Paper

Through the EPRO plastics sustainability platform RECOUP is members of, together with other organisations across the European plastics and packaging value chain, we signed a European Plastics Circularity (EPC) Coalition joint position to the European Commission on how recycled-content rules under Article 7 of the Packaging and Packaging Waste Regulation (PPWR) should be implemented.

The aim of the paper is to ensure that recycled content targets under Article 7 of the PPWR value and incentivise investment in European recycling systems, including the UK.

There are three asks to the European Commission, with point 2 relevant for the UK with only recycled content genuinely produced in the EU, EFTA and UK should count towards the targets:

• Assess equivalence at country level, not only on factory level. A single certified plant does not prove a country manages its waste in a sound, circular and equivalent manner.
• Apply clear, simple rules for what counts. Until a system-level equivalency is operational and enforced, only recycled content genuinely produced in the EU, EFTA and UK should count towards the targets, with a built-in safeguard for proven shortages. Later, recycled material from a system-level equivalent framework (annex 2) in a country can count too, provided it is recycled in an EU-equivalent installation and the recycled waste is traceable back to where it was collected.
• Make it enforceable. Real assessments, audits and real penalties, as harmonised as possible, and deterrent enough for breaking the rules to cost more than following them — so that responsible investment cannot be undercut by material that was never properly checked.

Please click here to view the letter.

If you would like to discuss this please contact Steve Morgan