The undersigned organisations fully support the policy objectives laid down in the European Green Deal to ensure that all packaging is reusable or recyclable by 2030. Striving towards these goals requires significant investments from the packaging supply chain and from public authorities.
However, we are concerned about the possible introduction of new or additional fiscal measures on packaging. We strongly believe that further fiscal measures are not the most efficient tool to drive innovation and investments that are needed to meet the intended policy objectives of the Green Deal.
Earmark revenues for waste management technologies and infrastructures
Fiscal measures on packaging materials and applications, whether at national or EU level, risk hampering national authorities’ efforts to move towards a truly circular economy and improve waste management systems across Europe.
In the absence of earmarking revenues, there is no guarantee that the resources collected through such fiscal instruments will be reinvested into better collection, sorting and recycling infrastructures needed to increase the amount of packaging that is effectively recycled.
If the EU levy on non-recycled plastic packaging waste is introduced, the undersigned organisations call for a budget equal to the expected revenues to be reinvested to support packaging circularity, including improvements in recycling technologies and waste management infrastructures at national level.
This could be done through the introduction of a supplementary and dedicated budget line in the MFF or the ‘Next Generation EU’ fund.
Prevent diversion of investments
If fiscal measures on packaging materials and applications are considered, careful design and calibration will be essential to avoid undermining industry’s ability to continue investing in more sustainable packaging solutions, recycling technologies and waste infrastructures.
This requires taking into account the costs borne by packaging users as a result of existing legislation as well as financial commitments linked to voluntary pledges across the packaging value chain.
Packaging users are already paying fees towards Extended Producer Responsibility (EPR) schemes, which are set to increase considerably, in particular under the new EU waste legal requirements to boost packaging recycling (EPR fee eco-modulation).
Support circularity while safeguarding the Single Market
If fiscal measures to incentivise circularity of packaging materials and applications are considered, they should aim to drive the increased availability of high-quality recycled materials across the EU at affordable prices to be reintroduced in the value chain.
In particular, they should encourage and reward the uptake of sustainable materials, for instance through a digressive scale or exemptions for recycled materials to enable packaging users to close the loop of circularity.
It is also essential that such measures are non-discriminatory and avoid distortions and fragmentation of the EU Single Market.
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