Rethink Plastic provides feedback on the Environmental Omnibus

Input from the Rethink Plastic alliance on the Commission’s initiative to simplify and streamline administrative requirements related to the environment in the areas of waste, products, and industrial emissions.

The priority for the Rethink Plastic alliance is to ensure that the policy measures devised under this simplification initiative do not undermine the environmental objectives pursued by the legislation
in question. We acknowledge and strongly welcome the statement in the Call for Evidence that the
goal is not to lower the EU’s environmental objectives or the protection of human health granted by
EU environmental laws.

However, we are concerned that removing certain databases or reporting obligations would indeed
have such a negative impact, and we wish to stress the importance of maintaining existing
obligations that meaningfully contribute to the EU’s high standards of environmental protection. In
this regard, we detail why it is important to maintain reporting obligations related to the SCIP
(substances of concern in products) database, under the Waste Framework Directive, and the
Waste Shipment Regulation.

At the same time, we are supportive of targeted simplification and harmonisation in cases where it
is clear that fragmentation across Member States is resulting in major inefficiencies and when
targets have proven to be ineffective. To this end, we make concrete recommendations for
targeted simplification of certain EU rules, namely rules related to Extended Producer
Responsibility (EPR) and the EU Landfill Directive.