The development of End-of-Waste criteria can support the EU’s transition to a circular economy. EU EoW policy must be driven by transparency and traceability, clarity and enforceability, and non-toxicity. This will enable genuine circularity, ensure high protection of human health and the environment, and support the EU’s leadership in high-quality waste-derived materials.
Rethink Plastic Alliance provides feedback on End-of-Waste Criteria for Plastic Waste
The Rethink Plastic Alliance welcomes the opportunity to provide feedback on the Commission’s draft Implementing Regulation to set harmonised End-of-Waste (EoW) criteria for plastics in the EU. Overall, we welcome the proposed EoW criteria for plastics but we urge the EU to strengthen the criteria for eligible inputs and control mechanisms to ensure genuine circularity. Our position is outlined in more detail in the attached document.
Pallet Wrappings and Straps: Exemption from the 100% Reuse Targets under PPWR
The Rethink Plastic Alliance is opposed to the exemption for pallet wrappings and straps from the 100% reuse target in the PPWR. We point out that the proposed exemption does not fulfill the conditions laid down in the Regulation, nor does it satisfy the criteria of having taken into account the latest scientific and economic data and developments. We also consider it unreasonable and non-transparent that this proposal has been made without publishing all relevant supporting documents and call for their quick publication.
The Rethink Plastic Alliance contends that the exemption should not be adopted unless it aligns with the PPWR’s conditions, is supported by recent and verifiable data, and all preparatory documents are published in a timely manner.
Furthermore, we urge the Commission to avoid proposing any further exemptions from the PPWR. In order for Member States to have a decent chance of reaching their legally-binding waste prevention targets, it is imperative that this crucial Regulation is implemented as ambitiously as possible.
Rethink Plastic provides feedback on the Circular Economy Act
The Rethink Plastic Alliance is advocating for a CE Act that truly rises to the challenge and reflects the urgent need to reduce, reuse and recycle materials. Concerningly, the Call for Evidence suggests that the Commission’s main focus is on downstream measures. While we acknowledge and support the need to improve recycling in the EU, we are calling for a CE Act that accurately reflects the waste hierarchy and therefore also includes strong measures on waste prevention and reuse, while ensuring material loops are toxic-free.
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.
Rethink Plastic provides feedback on new rules for chemically-recycled content in plastic bottles
Input to the public consultation on the draft Implementing Decision laying down rules for recycled content in single-use plastic beverage bottles, including chemically-recycled content. The proposed Implementing Decision does not comply with the principle of proportionality and exceeds the scope of the implementing power granted by the Single Use Plastics Directive.
Rethink Plastic and Environmental Paper Network’s response to the consultation on a revised EU Bioeconomy Strategy
We urge the European Commission to ensure that the revised strategy actively supports a truly circular, regenerative, and ecologically sound bioeconomy. This includes ensuring ambitious alignment with European and global objectives on packaging, ecodesign for sustainable products, and nature restoration. In particular, this new strategy must recognise the risks of unchecked expansion of bio-based material production, addressing the full lifecycle impacts of bio-based plastics and paper, and prioritising resource sufficiency, ecological resilience, and social equity over simplistic assumptions of renewability or carbon neutrality.
Scrutinising Scientific Standards
A Scientific Assessment of the JRC Study on European Sustainability Criteria for Plastics Recycling Technologies
The aim of this report is to allow for a better understanding of the full environmental impacts of different plastic recycling technologies.
Packaging and Packaging Waste Regulation Implementation: A roadmap for national & local governments to slash record levels of waste
Despite some shortcomings, exemptions and loopholes, the Packaging and Packaging Waste Regulation establishes a number of key requirements, notably on waste prevention, reuse and recyclability. It also provides many tools that governments at the national, regional and local levels can leverage to reduce packaging waste.