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Joint letter to VP Timmermans

May 04 2021

Dear Executive Vice-President Timmermans, dear Commissioner Sinkevičius,
The undersigned associations representing the packaging value chain are writing to you to voice their
concerns regarding the timing and resources allocated to the review of the Packaging and Packaging
Waste Directive.
Our organisations fully support the objectives of the new Circular Economy Action Plan and believe that
the upcoming revision of the Packaging and Packaging Waste Directive represents a key opportunity to
accelerate and further scale up the circularity of the EU economy. To this end, the ambitious policy goals
must be supported by robust legislation, providing a future-proof regulatory framework driving
investment in innovation and ensuring stronger enforcement and harmonisation across the EU. A lot is at
stake and the review of this Directive is too important to fail.
The complexity of the measures requires a thorough and evidence-based impact assessment. This must
be supported by a regular dialogue and effective consultations with all relevant stakeholders. We are
concerned that the limited number of planned stakeholder workshops coupled with the indicative
timeline raise the likelihood that these conditions cannot be met satisfactorily ahead of the planned
adoption of the legislative proposal by the end of this year.
Rushed decision-making processes tend to result in insufficiently defined regulatory measures requiring
further clarification through additional provisions. These are often delayed well-beyond the official
deadlines set to ensure their timely and harmonised transposition across the EU. The Single-Use Plastics
Directive and severe delays with the adoption of its implementing acts and guidelines set a concerning
precedent in this regard.
Given the breadth and complexity of the Packaging and Packaging Waste Directive review, and the
numerous legislative files being reviewed in relation to the Circular Economy Action Plan, it is essential to 2
foresee sufficient time and resources, as recently voiced by the European Parliament in its Resolution on
the New Circular Economy Action Plan1
.
We would very much welcome the opportunity to exchange views on these critical issues with you and
your services and we remain committed to support the Commission with a successful review.

ACE – The Alliance for Beverage Cartons and the Environment
AGMPM – Association of the Greek Manufacturers of Packaging and
Materials
AGVU – Arbeitsgemeinschaft Verpackung und Umwelt e.V., Germany
AIJN – European Fruit Juice Association
A.I.S.E. – The International Association for Soaps, Detergents and
Maintenance Products
AMCHAM – American Chamber of Commerce to the EU
APEAL – The Association of European Producers of Steel for
Packaging
ARA – Altstoff Recycling Austria
ARAM – Association for Packaging and the Environment, Romania
CEPI – Confederation of European Paper Industries
CICLOPLAST – Spanish Association of Plastics Transformers and
Raw Materials Producers for Promoting Plastics Packaging Recycling
CICPEN – Industrial Coalition on Packaging and the Environment,
Czech Republic
CITEO
CITPA - The International Confederation of Paper and Board Converters in Europe
Cosmetics Europe – The Personal Care Association
CPME – Committee PET Manufacturers Europe
Der Grüne Punkt
EAFA – The European Aluminium Foil Association
ECMA – European Carton Makers Association
EKO-PAK – Packaging Association, Poland
ELIPSO – Les Entreprises de l'Emballage Plastique et Souple,
France
EPTA – The European Power Tool Association
EUMEPS – European Manufacturers of EPS
EXPRA – Extended Producer Responsibility Alliance
Emballasje foreningen – Norwegian Packaging Association
EPPA – European Paper Packaging Alliance
EUPB – European Bioplastics
EuPC – European Plastics Converters
EUPIA – European Printing Ink Association
EuroCommerce
EUROPEN – The European Organization for Packaging and the
Environment
FEA – The European Aerosol Federation
FEFCO – The European Federation of Corrugated Board
Manufacturers
FEICA - Association of the European Adhesive & Sealant Industry
FEVE – The European Container Glass Federation
FoodDrinkEurope – The Organisation of Europe's Food & Drink
Industry
FPE – Flexible Packaging Europe
IK – Industrievereinigung Kunststoffverpackungen e.V, Germany
INCPEN – The Industry Council for Packaging & the Environment
Independant Retail Europe
INTERGRAF – European Federation for Print and Digital
Communication
LE - LightingEurope
Miljöpack – Packaging Association, Sweden
MPE – Metal Packaging Europe
NMWE - Natural Mineral Waters Europe
Pakkaus – Packaging Association, Finland
PCEP – Polyolefin Circular Economy Platform
Petcore - Petcore Europe
PlasticsEurope – Association of Plastics Manufacturers
Sociedade Ponto Verde, S.A. – Packaging Recovery Organisation,
Portugal
Pro Carton – European Association of Carton and Cartonboard
manufacturers
REPAK
RUCODEM – Romanian Union of Cosmetics and Detergents
Manufacturers
SCS – Styrenics Circular Solution
SEPEN – Association for Packaging and Environmental Protection,
Serbia
SZZV – Slovak Associations for Branded Products
UNESDA – Union of European Soft Drinks Associations
360° Foodservice