CIAA : Confederation of the Food and Drink Industries of the EU

- Positions

CIAA Position on the Commission Proposal for the Revision of the Packaging and Packaging Waste Directive
COM(2001)729

13 May 2002

CIAA is the voice of the food and drink industries of the EU and therefore represents one of the most important groups of packaging users in the packaging chain.

CIAA welcomes the proposal for a revision of the Packaging and Packaging Waste Directive. It presents many strengths:

- A limited scope of revision, restricted to the review of the recovery and recycling targets. The scope of revision has to be limited to be able to respect the timeframe foreseen by the Commission (2006) to achieve these targets.
- The range-based structure for the recovery and recycling targets.
- The overall recovery target of 60-75%.
- The clarification of the definition of packaging.

CIAA views on recycling

However, there are some aspects of the proposal regarding recycling that need to be questioned.

- Overall recycling targets:
CIAA supports an overall recycling target of 50-70%. For many Member States, those targets are already very strict and will require intensive work and extensive financing efforts, especially in the timeframe foreseen by the Commission (2006). We consider that minimum levels should be realistic, achievable and proportionate to the local conditions in all Member States, as well as reasonable and affordable for accession countries.

- Specific material targets:
CIAA is in favour to keep the current structure of the Directive and have a single minimum recycling target common to all materials. Such a target could be increased to 20% for all materials, provided that chemical recycling for plastic is included.
Differentiated targets per material on EU level are not feasible because of the strong differences in the market and infrastructure of the various Member States and the wide divergence of recycling performance to date across the EU.

CIAA admits the necessity to launch a dialogue on issues such as prevention, producer responsibility or reuse.

This should be done in the long term, in the context of the 6th Environment Action Programme and the thematic strategies on recycling and sustainable management of resources. These discussions, however, should not delay the revision of the recovery and recycling targets as foreseen in the Directive 94/62.