Category: Position Papers

The undersigned 78 organisations, led by the New European Reuse Alliance and Reusable Packaging Europe on behalf of the reusable packaging industry as well as other civil society organisations, fully support the European Union’s ambition to reduce packaging waste and acknowledge the initiative laid down in the Regulation (EU) 2025/40 on packaging and packaging waste (hereinafter, PPWR) to introduce a label to indicate the reusability of packaging (Article 12.2). On this basis, we call for a symbol on reusability -in line with the labelling requirement laid down in the PPWR- that is clear, enforceable, and resistant to misuse from packaging that is not truly reusable. In the present statement, we outline a vision for such a symbol, including key requirements the pictogram should (implicitly) represent, enforcement mechanisms required to ensure that only genuinely reusable packaging can bear the symbol, the specific case applicable to reusable transport packaging, and suggestions for key visual criteria for a powerful reuse symbol.

Since implementing acts on the development of labelling requirements are expected by August 2026, as set in Article 12.6 of the PPWR, we would like to ensure that the reuse symbol effectively supports the EU’s circularity goals while aligning with the operational realities of all reusable packaging systems, in particular those of reusable transport packaging operating in pooling system for business-to-business (B2B) operations.

Dear Executive Vice-President Ribera,
Dear Executive Vice-President Sèjournè,

We, the undersigned coalition of circular economy trade associations, businesses, and NGOs from across Europe, are writing to express our concerns regarding the current draft of the Clean Industrial State Aid Framework (CISAF), and its notable omission of support for circularity measures.

Strategic Importance of Circularity
The Clean Industrial Deal (CID) recognises that “Circularity will be a priority. It is the key to maximising the EU’s limited resources, reducing dependencies and enhancing resilience. It reduces waste, lowers production costs, lowers CO2 emissions and creates a more sustainable industrial model that benefits the environment and enhances economic competitiveness. The ambition of the Clean Industrial Deal is to make the EU the world leader on circular economy by 2030.”

This ambition cannot be realised without appropriate financial support mechanisms, to scale-up enabling infrastructure. By placing circularity at the core of our decarbonisation strategy, the EU not only improves the affordability and accessibility of essential materials but also reduces strategic dependencies as materials are reused, remanufactured, recycled, and kept within the economy for longer.

The Case for Circularity under CISAF
While we welcome the Commission’s communication for a Clean Industrial Deal (CID) and the supporting framework provided by CISAF, we are deeply concerned that despite “Circularity and access to materials” being explicitly identified as the fourth pillar of the CID, it has not been afforded the same provisions within the State Aid Framework as other priority areas.

The draft CISAF contains provisions for the following types of aid measures:

• • Measures accelerating the rollout of renewable energy
  • Measures facilitating industrial decarbonisation
  • Measures ensuring sufficient manufacturing capacity in clean technologies
  • Measures to de-risk private investments in projects related to the previous three bullet points

However, circularity measures have been omitted in this support framework, creating a significant policy inconsistency that could hinder the sufficient availability of secondary raw materials, which undermines the CID’s stated objectives.

Our Request
We therefore respectfully urge the Commission to ensure the CISAF includes explicit provisions for Circularity measures.

Enabling state aid for projects that boost material circularity will make Europe’s industrial production more sustainable, accelerate decarbonisation efforts, and significantly enhance resource security. It is a natural and necessary step to support the CID’s objective of increasing material circularity up to 24% by 2030, ensuring resources remain in circulation for as long as possible.

As Europe strives for strategic autonomy in a resource-constrained world, we must ensure that all pillars of the Clean Industrial Deal receive equal policy and financial support. The inclusion of Circularity under the CISAF is not merely an environmental consideration but a fundamental economic and strategic imperative.

We remain at your disposal to discuss this matter further and look forward to your positive response.

Yours sincerely, 

A few weeks after the publication of its “EU Competitiveness Compass”, the European Commission presented on Wednesday February 26 2025, the first two flagship initiatives of the new mandate to strengthen the competitiveness of the European economy and ensure sustainable prosperity: the first Omnibus Package and the Clean Industrial Deal.

In its Omnibus Package, the European Commission proposes to revise key Green Deal regulations in order to foster competitivity by simplifying reporting obligations: the 2022 Corporate Sustainability Reporting Directive (CSRD), the 2024 Corporate Sustainability Due Diligence Directive (CSDDD), the 2020 EU Taxonomy regulation as well as the 2023 Carbon Border Adjustment Mechanism (CBAM).

The Business for a Better Tomorrow coalition takes note of the Commission’s proposal and supports its approach aimed at optimizing the implementation of the above mentioned sustainability regulations. However, we regret the path taken by the European Commission, which, by reopening several of these texts at level 1, undermines provisions at the heart of our future resilience and creates legal and competitive uncertainty ahead of the forthcoming negotiations in Brussels. Predictability is essential for competitiveness—EU policies must provide a stable and coherent framework that allows businesses to align their operations and value chains with the transition pathway. Many companies have already made significant investments to comply with EU obligations, and weakening these rules now would not only penalize early movers but also erode trust in the regulatory environment. Furthermore, the coalition stresses that the proposed revisions amount to a major rollback of the EU’s environmental and social ambitions, in sharp contrast with the Commission’s statement that the goals of the European Green Deal would remain intact.

Sustainability reporting and due diligence requirements empower businesses to tackle the ecological and social challenges of tomorrow  while strengthening their resilience to the risks these challenges pose. Simplification must not be a pretext for rolling back ambition—it should be a lever to drive both sustainability and competitiveness for EU businesses. We call for a swift and decisive conclusion to the discussions that are about to be reopened with the Commission, Council and Parliament, so that European businesses can thrive within a clear and harmonized framework.

We welcome the adoption of the Clean Industrial Deal by the European Commission, which provides concrete answers to the challenges facing businesses, particularly in terms of energy costs, fair competition for decarbonized products, the development of the circular economy and the need for investment in clean technologies and digital sovereignty. The adoption of these measures represents a significant step forward in boosting European industrial competitiveness. It will therefore be essential to ensure their deployment under fair and effective conditions, in line with companies’ expectations.

Simplification, supported by the Omnibus package, must be a lever for competitiveness and growth, not a renouncement of Europe’s sustainability ambitions. At the same time, the Clean Industrial Deal must create a stable, predictable, and incentivizing framework to accelerate the decarbonization of the economy and support innovation.  In this perspective, the Business for a Better Tomorrow coalition will remain mobilized to ensure that these initiatives fully meet—rather than undermine—the needs of businesses committed to ecological and social transition.

Finally, while discussions in the Competitiveness Council on March 12 indicate the possibility of including additional environmental regulations in the Omnibus process, we urge caution against reopening other critical files. Businesses require clarity and stability in existing policies to maintain their momentum in the transition.

Far from being a constraint, the transition should be a strategic opportunity to strengthen the competitiveness, innovation and resilience of European businesses.

Dear Members of the European Parliament,
Dear Representatives of the Council of the European Union,
Dear Representatives of the European Commission,

Ahead of your meeting on 4 March, where you intend to reach an agreement on the Packaging and Packaging Waste Regulation (PPWR), we urge you to agree to ambitious measures to reduce the amount of problematic, avoidable, and unnecessary single-use packaging in the EU.

We would like to reiterate our strong support for an EU-wide restriction of single-use packaging in the HORECA sector for customers who dine in. We hope that negotiators can agree to the proposals in this regard made by the European Commission in November 2022 and endorsed by the Council’s General Approach of December 2023. Please support Art. 22 together with points 3 and 4 of Annex V (“Restrictions on Use of Packaging Formats”).

The types of single-use packaging covered under these points fulfil all the criteria to be restricted:

• • They are problematic: most single-use packaging used in the HORECA sector is difficult to recycle after use and contact with food, and is often not recycled or downcycled¹.
  • They are unnecessary and avoidable: most operators in the HORECA sector offer reusable tableware to customers dining in; single-use packaging can clearly be avoided by adopting suitable operating procedures.

We would also like to draw your attention to the EU Joint Research Centre’s recent study², which assessed the environmental performance of single-use (SU) and multiple-use (MU) packaging in a dine-in restaurant case study and found that “the ‘Restaurant Scenario’ resulted in lower impacts for the MU packaging in the majority of impact categories and simulations.” This illustrative example is in line with many other life-cycle assessments and demonstrates the clear benefits of restricting single-use packaging for dine-in.

To conclude, we remind you that the EU is part of the high-ambition coalition to negotiate a global treaty to eliminate plastic pollution. In the ongoing negotiations, the EU and its Member States argue for ambitious restrictions of problematic, avoidable, and unnecessary single-use plastics. On 4 March, you have the opportunity to adopt such measures for the EU and send out a strong signal to other regions of the world. Push back against the throwaway culture and prevent unnecessary waste!

Dear Members of the European Parliament,

We are passionate entrepreneurs and write to you as part of the burgeoning reusable industry, with a clear request to seize the Packaging and Packaging Waste Regulation (PPWR) as a significant economic, ecological, and social opportunity for Europe and to ensure the following implemented:

Political urgency and climate imperatives converge with imminent EU elections. Simultaneously, a longer-term perspective involves strategic efforts for lasting positive environmental impact. The industrial landscape, operating within its own rhythm, becomes evident when confronted with transformative shifts. Within this context, the PPWR stands out as a potential transformative European milestone, aligning seamlessly with various timelines. This presents a unique opportunity window that requires immediate action before it closes for the next five years.

While recognizing the endeavors of co-legislators over the past year in navigating complex perspectives and seeking compromises among their respective institutions, the outcomes, notably in articles 26 and 22, lack the desired ambition and raise concerns due to potential loopholes. For the PPWR to genuinely address the problems it aims to solve, it must follow and align with the waste hierarchy (article 4.1 of Directive 2008/98/EC), where prevention and reuse prevail over recycling. By doing so, we can establish robust, ambitious, clear, and coherent regulations in line with the PPWR’s objectives and the EU Green Deal. Such consistency and coherence are necessary for the development of the reuse and refill industry, as well as for all stakeholders awaiting a strong signal from Europe to engage in new practices.

Below are the key points advocated by the reuse and refill industry.

Dear Executive Vice-President Séjourné,
Dear Commissioner Albuquerque,
Dear Commissioner Dombrovskis,

The Business for a Better Tomorrow coalition, representing the interests of 19 EU and national-based business networks committed to the ecological and social transition, extends its heartfelt congratulations on your respective appointments to the new College. Your leadership comes at a critical juncture for the European economy, where strengthening competitiveness, innovation, and resilience is more important than ever, alongside the need to streamline regulations. These efforts must, however, be carried out without compromising the EU’s ambitious sustainability goals.

The Business for a Better Tomorrow coalition reminds you that the regulations in question—specifically the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CS3D), and the EU Green Taxonomy—are essential pillars of the Green Deal. These regulations provide businesses with a harmonized framework that supports their sustainable transformation and long term competitiveness. They are designed to foster the emergence of a more robust, innovative economy that is capable of addressing the ecological and social challenges of tomorrow. The successful implementation of these measures will be instrumental in creating a fairer, more attractive business environment, while simultaneously solidifying the EU’s position as a global leader in sustainability.

In this context, we stress that revisiting certain provisions of these texts should not result in a reduction of their ambition or in delaying their implementation. The focus of any adjustments must be on simplification from a practical point of view, enabling businesses to achieve sustainability goals without imposing an undue burden. These improvements should focus on simplification rather than deregulation of laws, with the aim of notably facilitating compliance for SMEs by offering tailored expert assistance, technical tools in their language, and digital and AI-based solutions to streamline processes. We also advocate for a systematic review of new regulations to ensure their consistency, harmonization, and simplicity, particularly in sectors that are highly exposed to competition.

Simplification must streamline processes, not dilute objectives. By removing unnecessary barriers, clarifying requirements, and considering the practical realities faced by businesses, these regulations can become more actionable. Moreover, it is vital to recognize the early movers—companies that have already taken proactive steps toward compliance. Extending revisions beyond practical simplifications would penalize these pioneers and discourage other businesses from following their lead. Such refinements should therefore align sustainability objectives with clear, actionable pathways for businesses, fostering transparency and engagement across all sectors of the economy. These regulations are not just about protecting the market—they are about enabling businesses to thrive, innovate, and contribute to the long-term prosperity of the European economy. Any deviation risks creating uncertainty and undermining the regulatory stability necessary for long-term progress and competitiveness.

We also recognize the crucial role of business and civil society organizations in monitoring the simplification process to ensure it does not inadvertently become a deregulatory agenda. Our vigilance is essential to preserving the integrity and ambitious impact of these frameworks, ensuring they continue to align with the business strategies of companies on their sustainable journey toward more resilient and competitive models that embed ecological and social objectives into their governance and operations.

In conclusion, we stand resolute in our commitment to collaborate with you and all relevant stakeholders to ensure that these regulations, vital to the future of both European business and global sustainability, remain robust, ambitious, and effective. The decisions made in this regard will resonate far beyond the immediate context and will shape Europe’s economic and environmental future for generations to come.

We thank you for your attention to this crucial matter and look forward to the opportunity to engage in further constructive discussions.

Yours sincerely,

The Business for a Better Tomorrow coalition

Over the past five years, the EU has made significant strides in developing policies and legislation to promote a more circular economy, particularly through the Circular Economy Action Plan. However, the EU’s Circular Material Use Rate has essentially stagnated, increasing only marginally from 10.7% in 2010 to 11.5% in 2022, highlighting the need to address gaps and strengthen implementation. As underlined by the European Environment Agency, these policies need to become more binding and target-oriented to accelerate the shift towards a regenerative economy in Europe. This means moving beyond the current strong focus on waste management to address resource use more directly. In the coming years, supporting Member States with the implementation of circular economy policies and demonstrating high ambition in preparing accompanying measures should also be a priority.

The appointment of a dedicated European Commissioner for Circular Economy is a critical step forward in the EU’s commitment to accelerating the transition to a circular economy. The central question is whether establishing a dedicated Circular Economy Commissioner would pave the way for a comprehensive sustainable materials and resources management framework.

In the context of the upcoming hearings for EU Commissioner-designate candidates, we, as NGOs, EU organisations, and leading sustainable businesses in the circular economy ecosystem, urge you, members of the European Parliament, to rigorously question potential candidates with portfolios related to resource sufficiency and the circular economy on the following topics:

✔ For a systemic vision on materials and resources within planetary boundaries: towards a resource-based systemic approach supported by binding EU resource use reduction targets on material and consumption footprint. This will be crucial for ensuring the long-term competitiveness of European industry and increasing the circular material use rate, as recognised in the June 2024 Council Conclusions.

✔ For the improvement of fiscal and economic tools: Shifting the tax burden from labour to raw material extraction, alongside implementing circular taxation, is essential for aligning economic incentives with the goals of a circular economy.

✔ For the inclusion of circular economy criteria within trade policy: the EU should lead in setting global circular economy standards, using trade policy and international instruments, such as the EU Carbon Border Adjustment Mechanism or the EU Deforestation Regulation, to promote climate neutrality, decarbonization, and a just transition worldwide. In line with the Ecodesign for Sustainable Product Regulation, instruments such as the CBAM could be expanded to address the resource intensity of imported products. Impact assessments should be a key component of EU trade and circular policy development. These assessments should evaluate the socio-economic implications for trading partner countries, including the impact on both formal and informal labour markets. To ensure comprehensive and reliable assessments, broad stakeholder consultation and independent research should be incorporated.

✔ For the improvement of the Extended Producer Responsibility framework to become a game-changing policy tool that supports prevention, reuse, separate collection, and high quality recycling: to prevent distortions and ensure a fair competition in the market, especially as EPR expands to more products, coordinated EU-level action is essential. The EU should therefore ensure adequate cost coverage provisions to fully implement the Polluter Pays Principle, establish an eco-modulation system designed for simplicity, practical application, and a focus on prevention and reduction, recyclability and recycled content. It should also address the free-rider problem through a comprehensive framework and tackle the limitations of EPR schemes when second hand products are exported for reuse from the EU to third countries. Finally, EPR schemes should be supervised by an independent advisory and monitoring body in which all the stakeholders are represented.

✔ For product lifespans extension and maintaining the long-term competitiveness of
European industry: a clear and progressive policy framework prioritising reduction, prevention, reuse, and recycling is crucial for boosting material and product circularity. The Circular Economy Act should place greater emphasis on the establishment of binding quantitative and qualitative targets at the product level as well as economic support for redesign, reduction, reuse and repair. The Circular Economy Act should also reaffirm the role of businesses as drivers of innovation and support their initiatives when it comes to integrating circularity practices into their business models.

✔ For a circular economy single market: Europe’s overdependence on primary material extraction carries severe social and environmental consequences, while also exposing the EU to new geopolitical vulnerabilities. A well-functioning circular single market, as mentioned in Enrico Letta’s report, would ensure a level playing field for circular materials, products and services enhancing the EU’s resilience against import shocks. As pointed out in the report, the EU must “establish a Circular Single Market where economic growth and well-being are no longer dependent on unsustainable use of natural resources and dangerous dependencies”.

✔ For public procurement as a key accelerator of circular economy deployment: Ursula von der Leyen has proposed to revise the Public Procurement Directive in her political guidelines for the new Commission. Thus, it is a good time to introduce circular public procurement requirements, with economic incentives and the possibility of penalties if public tenders continue to favour resorting to primary raw materials and business-as-usual models.

✔ For a circular economy supporting good quality jobs: the value of the circular economy should be clearly articulated and actively facilitated within the upcoming revision of the Just Transition Framework.

✔ For recognising the key role of local and regional authorities: the 2023 report from the European Court of Auditors highlights that there is limited evidence to suggest that the Circular Economy Action Plans have significantly influenced circular economy activities in Member States. Local and regional leaders, who are responsible for over 70% of Green Deal implementation, play a key role in this transition, as underlined recently by the letter from the Circular Cities Frontrunner Group, being the closest level of power to the citizens who are also consumers while being the competent authority to manage municipal waste. Many EU countries are failing to meet their recycling targets for municipal and packaging waste. Initiatives such as the Circular Cities and Regions Initiative, which supports large scale circular economy projects at local and regional levels, are vital in this regard. Local and regional authorities can significantly accelerate the circular economy by promoting circular public procurement, enhancing transparency and promoting fair competition. Furthermore, aligning the Cohesion Fund with local targets and increasing public private investment can unlock additional funding and support for circular initiatives.

✔ For ensuring sufficient funding for circular economy efforts: it is vital that European funding is properly allocated to invest in the top three steps of the waste hierarchy: prevention, re-use, and recycling. The existing strategies should also be aligned with new and emerging policy frameworks, such as the Net Zero Industry Act, to further drive investment in circular economy industrial development within the EU.

✔ For a safe and healthy circular economy: safety and human health must be a central part of the EU’s circular economy. Therefore, it must support ambitious measures outlined in the Chemicals Strategy for Sustainability, such as to phase out the most harmful substances in consumer products.The Circular Economy must promote clean manufacturing and non-toxic materials cycles.

✔ For ensuring the implementation of the legislation: with the recent increase in policy measures, it is now important to assess how effectively these policies are being implemented and to evaluate their overall impact. Additionally, ensuring the timely and accurate implementation of EU circular economy policies is essential, along with taking swift and decisive action against incorrect transposition and non-compliance.

Honourable members of the European Parliament and national representatives,

Trust is easy to lose and hard to regain – and current practices for communicating environmental information are rapidly eroding public trust in green claims, as recently shown by a consumer survey conducted by the European Consumer Organisation (BEUC). The Green Claims Directive is Europe’s best chance to eliminate greenwashing.

By guiding businesses to have confidence in the claims they can make, this Directive could set the foundation necessary to repair a market failure that is costing rather than rewarding businesses for sustainable innovation.

We, the undersigned (civil society organisations and businesses across Europe), call on the Council and Parliament to support a robust Directive with a meaningful verification procedure and clear rules on environmental claims to protect consumers and sustainable businesses.

In particular, two key provisions are needed to achieve more sustainable consumption:

1. Ensure the efficient verification of all claims before they enter the market.
Today, half of environmental claims on the market are either misleading or misuse methods of substantiation. Market authorities cannot enforce current legislation sufficiently due to the sheer number of claims whilst traders face legal uncertainty and fragmentary enforcement. Smaller businesses that cannot afford the best lawyers and who cannot risk enforcement are the most disadvantaged. Including verification ex-ante by default would eliminate greenwashing from the start and support businesses in managing legal risks from greenwashing. The process should be swift, manageable, and affordable.

2. Prevent misleading environmental claims relying on ‘offsetting’ of environmental impacts, including at the traders’ level.
The EU’s Empowering Consumers for the Green Transition Directive, national regulators, and Courts have all recognised that ‘offsetting’ is a highly flawed concept that does not align with scientific evidence. Instead, the Directive should enable companies to communicate about their contribution to environmental projects outside of their value chain, with no notion of compensation.

The Green Claims Directive is a major milestone of the New Consumer Agenda and the European Green Deal – and it is as urgent as ever to put it into action. We firmly believe that these provisions will ensure that consumers receive truthful information about the real environmental impacts of products and traders.

We urge you to support and enhance the sound provisions proposed by the European Commission and the co-legislators, as proposed in this letter.

We are deeply concerned that the strategic work on standardising corporate sustainability disclosures in the EU is being wrongly portrayed as a threat to competitiveness, and particularly by the implications of President Ursula von der Leyen’s recent announcement of an Omnibus proposal. This was preceded by recent debates in the EU Parliament on the “abolition of unnecessary burdens and reports”, and statements by representatives of the German and French governments.

This one-sided representation seems to serve a full deregulatory agenda, not a simplification initiative to support objectives of this legislation and to support companies in their sustainable transition towards more resilient and competitive business models. It undermines the European Commission’s own statement that “Sustainable finance facilitates re-orientating investment towards sustainable economic activities. It is an essential part of the European Green Deal”, which depends on readily available, comparable and reliable sustainability information. Companies need clarity and banks and investors expect better quality and comparability of ESG data following the implementation of the CSRD next year. Instead of playing ping-pong with the legal framework, we strongly encourage focusing on smart and easy implementation and consider the current lack of key data relevant for the economic transformation.

President von der Leyen asked EU Commissioner Albuquerque in her mission letter to focus on scaling up sustainable finance. To achieve this goal, transparency and standardisation of sustainability reporting is critical. The focus should be, as noted by the President, on implementation and ensuring that rules are easy to comply with.