Category: Position Papers

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.

Subject: Safety of food contact materials: 20 years of inaction on EU’s basic rules

Dear President von der Leyen,

We, the undersigned, are deeply concerned about the current state of the EU Food Contact Materials Regulation revision (EC 1935/2004) due to its significant delay. The European Commission committed to updating these 20 year-old rules to better regulate harmful chemicals in food contact materials (FCMs) as part of the 2020 EU ‘Farm to Fork’ and ‘Chemicals Strategy for Sustainability’ initiatives. While new rules on recycled plastic in FCMs were introduced in 2022, the overall revision of the law is still pending.

FCMs, including food packaging, make up a large segment of consumer goods. Undeniable evidence shows that hundreds of chemicals possessing well-known hazardous properties are intentionally used in these products, made from both plastic and non-plastic materials. For example, more than 70 carcinogens were found in FCMs purchased from markets including the European Union. Thousands of FCM chemicals continue to be detected in human samples, such as urine, blood, and breast milk, with links to serious health effects, particularly for vulnerable populations like children and pregnant women. Many chemicals remain insufficiently tested, and current EU risk assessments do not address their cumulative toxicity.

This regulatory failure is contributing to rising health concerns. The EU is seeing an increase in cancer rates, infertility, and metabolic diseases like Type 2 diabetes. The estimated cost of exposure to endocrine disrupting chemicals, including phthalates and bisphenols found in food packaging, is €157 billion annually.

There is also growing evidence of health risks associated with some alternative materials introduced after the Single Use Plastic Directive. Studies from the Netherlands and Belgium highlight the potential dangers of these materials, making it crucial to harmonise and strengthen EU regulations on all FCMs to ensure consumer safety.

Therefore, along with political demand for long term competitiveness, sustainable circular economy solutions and creation of a strong secondary materials market in the EU, the critical aspect of safety of all food contact materials, both conventional and alternative, virgin and recycled, cannot be left behind any longer.

We thank you for your consideration of this important matter and remain at your disposal for any questions you may have.