Mandatory extended producer responsibility (EPR) schemes and eco-modulated fees for packaging

Joint Paper on Discussion points on mandatory extended producer responsibility (EPR)
schemes and eco-modulated fees for packaging.
October 2019

Europe’s glass, steel and aluminium industries for packaging fully support the European Commission’s ongoing work to develop secondary legislation on introducing the concept of ecomodulated fees for the collection, sorting and recycling of packaging waste based on circularity.

We as the permanent materials coalition support the European Commission in particular:
✓ To draft a roadmap to ensure the introduction of mandatory EPR for packaging by 2024;
✓ To introduce the concept of recyclability in the eco-modulated EPR-fees;
✓ To introduce the concept of permanent materials in the eco-modulated EPR-fees;

Permanent materials can be recycled repeatedly with no loss of their main intrinsic properties and the
packaging made from these materials are easy collectable and sortable for high-quality recycling.
In order to keep glass, steel and aluminium packaging materials in the circular economy loop, we
support eco-modulation of fees to be paid by obliged industry that do reflect the recyclability of the
packaging and packaging material, considering:
• The actual recycling capability of the packaging;
• The potential to be recycled over and over again without loss of main intrinsic properties
(multiple recycling);
• The current and future recycling rates of each packaging material;
• The operational (such as sorting and collection for recycling) costs and revenues of the
packaging material avoiding cross-material subsidies;
• The most optimal collection and sorting infrastructure for each packaging material,
guaranteeing high quality material input for the recycling operation.

Please read the full position paper here