Packaging Supply Chain Guiding Principles on EPR fee modulation & the legal review of the Essential Requirements for packaging

May 2019

In the context of the EU’s Circular Economy Package and particularly the Extended Producer Responsibility (EPR) general minimum requirements in the revised Waste Framework Directive (WFD) and the ongoing legal review of the Essential Requirements (ER) for packaging as laid down in the Packaging and Packaging Waste Directive (PPWD), the 57 undersigned organisations1 wish to share the following common guiding principles and recommendations for consideration as part of the ongoing related studies.
The following guiding principles are relevant for both policy initiatives. In addition, we make more specific recommendations for each of them, including with regard to the definition of “necessary costs” in relation to litter clean-up2 which is due to be partly covered within the guidelines on EPR fee modulation.

Please read full position paper here