by Sam Smith, December 16th, 2019
Sam is an EC4P Compliance Consultant helping companies identify their legal exposure to WEEE, Batteries and Packaging legislation and providing cost-effective and legally-robust recommendations for compliance.
EC4P first reported on the EU’s new Circular Economy Package (CEP) in June 2018
when France announced plans to exceed the requirements of the CEP.
Since then, most member states have suggested amendments to their
regulations to transpose the CEP ahead of the 05 July 2020 deadline.
This update gives a brief overview of the notable actions that certain member states have taken during 2019 and what it could mean for packaging producers in 2020.
Guided by the Circular Economy Roadmap, France has continued to be proactive in preparing new CEP initiatives. One expected amendment will obligate online retailers to prove that all of the products sold through their platform have had an ‘eco-contribution’ paid on their behalf – increasing non-complaint producer’s exposure to penalties.
has also been very proactive in planning their transposition of the CEP
and promoting their commitment to creating a circular economy,
increasing their recycling rate and achieving carbon neutrality by 2035.
The 'Plastic Roadmap Network', submitted a report on implementing the
CEP in September 2019 and suggested:
Whilst these amendments are being considered, Finland's latest schedule of legislative projects plans to meet the CEP transposition deadline.
Although it was expected that before the end of 2019 a Decree would make EUR 140 million available for circular economy research and development projects, how Italy will transpose the CEP is still very unclear. For example, a draft of the 2020 Budget Law planned to introduce a tax of EUR 1 per kg on plastic packaging and certain Single Use Plastic (SUP) products from April 2020. The tax is open to modulation and includes incentives to use biodegradable materials but it was so heavily criticised by industry that the Italian Government have already backtracked with an amendment to half the tax. Full details on the scope and how this will be implemented is expected in early 2020.
Netherlands first released plans to create a circular economy in 2016
and although several agencies have subsequently worked on developing
indicators to progress the circular economy, little progress has been
made. A draft Decision on EPR may change this as it plans to uniformly impose fundamental requirements on producer responsibility organisations (PROs) for all waste streams under a single text. Released for comment in July 2019 and if adopted ,would apply from 2023, PROs would be required to:
draft regulation on Packaging and Packaging Waste, released in June
2019, proposes to transpose the amendments of the EU's Circular Economy
Package (CEP) and to fix the shortcomings of the current packaging
regime. The draft notably proposes:
EC4P continually monitor the evolution of WEEE, Batteries and Packaging legislation around the world and the EU’s CEP is just one area of development which will bring new requirements, challenges and opportunities for producers. EC4P offer a range of services to help companies manage their extended producer responsibilities. This includes keeping clients up to date with legislative changes, assessing whether any action is needed and identifying the best solutions to ensure compliance. For full details about our services please contact us.
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