A coalition of organisations within the packaging value chain has issued a plea to EU legislators, urging the removal of references to ‘state-owned producer responsibility organisations’ (PROs) from key sections of its draft Packaging and Packaging Waste Directive (PPWR).

According to the groups, the proposed inclusion of such provisions could have far-reaching consequences, impeding progress and undermining the EU’s global leadership on extended producer responsibility (EPR).

Concerns raised over state-run PROs’ mandate and functionality

Expressing deep concern, the signatory organisations highlighted issues with the last-minute insertion of references to state-run PROs in the European Council’s general approach.

Of particular concern is the notion that these PROs would operate without a represented producer mandate, essentially serving as entities solely responsible for tax collection and aiding Member States in meeting reporting obligations.

The signatories argue that such an interpretation contradicts the core function of PROs, which is to manage and fulfil producers’ responsibilities.

Potential reversal of progress and impact on recycling goals

The coalition emphasises that the proposed provisions, if adopted, could result in a setback to the progress achieved through the 2018 revisions of the Waste Framework Directive and the PPWD.

This, it argues, could not only compromise the EU’s ability to lead in global EPR initiatives but also pave the way for legal loopholes that Member States might exploit to evade their legal obligations.

Additionally, the coalition’s organisations stress that the envisaged changes could lead to a decline in packaging recycling rates, hindering producers’ ability to meet their obligations and fulfil the minimum requirements for packaging placement on the market.

Such consequences, they warn, would directly undermine the core recycling objectives of the PPWR and jeopardise the EU’s Green Deal commitments, including the goal of achieving net zero by 2050.

Industry urges deletion of references to state-owned PROs

In light of these concerns, the undersigned organisations are calling on EU legislators to remove references to state-owned PROs in recital 97a, Article 39.7b, and Article 42.6 of the draft PPWR.

They argue that this step is essential to preserve the integrity of EPR schemes, protect the achievements of past legislative revisions, and ensure continued progress towards the EU’s ambitious recycling and sustainability goals.