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Position Papers
Brussels, 24 november 1999

Euro Coop's Comments to the European Commission's Draft Proposal for a Revision of the Directive on Packaging and Packaging Waste (94/62/EEC)


Euro Coop is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 13 of the 15 member states of the EU and in 5 central and eastern European countries. Created in 1957, Euro Coop today represents over 3,200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the EU and 2 million in the associated countries of Central and Eastern Europe.

Euro Coop has ever since the first directive on Packaging and Packaging Waste (Directive 94/62/EEC) was drawn up called for the European Commission to introduce means to diminish the volume of packaging produced. Once more, the Commission has failed to address this issue.

In the draft proposal for a revision of the directive, it is suggested to reinforce the two concepts: Reuse and prevention in the relevant articles. However, the Commission only suggests practical means for the recycling concept but not for prevention. Euro Coop believes it is crucial that preventive means are introduced to get to the root of the problem, namely, less packaging produced, in order to obtain sustainable consumption in the long run. As such, prevention in terms of reduction of packaging and packaging waste must be the primary aim, followed up by specifying quantitative means in a revised Directive.

One way could be to increase the level of information available to users of packaging, in particular businesses and consumers. A higher level of information should make users aware of the environmental problems connected to packaging and packaging waste in order for them to change consumption habits in favour of a sustainable environment. It is essential that the information given provides transparency in the following areas concerning packaging waste management: the full costs involved, the price to pay, the environmental damages and health risks.

Euro Coop is in favour of introducing the principle of producer responsibility by making the producers in charge of the costs for the return, collection, reuse and recycling systems. It is an important principle to introduce in order to promote environmental responsibility among producers and traders, as well as to secure a reduction in packaging and packaging waste. In the current system society is paying and in the end the consumers. It seems only fair that the producers become directly responsible for use of packaging for their products by the introduction of the Polluters' Pay Principle (PPP).

Euro Coop would like to stress that the EU must commit itself to take legal action against Member States violating the Directive in order to secure proper implementation.