ECOS Position paper – European Commission Proposal for a Regulation on Packaging and Packaging Waste
ECOS publishes a position paper on the Packaging and Packaging Waste Regulation ahead of the negotiations in the European Parliament and Council, aiming to see the European proposal improved.

Much of the increase in packaging waste results from the omnipresence of packaging. Packaging is integral to business models with reduced labour intensity for service delivery – e.g., low-service restaurants, online shopping, etc. However, cutting costs by means of increased use of raw materials is going against the political ambition to build a sustainable circular economy.
ECOS key suggestions
- Packaging restrictions: allow local, regional and national administrations to adopt packaging restrictions beyond those adopted by the EU regulation.
- Packaging minimisation: restrict deviation from minimal packaging requirements on the grounds of marketing and consumer convenience.
- Reusable packaging: define the number of trips reusable packaging is meant to last for.
- Reuse systems: define minimum return rate of reusable packaging.
- Reuse target in HoReCa: refer to refill as “bring your own” and make it a right for consumers without derogations for small companies.
- Reuse target in retail: refill station requirements should only apply to refilling by customers in retail markets and refilling should not count towards achieving reuse targets.
Read the full paper, HERE.
Download the document