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First-Vice President Timmermans
European Commission
Rue de Loi, 200
Brussels, 28 November 2014
B-1049 Brussels
Subject: Circular Economy Package – Revision of the Packaging & Packaging Waste Directive
(94/62/EC)
Dear Mr. Timmermans,
I am writing to you on behalf of the members of the Alliance for Beverage Cartons and the
Environment (ACE) concerning the Circular Economy Package. As an industry based on renewable
resources and committed to recycling, we fully support the goals of the Circular Economy and
believe it can help contribute to the wider Commission agenda on jobs and growth over the
medium to long term.
While the new Commission may have concerns about the need to review some existing and
proposed legislation originating from the previous Commission, we believe that the Circular
Economy Package, despite some of the challenges it poses, is a basis for addressing a range of
outstanding issues of concern for waste management and resource recovery which impact Member
States, municipalities and industries, including our own.
The proposal is already in the co-decision process with the Council now actively working on the
package and indeed seeking to address directly some of the more problematic aspects. We believe
the outcome of this work coupled with input from the Parliament will actually greatly improve the
technical and economic feasibility of what has been proposed. As a key player in the process, the
Commission too can provide further input into the refinement/clarification of its own proposal.
From our specific point of view, to stop or withdrawn the proposal at this point risks exacerbating a
trend we see towards fragmentation of packaging waste producer responsibility schemes which are
critical to the success of the PPWD in ensuring packaging waste is recovered and recycled.
ACE member companies are at the leading edge in terms of packaging innovation, resource and
energy efficiency as well as recycling and materials recovery – all critical to high value jobs and
economic growth. We see the Circular Economy Package supporting this agenda as long as it is
adjusted in order to prevent unintended barriers to increased recycling of our packaging. We
therefore, respectfully urge you and your colleagues to allow the legislative package to proceed
through the co-decision process.
Yours Sincerely,
Erika Mink, President
CC. Mr. Karmenu Vella, Commissioner for Environment, Maritime & Fisheries Affairs; Catherine Day,
Secretary General
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