dear commissioner potonik,on behalf of europen1 &ndash the european organization for packaging and the environment &ndash a crosssectoral industry body representing the packaging supply chain in europe, we would like to reiterate the importance of transitioning to a competitive and resource efficient economy. transforming waste into a resource is at the heart of achieving a circular economy.we believe that full implementation and enforcement of eu waste legislation in all member states in order to drive more recycling and recovery and to divert waste from landfill &ndash are necessary to ensure this transition to a resource efficient europe.the forthcoming review of the targets in the different waste directives waste framework directive wfd, landfill directive and packaging and packaging waste directive ppwd will play a critical role in this respect. europen sees the review of eu waste management targets as an opportunity to ensure the continued relevance and effectiveness of the ppwd in a changed regulatory and market setting.we hence call on the european commission to take the following remarks into consideration1. europen wishes to reiterate that the ppwd is a harmonisation measure, i.e. it establishes common rules that help enable packaging and packaged goods to trade freely and easily throughout the eu, safeguarded by the internal market legal base. it defines minimum &lsquoessential&rsquo requirements for packaging design together with overall and material specific targets for used packaging that must be recycled or recovered in the member states. this intrinsic link reflects lifecycle thinking, and should remain so, also accurately reflected in the directive&rsquos title, i.e the packaging and packaging waste directive.2. recycling and recovery targets for packaging waste should remain in the ppwd. the ppwd remains the appropriate legislative framework for driving recycling and recovery of all packaging waste, irrespective of the waste stream in which it arises. the packaging targets need to be structured differently from those in the wfd. it ensures that the investments in infrastructure and systems for the separate collection of used packaging for recyclingrecovery remain in place and in some cases are developed further.3. packaging waste targets should be achievable and realistic, taking into account different member state levels of performance, consumption rates and infrastructure capacities, and should be based on1 europen the european organization for packaging and the environment is an eu industry association in brussels presenting the opinion of the packaging supply chain in europe, without favouring any specific material or system. europen members are comprised of multinational corporate companies spanning the packaging value chain raw material producers, converters and brand owners plus five national packaging organizations all committed to continuously improving the environmental performances of packaged products, in collaboration with their suppliers and customers. www.europenpackaging.eu2harmonised rules for calculating and reporting packaging recycling and recovery rates, as well as packaging placed on the market. the definitions of recycling and recovery should be harmonised with those in the wfd.4. postconsumer packaging2 collection should be encouraged in the ppwd. collection of postconsumer packaging separately from organic or industrial, commercial and institutional packaging waste is essential to ensure sufficiently high levels of both quality and quantity to meet existing and future recycling targets and to make recycling and recovery economically viable and environmentally beneficial.5. binding minimum requirements on extended producer responsibility epr for used packaging should be enshrined in the ppwd along with clearly assigned roles and responsibilities for member states, municipalities and economic operators see below in annex 1. these should be codified, along with a requirement for member states to implement and enforce national authorisation procedures for epr compliance schemes. a waste streamspecific regulatory approach for epr in the ppwd is essential because the roles and responsibilities and challenges for packaging and packaging waste are different to those for other waste streams where epr exists, in terms of volume, consumer visibility, recycling value and market structure.the implementation of epr for used packaging has a proven track record for organising the recovery of materials and closing the loop. europen members reiterate the european resource efficiency platform&rsquos call to use the opportunity of the waste policy review to make epr compliance schemes more efficient and effective in order to support the transition to a circular economy. europen and its members look forward to providing continued support to this important review process.further details of these points and additional viewpoints can be found in our position papers enclosed. should you require any further clarification, i remain at your disposal.yours sincerely,virginia janssensmanaging director 
