INTERIM REPORT OF ECOLAS PIRA FOR THE STUDY OF THE IMPLEMENTATION OF DIRECTIVE 94/62/EC ON PACKAGING AND PACKAGING WASTE AND OPTIONS TP STRENGTH PREVENTION AND RE-USE OF PACKAGING

*PRO EUROPE believes it is essential to take into account the state-of-the-art technology, demography as well as environmental and geographic factors in the Member States, in order to understand the effectiveness of Directive 94/62/EC.
*The impact analysis of the report contains too little information to make an appraisal of it and data is often out of date.
*The SOFRES study, used as the most important data source, only gives information on four countries.
*European legislation which has already been passed is not taken into account
*The interim report is basically descriptive and a lot of information is missing or incomplete.

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INTERIM REPORT OF THE STUDY ON THE PROGRESS OF THE IMPLEMENTATION AND IMPACT OF THE PACKAGING DIRECTIVE 94/62/EC ON THE FUNCTIONING OF THE INTERNAL MARKET

PRO EUROPE feels that it is too simplistic to assess that the Packaging Directive has not had any influence in the countries where national legislation was applicable before the Packaging Directive came into force. It is an underestimation  to say that the incremental costs of meeting the Directive's recycling and recovery targets are quite limited.

 To measure the effect of the Packaging Directive, PRO EUROPE proposes that only household packaging should be taken into account, whereas the study includes all types of packaging. Furthermore, the evolution of plastics is missing in the graphs analysing the recycling evolution of materials.

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EXTENDED IMPACT ASSESSMENT ON THE THEMATIC STRATEGY ON THE PREVENTION AND RECYCLING OF WASTE

PRO EUROPE considers that an optimal waste management strategy from an environmental, economic and social point of view should include a balanced combination of waste prevention, material recycling, energy recovery and disposal options.

Therefore, PRO EUROPE supports a waste policy based upon an evaluation of the environmental impact of the whole life of resources and products.
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