Ref. Ares(2021)5737909 - 20/09/2021
UNESDA – Soft Drinks Europe calling for Roadmap on New Circular Economy Action Plan to
build on existing EU legislations to accelerate the transition towards a circular model while
ensuring legal and regulatory stability
From linear to circular – speeding up the transition
UNESDA and its members have been driving sustainability throughout their value chain for the past 30 years.
We fully supported the Circular Economy Package adopted by the EU in 2017 and its objectives to build a circular
economy, and we continue to support this objective. We also welcome the publication of the communication
on the European Green Deal and its ambition of making Europe the world’s first climate-neutral continent by
2050.
We agree with the identified chal enges listed in the Roadmap: indeed, empowering consumers, boosting
sustainable products policies, reducing waste generation, creating a wel -functioning secondary raw materials
market and speeding up the transition from a linear model to a circular one wil al be key to create a circular
economy. The transition has already started: we wil use 25% recycled content in packaging in the next five years,
and our members are committed to going significantly beyond if the supply of food-grade quality rPET is secured
accordingly. UNESDA pledged to increase col ection rates and to reuse packaging, e.g. refil able bottles, where
it makes environmental and economic sense. Col ection rates for PET are already above 80% in a number of EU
countries (Sweden, Belgium) and even above 90% in others (Denmark, Norway, Germany) and efforts are
accelerating in other countries to achieving similar col ection rates.
Implementing existing EU legislations and reinforcing the principles of circular economy
We consider that it is crucial to first implement rules that were just adopted – in particular the review of the
Waste Framework Directive, the Packaging and Packaging Waste Directive and the Single-Use Plastics Directive
– whilst ensuring there is space for further innovation and solutions to make business and consumers practices
more sustainable.
Going further wil also require protecting the very principles of circular economy, meaning that a product that is
easily recyclable, col ected and recycled, must be considered as a full and legitimate part of that circular thinking.
We support al EU legislations ensuring that only safe and sustainable products can be put on the market and
we reaffirm the need to maintain the spirit of the Circular Economy package, implementing science-based
measures and considering reuse, repair and recycling as different tools that each contribute, when optimised,
to achieving circularity of the EU economy. For example, swift actions from the Commission must be taken on
authorising plastic mechanical recycling processes positively evaluated by EFSA as wel as on creating a
supportive legal framework for alternative plastic recovery technologies like enhanced recycling and feedstock
recycling. These alternative technologies are complementary to mechanical recycling processes and can boost
the internal market for safe secondary raw materials.
Circularity involves everyone and requires a holistic approach
Achieving a circular economy requires a multi-stakeholder approach, requiring the ful mobilisation of industry,
governments, consumers, academia and civil society. We invite the Commission to reference existing platforms
such as the Circular Plastics Al iance, working towards boosting the uptake of recycled plastics. Al parties should
be involved in a proportionate way: contributing to strengthening waste col ection systems must be a col ective
effort, as wel as funding clean-up costs for litter which should not fal solely on specific stakeholders.
Our members are working hard to be frontrunners in making both our products and packaging more sustainable
and we welcome al initiatives from the Commission to fast-track the transition from a linear to a circular model
in the years ahead.
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Electronically signed on 20/09/2021 14:15 (UTC+02) in accordance with article 11 of Commission Decision C(2020) 4482