ACEA backs the shift to a circular economy envisaged by the EU’s Packaging and Packaging Waste Regulation (PPWR). Yet, resource-inefficient repackaging requirements for spare parts may actually be detrimental to the environment if not addressed during trilogue negotiations.

ACEA is fully committed to accelerating the transition to a circular economy and welcomes the European Commission’s initiative to minimise the negative environmental impacts of packaging and packaging waste. The PPWR provides an opportunity to enhance the internal market and support the Green Deal’s objectives. However, law makers should address shortcomings in the European Commission’s proposal to accomplish these joint goals. In particular, we urge co-legislators to exempt packaging manufactured before the PPWR’s date of application from the regulation’s scope.

The automotive industry is obliged to ensure the supply of spare parts for an extended period of time (between 10 to 15 years) after a vehicle is produced. These spare parts must be provided to customers to ensure future maintenance and repair. Yet, they are already stored in packaging manufactured before the PPWR’s date of application.

To enhance waste prevention, European vehicle manufacturers strongly encourage law makers to apply a lifetime exemption to packaging produced before the PPWR’s date of application, as included in recital 11(a) of the Council’s General Approach – but with a focus on production and not on market placement. Repackaging these products at the time of sale would not be resource-efficient, generating unnecessary waste with no environmental benefit.