Joint industry letter on Single Market distortions

The 1st of January 2023 will mark the 30th anniversary of the establishment of the European Single Market. One of the EU’s greatest achievements, the Internal Market is the key driver of EU economic integration. This has been essential to the growth of the European economy and remains crucial to Europe’s global competitiveness. It has brought about greater economies of scale while improving the allocation of resources and enabling the EU to set high harmonised safety standards for consumers and environmental protection.

Today, Europe faces new challenges and has new priorities. Chief amongst these is the European Green Deal and the need for a transition towards a circular and climate neutral economy. The packaging industry, the consumer goods industry and downstream operators understand this imperative and are fully committed to resource-efficient circularity goals. However, fragmentation of the Single Market due to countries taking divergent measures is undermining this commitment and hampering EU industry’s aspiration to lead the transformation towards a more sustainable economy. In light of this, the undersigned associations call on the EU to create one single circular economy not 27 separate ones, underpinned by an integrated Single Market.

Almost everything we consume is packaged. Packaging is an integral part of a product supply chain, and measures that relate to packaging affect most goods traded within the EU. Preserving the integrity of the Single Market is key to ensuring that packaging materials and packaged goods can move freely around the EU, thus avoiding negative impacts on consumers, companies, the environment and on the resilience of essential systems, such as the food and pharmaceutical sectors. Despite this, Member States are increasingly introducing unilateral and often divergent requirements. These are no doubt well-intentioned efforts to improve design, manufacture and labelling of goods to improve their potential for repair, re-use or recycling. Yet, many of these requirements pre-empt forthcoming legislative developments at EU level, compromising the effectiveness of an EU-wide approach.

The increasing number of national measures on the labelling of packaged goods for later sorting is a case in point. These are often implemented at short notice, are contradictory and are not always notified as Single Market rules require. We rely on the Commission to ensure that these divergent rules and their non-notification do not go undetected.

Concretely, disparate national packaging requirements impede the use of a single packaging execution and therefore require the redesign of all packaging across the entire Internal Market destined for an individual country. This has the adverse consequence of diverting investments away from other activities to advance sustainability, such as R&D on eco-design and digital traceability of product information for more efficient recycling.