Brussels for Human Rights and Developments (BHRD) welcomes the European Commission’s draft act on Single-use plastic beverage bottles EU rules for calculating, verifying and reporting on recycled plastic content. We believe that the act is a significant step forward in the EU’s efforts to reduce plastic waste and promote the circular economy.

We support the following key provisions of the draft act:

-The requirement that all producers of single-use plastic beverage bottles in the EU must calculate the recycled plastic content of their products.
-The requirement that producers verify the accuracy of their recycled plastic content calculations. The requirement that producers report their recycled plastic content calculations to the European Commission.

We believe that these provisions will help to increase the transparency of the recycled plastic market and make it easier for producers to find and use recycled materials. We also believe that these provisions will help to reduce plastic waste incineration and landfill.

We have a few suggestions for improving the draft act:

-We suggest that the act be extended to include other single-use plastic products, such as straws, stirrers, and cutlery.
-We suggest that the act include a requirement for producers to use recycled plastic in their products. We suggest that the act include a financial incentive for producers to use recycled plastic in their products.
-We believe that these suggestions would further strengthen the act and help to achieve its objectives. We thank the European Commission for its work on this important issue.
-We look forward to working with the Commission to ensure that the act is adopted and implemented effectively.

In addition to the above, we would like to highlight the following specific concerns:

-The draft act does not include any provisions to address the human rights impacts of plastic production and disposal. We believe that it is important to ensure that the transition to a circular economy does not lead to new human rights abuses, such as forced labor or environmental degradation.
-The draft act does not include any provisions to address the issue of plastic pollution in developing countries. We believe that it is important to ensure that the EU’s efforts to reduce plastic waste do not lead to a disproportionate burden being placed on developing countries.

We urge the European Commission to address these concerns in the final version of the act.

The Feedback on the European Commission Website