Position Papers

30 Jan 2024

APEAL / MPE Position Paper PPWR January 2024

APEAL, representing the steel for packaging sector, and MPE, representing the rigid metal packaging industry, welcome the direction taken both by the European Parliament (EP) and the Council on the Pa...
15 May 2023

PPWR proposal – Permanant Materials Alliance suggested amendments

The Permanent Materials Alliance brings together Steel for Packaging Europe, formerly known as APEAL, European Aluminium, the European Container Glass Federation (FEVE) and Metal Packaging Europe....
17 Apr 2023

APEAL position on packaging and packaging waste regulation (PPWR) proposal com(2022)0677

APEAL welcomes the general approach taken by the Commission with its Packaging and Packaging Waste Regulation (PPWR) proposal, but believes that more is to be done to fully close the circular loop....
24 Feb 2022

European Commission’s call for evidence for revision of the EU waste framework

In light of the call for evidence for the upcoming revision of the Waste Framework Directive, APEAL submitted the attached Position Paper  on 21st February 2022....
06 Dec 2021

APEAL position paper on harmonisation of separate collection of municipal waste

The EU’s Circular Economy Plan (CEAP) commits the Commission to investigate the impact potential for harmonising separate waste collection systems across the EU, a study which the JRC is currently e...
30 Sep 2021

APEAL position paper on “The Definition of Recycling”

APEAL has actively participated and contributed to the stakeholder’s consultation by the Joint Research Centre (JRC), in collaboration with DG ENV, on the “Assessment of the definition of recyclin...
12 Jul 2021

APEAL position paper on the review of the Packaging and Packaging Waste directive (PPWD)

In 2020, the European Commission adopted the new circular economy action plan (CEAP) . It is one of the main building blocks of the European Green Deal, Europe’s new agenda for sustainable growth...
12 Jul 2021

Permanent Materials Coalition position paper on the review of the Packaging and Packaging Waste directive (PPWD)

Within the context of the European Green Deal (EGD) and the new Circular Economy Action Plan (CEAP), the European Commission is reviewing the requirements on packaging and packaging waste in the E...
14 Jun 2021

APEAL position paper for the revision of the REACH regulation

The European Commission has opened a public consultation to allow all interested stakeholders to engage with the revision of REACH regulations. Here attached the contribution from APEAL....
15 Oct 2020

APEAL position paper on European Parliaments Own Initiative report on Circular Economy Action Plan 2.0

APEAL welcomes  MEP Huitema’s draft report on the new Circular Economy Action Plan 2.0. Alongside the Europe’s other permanent materials (glass and aluminium) the steel industry would like to...
01 Sep 2020

APEAL input to EC public consultation on substantiating green claims

APEAL welcomes the EC public consultation initiative on substantiating green claims. We support the EC establishing legal framework that provides a level playing field, limits the proliferation of...
18 Jun 2020

APEAL Position Paper on the European Parliament’s Own-Initiative report on the Circular Economy Action Plan 2.0

On 12 March, the European Commission adopted a new Circular Economy Action Plan - one of the main building blocks of the European Green Deal, Europe's new agenda for sustainable growth. With measures...
16 Jun 2020

APEAL input to the DG Environment open consultation on packaging waste prevention

APEAL recently participated in a webinar (26.05.20) and workshops (28-29.05.20) on the subject of packaging waste prevention. The consultation was organised by Eunomia and the EU's DG Environment,...
14 Feb 2020

APEAL input to the public consultation for EC’S Roadmap for the next Circular Economy Action Plan

Circular economy – Commission’s New Action Plan to increase recycling and reuse of products With the European Green Deal for the European Union (EU), the Commission resets its commitment to tackl...
28 Jan 2020

APEAL position on recycling average loss rates 2020

APEAL supports the Commission’s decisions 1) that the measuring of the recycled packaging waste tonnages must occur at the entrance of the recycling operation, being the so-called calculation poi...
18 Oct 2019

Discussion points on mandatory extended producer responsibility (EPR) schemes and eco-modulated fees for packaging

Europe’s glass, steel and aluminium industries for packaging fully support the European Commission’s ongoing work to develop secondary legislation on introducing the concept of eco-modulated fees...
21 Jun 2019

Joint metals and glass position paper on the Essential Requirements for packaging

In the context of  the EC revision of the Essential Requirements for packaging (stimulating good practices in packaging design suitable for the circular economy),  APEAL, Eurofer, Eurometaux, Europe...
07 Jun 2019

APEAL position paper on current authorisation status of hexavalent chrome

REACH Committee Favourable Vote on AfAs 0032-05/06 and 0043-03 regarding Authorisation for Electrolytic Tin Plate (ETP) and Electrolytic Chrome Coated Steel (ECCS) APEAL – the Association of Eur...
07 Jan 2019

Joint Ferrous and Non-Ferrous Metals Position Paper on methodology and reporting of recycling rates

APEAL's recommendations for continued ambition in the calculation methodology and reporting for metals recycling rates, issued together with Eurometaux, Eurofer and European Aluminium....
20 Jun 2017

APEAL Statement on the continued use of chromium VI in the production of steel for packaging

Following the ECHA recommendation, APEAL expects the Commission to grant authorisation for the temporary continued use of chromium VI for the production of steel for packaging. The steel for packagi...
22 Dec 2015

APEAL Circular Economy Position document

The steel packaging industry welcomes the European Commission dossier on the Circular Economy. This paper complements the European Steel Association (Eurofer) Circular Economy position paper “The ro...
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