JBCE’s Answer to ECHA’s Call for Evidence on Substances in Packaging and Packaging Waste

28/10/2025

Date: 28/10/2025

JBCE has submitted its response to the European Chemicals Agency’s (ECHA) call for evidence regarding substances of concern under the Packaging and Packaging Waste Regulation (PPWR).

Key recommendations include:

• Avoiding duplication with existing legislation.
• Clarifying the definition of substances of concern/information acquisition.
• Using scientific evidence and risk-based assessment.
• Aligning with circular economy objectives.
• Ensuring transparency and stakeholder engagement.

JBCE recommends that ECHA designs the PPWR framework in a way that is consistent with existing laws, scientifically sound, and practical for global supply chains. JBCE supports the objective of protecting the environment while ensure that it does not impose unnecessary burdens on industry.

JBCE details its views and insights in its position paper, which can be downloaded below.

For more information please contact:

Shigeto Omae

Policy Manager

Environment & Energy

This email address is being protected from spambots. You need JavaScript enabled to view it.

Download documents:

JBCE Position Paper