Position Papers
Position Papers - Ireland (EN) Skip to content Search for: Member login Retailer Registration Toggle Navigation Country Select country ERP Global Austria Brazil Canada China Denmark Finland France Germany India Ireland Select country Italy Japan Netherlands Norway Poland Portugal Slovakia Spain Sweden United Kingdom Toggle Navigation Who are you Producer Retailer Consumer School Collection Point B2B Who are we About ERP Circular Economy What we cover Waste streams WEEE Batteries Services Compliance B2B Marketplace Seller EPR Regulatory Info Services Solar Industry Solutions Global solutions What´s up News FREE Recycling Events Learning Center ERP Sustainability Programme Contact Search for: Country Country Select country ERP Global Austria Brazil Canada China Denmark Finland France Germany India Ireland Select country Italy Japan Netherlands Norway Poland Portugal Slovakia Spain Sweden United Kingdom Member login Position Papers admin 2026-09-11T15:10:15+01:00 Frontpage > Position Papers Position Papers Joint Letters Joint letter on proposed unitary own resource on non-collected e-waste (October 2025) Studies Study comparing EPR schemes (July 2021) White Papers Landbell Group paper on competition as a policy tool for effective EPR (November 2025) Landbell Group Paper Refining Extended Producer Responsibility to Boost The Circular Economy (October 2024) Landbell Group Paper Refining Extended Producer Responsibility to Boost The Circular Economy – summary (October 2024) Position Papers ERP Position Paper on the Evaluation of the EU Rules on Single-Use Plastics (March 2026) ERP Position Paper on the Circular Economy Act (November 2025) ERP Calls to Restore July Vote on WFD (May 2025) ERP Comments on Proposed WFD Amendments on Textiles (October 2023) ERP Position Paper on the Evaluation of the EU Rules on WEEE (September 2023) Comments on the Revision of the Packaging Directive (May 2023) Comments on the proposed amendments to the Directive on Waste Electrical and Electronic Equipment (April 2023) ERP Comments on the Proposal for a New Regulation on Packaging and Packaging Waste (March 2023) ERP Comments on the Evaluation of the EU Rules on WEEE (November 2022) ERP Position Paper on the Planned Revision of the Packaging and Waste Packaging Waste Directive (June 2022) ERP Position Paper on the Planned Revision of the EU Waste Framework Directive (February 2022) Joint Position Paper on Deposit Refund Schemes for Batteries (February 2022) ERP Position Paper on Eunomia Impact Assessment for Packaging and Packaging Waste Directive (July 2021) ERP Position Paper on European Commission’s Proposal for Regulation concerning batteries and waste batteries (March 2021) ERP Position Paper on the Review of Concentration Limits for Persistent Organic Pollutants Regulation (July 2020) ERP Comments on the Planned Modernisation of the EU’s Batteries Legislation (June 2020) Joint Position Paper on the Recast of the Persistent Organic Pollutants Regulation (September 2018) ERP Position Paper on Guidelines for the Circular Economy Package (June 2018) ERP Position Paper on Circular Economy Package (April 2018) ERP Position Paper on EU Plastics Strategy (January 2018) ERP Updated Position Paper on Waste Framework Directive as part of EU Circular Economy Package (December 2017) Discussion Papers and Initial Proposals ERP Discussion Paper on AR and Reporting Frequency, Environmental Omnibus (May 2026) ERP comments on the Eunomia Draft Report on EPR Guidance (January 2020) ERP Discussion Paper on Modulated Fees (June 2018) ERP Initial Proposal on Circular Economy Roles and Responsibilities (July 2017) Contribution Papers ERP Contribution to Stakeholder Consultation on Revision of EU rules on food contact materials (January 2021) ERP Contribution to Stakeholder Consultation on Waste Shipment Regulation (April 2020) ERP Contribution to Stakeholder Consultation on EU Battery Directive (November 2017) ERP Comments on Draft Commission Regulation for Harmonized