PUBLICATIONS
Position Papers
Read our latest papers, publications and download our reports to stay updated on Circular Economy and to find out the latest news about EucoLight and its members.

Position Papers

Position Papers
16 May 2025

Joint Industry Statement on State-run Producer Responsibility Organisations

EucoLight joins over 50 organisations in a joint statement against State-run producer responsibility organisations. The undersigned organisations deplore the recognition of state-run producer responsibilityorganisations (PROs) in the final text of the revised Waste Framework Directive (WFD), a regrettableprecedent also set in the new Packaging and Packaging Waste Regulation and Batteries Regulation. The undersigned organisations therefore […]

EucoLight - Publications
18 September 2024

Joint Statement – European stakeholders for a level playing field for online marketplaces and effective enforcement

NGOs and European industries are once again joining forces to urge EU policymakers toprioritise closing legal loopholes in the regulation and enforcement of online tradevia online marketplaces during the 2024-2029 mandate. Online marketplaces play a significant role with a growing number of consumers todayengaging in e-commerce, matching buyers and third-party sellers, attracted by benefitssuch as […]

EucoLight - Publications
28 June 2024

Joint Letter: Call against the inclusion of State-Run Producer Responsibility Organizations in EU legislation

EUCOLIGHT and several prominent European organizations, including EXPRA, CEFLEX, WEEE Forum, EUCOLIGHT, EUROPEN, The Slovak Association for Branded Products, and Flexible Packaging Europe, are publishing a joint letter expressing strong concerns about the recent legitimization of state-run Producer Responsibility Organizations (PROs) in EU legislation. This concept, recently included in the Batteries and Packaging & Packaging […]

EucoLight - Publications
22 September 2023

EUCOLIGHT RESPONSE TO THE PUBLIC CONSULTATION ON THE EVALUATION OF THE WEEE DIRECTIVE

EucoLight complemented its response to the public consultation questionnaire with a position paper, pointed out several issues that need to be addressed in the context of the revision of the WEEE Directive, while making a series of recommendations. Our recommendations in brief:

EucoLight - Publications
4 November 2022

EUCOLIGHT RESPONSE TO THE CALL FOR EVIDENCE FOR THE EVALUATION OF THE WEEE DIRECTIVE

EucoLight responded to the call for evidence for the evaluation of the WEEE Directive making a series of recommendations on the following issues: Scope and WEEE definitions WEEE definitions Subcategories for lighting Same rules for all actors Data transparency and control mechanisms Compliance with extended producer responsibility obligations associated with online sales, the online-free riding […]

EucoLight - Publications
16 August 2022

EUCOLIGHT RESPONSE TO THE PUBLIC CONSULTATION ON THE REVISION OF THE WASTE FRAMEWORK DIRECTIVE (WFD)

EucoLight responsed to the public consultation on the revision of the Waste Framework Directive making a series of recommendations on key priorities:

EucoLight - Publications
1 February 2022

EUCOLIGHT FEEDBACK ON THE CALL FOR EVIDENCE: ENVIRONMENTAL IMPACT OF WASTE MANAGEMENT- REVISION OF EU WASTE FRAMEWORK

EucoLight responsed to the call for evidence for an impact assessment on revision of EU waste framework making a series of recommendations on:​

Position Papers
2 May 2021

EUCOLIGHT POSITION PAPER ON THE PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON A SINGLE MARKET FOR DIGITAL SERVICES (DIGITAL SERVICES ACT) AND AMENDING DIRECTIVE 2000/31/EC

EucoLight  position paper addressing the responsibility of online marketplaces regarding non-compliant products. EucoLight commends the European Commission for its efforts to propose, with the Digital Services Act (DSA), new obligations on online companies to address concerns about illegal content. But there is room for improvement to address the responsibility of online marketplaces. EucoLight main recommendations: […]

Position Papers
16 July 2019

EUCOLIGHT AND LIGHTINGEUROPE JOINT POSITION PAPER ON ECO MODULATION OF FEES IN WASTE FRAMEWORK DIRECTIVE (EU) 2018/851

EucoLight and LightingEurope, as two EU wide trade associations with unique insight into the lighting industry, have prepared this position paper to consider how modulated fees might be applied to lamps and to luminaires.

Position Papers
25 January 2019

POSITION PAPER ON THE PUBLIC CONSULTATION ON THE EU PRODUCT POLICY FRAMEWORK CONTRIBUTING TOWARDS A CIRCULAR ECONOMY

EucoLight answers the public consultation, noting the lack of necessary questions about implementation, emphasizing that Extended Producer Responsibility is the best policy option for the management of waste and calling for improving legislation in several issues.

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