ESPO welcomed in particular proposals the definition of catering waste which would increase the quantities of recycled plastics and contribute to the targets of the European Plastics Strategy.

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However, ESPO believes that the 'polluter pays' principle needs to be strengthened. Introducing a fee system where ships would deliver unreasonable quantities of garbage, including dangerous waste for a fixed fee would be a severe divergence from the 'polluter pays' principle, as it risks to discourage reducing waste at the source.

ESPO's Secretary General, Isabelle Ryckbost, noted:

Overall, the report pursues the objectives of the circular economy and aims to reduce administrative burden for authorities and stakeholders. We strongly believe however that the ‘polluter pays’ principle needs to be better reflected in the new Directive. We cannot accept a regime whereby ships are not incentivised to limit waste at the source and ports have to carry the costs of delivering unreasonable amounts.

Additionally, ESPO opposed to the automatic reduction for green ships. Any green reduction, if not corresponding to a real cost reduction, will weigh the port authority. It said that "any mandatory green rebates for waste, as proposed by the Commission proposal, would prevent ports from addressing local environmental challenges."

The European Commission is also preparing an EU submission to the IMO proposing a 100% indirect fee without quantity thresholds at international level.